Part of what makes organic farming “organic” are the written regulations that provide the legal definitions and rules. Organic farming regulations provide consistency and a sense of trust in the system. What follows is my attempt to share what I am learning about those rules and the process involved in maintaining or changing them.
For many years I have shared with students in the MSU Organic Farming Principles and Practices class my perception that organic farming rules and regulations were on pretty solid ground and provided a strong dependable foundation. That perception was based on my reading of the 1990 Organic Food Production Act (OFPA), the actions of the USDA National Organic Program (NOP), and personal interactions with people involved in the National Organic Standards Board (NOSB) or as organic certifiers or inspectors or as certified organic farmers. I am disappointed to say that one of the outcomes of serving on the USDA Task Force (2015-2016) for Organic Hydroponics is that I have much less confidence in the people responsible for administering and implementing the USDA-National Organic Program (NOP), the role of the National Organic Standards Board (NOSB), and the NOP-accredited agencies implementing organic certification.
The Organic Hydroponic and Aquaponic Task Force was formed to gather relevant information pertaining to the alignment of hydroponic growing with organic regulations. We were repeatedly reminded from the start that our task was not to make recommendations but instead to provide information for the NOSB to use to help them make recommendations. The perspectives of the members of the Task Force were so divided from the start that a decision or recommendation would not have been possible. Part of the committee had been involved in organic farming certification, regulation, education or production for many years and were looking to maintain the historical expectations. Others on the committee were new to organic farming and mostly looking for a way to do greenhouse production that could be certified organic and therefore would benefit from the organic price premium. The subcommittee I served on had over 150 years of organic farming experience. My perception is that the other subcommittee had experience with hydroponics or aquaponics but lacked experience with organic farming or growing outside a greenhouse.
The final 196-page task force report is available here: https://www.ams.usda.gov/sites/default/files/media/2016%20Hydroponic%20Task%20Force%20Report.PDF
The first 100+ pages were prepared by the subcommittee that supported the 2010 NOSB recommendations not to allow organic certification for hydroponic operations. We worked to provide details and justification for why organic hydroponics should not be allowed. The next part of the report is by the subcommittee made up in part by hydroponic farmers that are currently certified and want to continue to be certified. They provided information about the various types of systems in use, although detailed organic nutrient management information was not provided because it was “proprietary”. The third part of the report is by a subcommittee that considered alternative practices or labels.
Apparently when the NOP regulations were first released (2001), the USDA stated that additional definition of greenhouse practices would be put in place within the first year. While a greenhouse proposal was developed by the NOSB in 2001, no official action was taken by USDA to make rules. Due in part to the lack of regulation, the exception for growing transplants in soilless growing media gradually was extended by some certifiers to apply to growing finished / harvestable crops. The assumption appears to be that if it’s ok to fertilize peat-based transplant media with fish emulsion and other water soluble fertilizers on a regular basis, it is also ok to grow crops to maturity in peat-based growing media with routine use of water soluble fertilizers. And if that is organic, why not allow growing of crops in sand or gravel or troughs of water routinely fertilized with OMRI approved organic fertilizers? These methods were initially only allowed by a limited number of certifiers while other certifiers would not allow them for finished crops. Canada does allow container crop production to be certified organic, but has worked to specify container size. With limited exceptions, container crop production of harvestable food crops including organic hydroponics is not allowed in IFOAM accredited certifications. The NOSB again provided greenhouse recommendations in 2010 that recommended no use of hydroponics but still the USDA did not take action. The lack of clarity in the regulations led to the formation of the Organic Hydroponic Task Force.
To summarize, organic hydroponics is using USDA-NOP approved nutrient sources to routinely (weekly, daily or multiple times a day) apply water soluble nutrients. Unlike conventional hydroponics, microorganisms and biology in the growing medium or nutrient solution are encouraged and considered essential. I saw two certified organic greenhouse installations in California growing lettuce and basil with a nutrient film technique (NFT). We heard about hundreds of acres of outdoor or protected container grown raspberries and blueberries grown with routine liquid fertilization and certified organic. Based on information provided primarily by one committee member, a large percentage of the organic tomatoes in large US retail food stores are currently hydroponically grown in Mexico, Holland, or a limited number of US locations. We were told that there are many greenhouse organic hydroponic producers waiting for the ruling and ready to build many more acres of greenhouse space if the growing method continues to be allowed.
Those in favor of organic hydroponics propose that consumers would benefit from a greater supply of organic produce, organic farming could be done in urban environments where soil is not available, and crops could be produced with the use of much less water. My perspective is that if container based growing continues to be approved, all of these objectives can be met with compost-based growing media that include some soil and do not require routine fertilization.
While concerns can be raised about the lack of action from USDA NOP regarding developing a greenhouse organic practice, another concern can be raised about the certifiers who are allowing organic hydroponic. The intended ideal of providing consistency across states and farmers cannot be achieved if the regulations are left open to interpretation by the 90+ certifiers accredited by the USDA-NOP.
Over the 7-month information gathering and sharing process, I learned about the implications of a system where NOSB members are provided expenses for travel, lodging and meals for meetings but serve without monetary compensation for their time, which includes a 3-year period of service and 4 meetings a year. It is very difficult for me to see how something so important can be dependent on volunteer service. I also learned that some NOSB members are focused on just one area or responsibility such as crops, livestock, processing, certification or representing consumers. Apparently when it comes to new regulations we can’t count on NOSB members being knowledgeable about key topics or even having read the pertinent background material prior to discussion. Then there is the fact that the NOSB is only advisory to the USDA-NOP.
Over the past 15 years I have had the opportunity to meet some of the original members of the organic community who worked to help make the USDA-NOP a reality, starting with the preparation of the 1990 Organic Food Production Act (OFPA) which is the federal law that led to a national standard for organic certification. The actual USDA-NOP regulations (issued in 2001) were developed from the OFPA during a 10-year process. The people that participated in this process deserve our appreciation for the difficult job they did.
I am reminded of the importance of not making assumptions and being as accurate as possible when it comes to choosing what to say and what not to say, and which words to use. The fact that organic farming is a soil based production system was so widely accepted by the early crafters of the regulations, it appears that stating the foundational essential premise of using soil or defining soil was not considered a necessary part of the regulations. The end result is that some with no prior organic farming experience interpret the rule as requiring soil biology and organic matter but not requiring soil itself because the rule does not say so. A justification was given by this group was that consumers don’t associate “soil” with “organic”.
Another example of how not being specific can lead to unintended consequences is that the NOSB greenhouse recommendations in 2001 and 2010 state that artificial lighting is allowed. The intent according to one member of the NOSB at the time was to allow supplemental lighting in a greenhouse. Organic transplants are allowed to be grown on light shelves in homes, basements and garages with no sunlight, but such production was not intended for harvested crops. But because details were not stated, there are now certified organic crops coming from warehouses and shipping containers with only electrical lighting and no sunlight. Does that sound like organic farming?
It will be interesting to see what happens next. There are many issues to be resolved. I have heard speculation that if organic certification of hydroponic systems continues to be allowed, the future validity of organic certification as a whole may be irreparably damaged.
There will be opportunity for public comment at the fall NOSB meeting, and online once the NOSB develops their recommendation. I hope you will be involved and express your perspective about “What is Organic”.