For the past decade, organic agriculture has heavily influenced by Federal Regulation. There is a colorful history surrounding the whys and wherefores of that. We won’t go there! It’s interesting but it doesn’t necessarily help you.What it will help you to understand is that the Legislation and the Regulation of Organic is first and foremost about consumer protection. Whether you agree with Federal involvement or not, I’m sure all of you can relate to the idea that consumers, who are willing to pay more for a product, should expect to get what they are paying for—or some reasonable level of that. It’s only fair.
So let’s start by talking about what it means to be organic, and what we might call different types of organic growers, from a Regulatory perspective.Anyone can farm organically… Organic methods are the foundation for sustainable cropping systems. So you can be sustainable…organic in spirit…and the Regulations needn’t affect you a bit.Where Regulation comes into effect is when you make marketing claim that what you are selling is organic. That is when this whole set of Regulations affect you. And they affect you whether you are or become a certified organic grower, or whether you are small enough to be exempt from certification—the same Regulations apply to you.
We’re going to focus, of course, on those folks wanting to market as organic. So the first quest is, “Do you need to be certified?”Basically any producer or processor that markets over $5000 of organic product annually needs to be certified. If you market less than $5000, you are exempt from certification, but are expected to follow the National Standard.
And that can create some problems, since certified growers are policed, as it were, and exempt growers are not. I wrote this little publication a few years ago to help alleviate some of the problems. The idea behind this was actually inspired back in 2005 when I did an In-Service training on certification for University of Arkansas Extension Agents. I was ready to talk about certification and all they wanted to talk about were the exempt growers at farmers markets. Were they or were they not organic???? This booklet, then, is a very stripped down guide to the Regulation and what it means to be organic, for small growers, whether they certify or not.I’m using it as a basic guide for this discussion and you have a copy of this on your flash drives.
If you are growing organic crops, large or small, your basic concerns are all the same. But we’ll look at ‘em one-by-one.
“How do you define Organic Farming?”The first thing that characterizes an organic farm is the practices; it is about what one DOES.
There is this host of practices that work to that end…building the soil.
And there are other cultural practices that support these. Techniques we’ll be discussing in the coming weeks.Remember, first and foremost Organic production is about what you DO!!!
Remember that definition of organic that we said was suitable for consumers. Well, the Regulation, as we said, is about consumer protection, so ensuring that nothing prohibited is used is a big part of what being organic today is about, like it or not.
Whether you want to think a lot about what’s allowed and what’s not, it is compelling because a mistake will cost you. You have probably heard that there is a 3-year transition period for a farm to be organic. That transition period is tied entirely to the last use of prohibited materials. If you intentionally or accidentally apply something you shouldn’t, your certifier will deny certification on that ground for the next three years. So you gotta take it seriously. The flip side of this, however, if you want to convert an old pasture, a field, or a garden that has not had conventional chemicals applied for a long time, you can probably become certified the year that you apply.
In your guide, PAGES 6 & 7 deal with Fertilizers and Soil Amendments, which are still an important element of organic growing. We start by listing the most common prohibited fertilizers. We also list a number of products and materials that many incorrectly believe to be organically acceptable. (Bagged sewage sludge is the first thing to spring to mind.) There are a lot of fertilizer sales people who’ve done a good job of convincing farmers their products comply with the law when they don’t. We show how to read a fertilizer label and how to recognize allowed products.
ON PAGES 9 & 10, we talk about pest control products. As with fertilizers, we start by talking about the common prohibited pesticides. We give both chemical and trade names. There are also a number of natural pesticides that have been ruled too toxic for organic use. These are discussed as well. There are instructions on how to read and interpret a pesticide label, and recognize allowed products.
Here are close-ups of some of the logos you can look for
Organic agriculture these days is also about food safety, particularly as regards the use of manure.
This is a portion of the Regulations that is highly prescriptive. At one of the Standards Board meetings I attended a few years back, the head of the program said she was not going to allow a food safety crisis to occur in organic agriculture on her watch. Basically, the Regulations state that manure must be composted if you are going to make free use of it on food crops. The requirements for safe composting are also very well-defined—they were essentially lifted from NRCS guidelines for controlling pathogens in sewage sludge. That does not mean that raw manure can never be applied. It simply means that 90- or 120-days must pass between the application and when the crop is harvested. The difference in time is dictated by whether the edible portion of the crop contacts the soil or soil splash, or not. Such crops would require a 120-day delay. These rules do not apply to non-food crops. And it doesn’t apply to compost that does not contain any manure.And by the way, manure from conventional confinement operations can be used in organic growing, unless the certifier feels that there is too much contamination with prohibited materials—arsenic use in poultry litter was often a concern in our region, but a lot of organic growers have used that resource for years. And supposedly, that’s no longer an issue??Biosolids are prohibited no matter how its managed.
What about seeds?
Identifying organic seed is a lot easier than other inputs. The critical information is the statement of who the certifier is. Most packets will also have the NOP organic seal.
Integrity is now an important part of being organic. You not only need to grow organically, but assure the consumer that what they’re buying has not been contaminated along the way, or commingled with something you or someone else has grown conventionally.
There is a lot of Regulation regarding marketing which addresses things like labeling, the color and use of the USDA seal and the like. But when you cut through all that, it comes down to three primary things, particularly where market farmers are concerned. Read slide.
To this point I’ve been talking about what it means to be organic, whether you’re talking about a certified or exempt operation. From this point on I’m going to focus on certification.
First is the Organic System Plan (OSP). Since exempt growers are not going through the application process with a certifier, they rarely have any written document that tells anyone what they do and don’t do. Though, technically, they are supposed to have one. Frankly, though, they need not be near as extensive as those required for certified production. Small Scale Organics features both a blank OSP document and update forms, beginning on PAGE 21. It is stripped of extraneous details information requirements. Check boxes are used as much as possible. It has also been structured as a declaration that the farmer can sign.This is a document then, that the grower can take to the Farmer’s Market, or take to Food Coop where he or she wants to sell produce, as an indicator or affirmation that they are an organic operation. Can someone still lie and get away with it? Sure? But most of us are reluctant to sign our names to a false statement.It is my recommendation to the managers of Farmers Markets that they actually require such a document from non-certified growers. I believe it would greatly reduce the amount of misrepresentation and suspicion.
Similarly, exempt growers are also, technically, supposed to keep records. These are minimal, again and we included some simple forms or that purpose. These begin on PAGE 31. There are really only a few things that exempt growers really need to track…mainly it is their inputs—seeds, fertilizers, and pest control products.
Thanks for your time.
Are We Organic Yet?
A Quick Overview of What It Means and What It Takes to be Organic Presented by George Kuepper Kerr Center for Sustainable Agriculture
Marketing Organic Certified Not Certified (i.e. Exempt) Organic in Spirit Sustainable Farming & Gardening
Main Exemption: Any producer or Operations that handler who markets market <$5000 of more than $5000 of organic products organic product annually annually
There are Two Fundamental Strategies for Crop Nutrition:•Feeding the Plant, Directly, with SolubleNutrients—the Conventional Approach•Feeding the Soil FoodWeb, and Allowing it To FeedThe Plant—the OrganicApproach
Diverse crop rotations including sod crops, cover crops, green manures, and inoculated legumes Crop residue management Application of livestock manures & composts Liming and use of other natural rock minerals Mulching with organic materials
Timed planting Pest barriers and traps Tillage and cultivation Release of beneficial insect Sanitation protocols Allowed pest control agents
•Livestock Manure Must either be composted*, appli ed according to the 90- and 120- day rules, or used on non-food crops. •Biosolids (Sewage Sludge) is a prohibited substance.•Regulations regarding composting are specific for C/N ratios, temperatures, turning, etc.
Organic seed and planting stock must be used If not commercially available, untreated seed or planting stock may be used; no GMOs Conventional seed treatments are prohibited, unless required by Federal or State regulations Organic transplants must be used
Directions for GrowingUSDAOrganic Seal Certified by Sooner State Organics Sell by 12/31/2011 Lot # OMG 16-09 Packed for 2011 Name OfCertifier
The 3-Source Custom AOSCA Organic Seed Finder http://www.organicseedfinder.org/
Do not sell anything as organic if it’s not… Do not say it’s certified if it’s not… You may display the USDA Organic Seal only if you’re certified.
National Organic Program 1400 Independence Ave., SWRoom 2646-South, STOP 0268 Washington, DC 20250 Tel: (202) 720-3252 Fax: (202) 205-7808 www.ams.usda.gov/nop/ What Is Organic Certification?/How Do I Get Certified Organic? http://www.ams.usda.gov/AMSv1.0/getfil e?dDocName=STELDEV3004346
Available on the ATTRA Web site* www.attra.ncat.org •Organic Farm Certification and the NOP •The Organic Certification Process •Organic Materials Compliance •Documentation Forms Inspection •Preparing for an Organic * Note that many ATTRA publications are no longer free-of-charge. There is a small charge for some PDF downloads and for print publications.
Available on the ATTRA Web site* www.attra.ncat.orgGuide for Organic CropProducershttps://attra.ncat.org/attra-pub/summaries/summary.php?pub=67* Note that many ATTRA publications are no longerfree-of-charge. There is a small charge for some PDFdownloads and for print publications.
The Organic Certification Process (MOSES)http://www.mosesorganic.org/attachments/productioninfo/fscertification.pdfHow to Choose An Organic Certification Agency(MOSES)http://www.mosesorganic.org/attachments/productioninfo/fsagency.pdf MOSES PO Box 339 Spring Valley, WI 54767 715-778-5775 firstname.lastname@example.org www.mosesorganic.org
Small Scale Organics is a guide forexempt organic farms (<$5000 annualsales) and those in the marketplacethat interact with these smallgrowers, such as farmers marketmanagers and produce buyers.This 34-page guide includes detailsfor assessing compliance with theNational OrganicStandard, templates for abbreviatedOrganic System Plans (OSPs), andsimplified record forms.Copies can be downloaded free-of-charge at:http://www.kerrcenter.com/publications/small-scale-organics.pdfPrint copies can be requested from: The Kerr Center for Sustainable Agriculture P.O. Box 588 Poteau, OK 74953 Tel: 918-647-9123
Thanks for your attention! George Kuepper The Kerr Center P.O. Box 588 Poteau, OK 74953 918-647-9123 email@example.com://www.kerrcenter.com/
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