by Keith R. Baldwin and Eric Soderholm
When it comes to inputs for transitioning or certified organic farms, there are plenty of mistakes that can easily be made that would start that three-year “transition” clock back to zero. A short review of some of these simple mistakes will hopefully keep you out of trouble.
You really can’t go wrong if you don’t use any inputs whatsoever, but for most producers that’s not realistic. So, the first thing to look for is a “seal of approval” from an institution that reviews products and has the authority to make a call as to what is “Allowed” and what is “Prohibited.” Though this sounds black and white, know that may allowed products come with restrictions or annotations specifying when their use is acceptable.
The Organic Materials Review Institute (OMRI) supports organic integrity by providing organic certifiers, growers, manufacturers, and suppliers an independent review of products intended for use in certified organic production, handling, and processing.
When companies apply, OMRI reviews their products against the organic standards. Acceptable products are OMRI Listed® and appear on the OMRI Products List©. Be careful though, the OMRI label doesn’t necessarily mean go for it. Use of any material has to be considered in the context of your specific operation and the specific use of the product.
The Washington State Department of Agriculture (WSDA) Organic Program maintains a list of products that have been determined to meet the requirements under the National Organic Standards. WSDA’s list is not a comprehensive list of all materials that are allowed for use in organic agriculture, but WSDA certified organic operators can use products that appear on this list and maintain confidence that the use of these products will not jeopardize certification.
Many products are “allowed” even if they have not been “vetted” by either of these organizations. There are many reasons for this: commonly, manufacturers do not want to pay the costs associated with a review. So, before using any product, check with your certifier to make sure that the input is “allowed” by that certifier. The Organic System Plan (OSP) for your farm requires the identification of all inputs. You are required to notify your certifier before any “new” inputs not included in your OSP are used on the farm. Remember that a manufacturer can put anything on the label, including “organic”, “natural”, etc. It’s a “buyer-beware” world.
Ready to Rock?
A common mistake that many producers make relates to the use of soil amendments derived from mineral rock. For example, potassium sulfate or potash fertilizer (0-0-50) can be either allowed or prohibited, depending on the manufacturing process. The “Great Lakes” brand is allowed, while some other brands are prohibited because they contain a dust suppressant. The same is true for sul-po-mag (0-0-22), which is sold by Planet Natural as “K-Mag NATURAL.” It is highly likely that this material is prohibited because we have not been able to source an 0-0-22 that does not contain a dust suppressant.
Top 10 Input Issues
Fertilizer materials derived from fish or fish byproducts can also be problematic. Some contain emulsifiers that are prohibited; others may have preservatives added to prolong shelf life. Here’s an input “case” where that OMRI or other seal of approval can save you time, money and grief.
It’s somewhat ironic that animal manures, in particular poultry litter, are allowed for use in organic production even though they can contain byproducts of industrial agriculture such as antibiotics and arsenic. And in the same vein, cottonseed and soybean meal can be used on organic farms as soil amendments even though they may be derived from GMO cotton and soybeans that have had conventional pesticide applications (disclaimer: check with your individual certifier).
OMRI has developed a “GMO decision tree” that generally supports use of these products, though there is disagreement from some quarters, as you might imagine. The “logic” supporting use of these products assumes that as a soil amendment any “GMO” in cotton seed or soybeans is unlikely to be assimilated by crops. At the same time, that logic also stipulates that GMO-derived products must not have an “impact” on soil microorganisms (not sure who might be checking on that).
Here’s a list of some other things to watch for with respect to inputs:
- “Allowed Synthetic” micronutrients (assumed to be synthetic because of the process used to produce the final product) can only be used when there is a “documented” soil deficiency as shown by soil or tissue testing.
- Most organic pesticides can only be used when “documented” use of other (e.g. cultural, biological) control methods have proven insufficient.
- Watch out for prohibited wetting agents in potting soil mixes.
- Certified organic seed is required for cover crops. Untreated conventional seed can be used if organic seed (species or cultivar) is commercially unavailable.
- Some inoculants for legume species contain synthetic ingredients or GMORhizobium bacteria that are prohibited.
- Seed treated or coated with any synthetic substance is prohibited. This includes seed that is pelleted for uniformity and easier seeding. Some seed companies, like Johnny’s, do a good job of denoting which seeds have an NOP-compliant pelletizing agent.
- Compost containing glossy, colored paper, compostable plastic and/or biosolids (sewage sludge) is prohibited. Always ask the compost manufacturer for the compost specs and run them by your certifier before purchase and use.
- Liquid fertilizers that contain 3% or more nitrogen must be approved by an accredited material review organization (OMRI or WSDA) for compliance. The NOP decided that individual organic certifiers are not allowed to review and approve these materials after a case of fraud in 2009.
What’s at Stake?
On the livestock side of a diversified farm, one question that frequently puzzles producers is the use of “treated” fence posts. In my experience, the interpretation of the NOP rule regarding this “issue” varies considerably by certifier. But it’s something to keep pestering them about. A prominent certifier in North Carolina allows that after three years in the ground, a treated fence post “transitions” into an allowed status. Until that time, animals must be “buffered” from any forage within the lateral extent of the root zone of that forage, which may be four or five feet. An alternative is to “wrap the portion of the fence post that will be buried in the soil with an impermeable covering. Livestock must not be allowed to come into contact with the post, and a hot wire may do the job there. In South Carolina, a prominent certifier’s position is that if the post is in the ground at the time of the initial inspection for certification, it is considered to be “allowed.” Needless to say, choosing a certifier and knowing their position is an important part of doing business for a livestock producer.
Mulches: We’ve (Almost) Got It Covered
A last word on the use of mulches: Both black plastic mulch and (some/check) landscape fabric are allowed for use in organic vegetable production systems, but both must be taken up at the end of the growing season. A new opportunity is on the horizon as the NOP just approved the use of bio-based, biodegradable mulches. However, based on OMRI’s research and understanding of these products, most and possibly all, of the currently marketed bio-based mulch films contain some petrochemical feedstocks, and the feedstocks used are typically less than 50% bio-based. It is unlikely that OMRI will be able to add any biodegradable, bio-based mulch films to the OMRI Products List© this year.
Head spinning? Check out CFSA’s Organic Production and Certification Consulting Services for help getting your farm organic certified.