• OFPA (The Organic Foods Production Act of 1990)
• USDA (United States Department of Agriculture)
• NOP (National Organics Program)
• NOS (National Organic Standards)
• NOSB (National Organic Standards Board)
• OMRI (Organic Material Review Institute)
• ACAs (Accredited Certifying Agents)

For the purposes of this report we’ll start with the “Organic Foods Production Act of 1990″ (OFPA). This act authorized the Secretary of Agriculture (USDA) to appoint a 15-member National Organic Standards Board (NOSB). The board’s main mission is to assist the Secretary in developing standards for substances to be used in organic production. The NOSB also advises the Secretary on other aspects of implementing the national organic program. One of these aspects was or is to maintain a list of materials that are accepted in certified organic production, called the national list.

The current board is comprised of four growers, two processors, one retailer, one scientist, three consumer/public interest advocates, three environmentalists, and one certifying agent who sit on various committees. Members come from all four U.S. regions and serve a term of five years.

The NOSB put forth standards and/or laws, in essence what can and can not be used in growing or processing Organic food. The National Organic Program (NOP) is a marketing program housed within the USDA Agricultural Marketing Service. This agency sets marketing standards for organic labeling. The NOP mission is to develop and implement national standards that govern the marketing of organic agricultural products. The actual laws or standards are known as the National Organic Standards. The NOS is a document of approximately 50 pages of law. A simple summery of these guidelines would be inadequate. As with any legal document, you’d almost need to be a lawyer or scientist to fully comprehend all that they entail. Suffice to say that they state what can and can not be used on or in anything that is certified organic.

Within the NOSB are several committees, one specifically called the Compliance, Accreditation, and Certification Committee. They over see the education, training and recommend the final accreditation for certification from the USDA. Then the USDA authorizes the certifying agents in some state’s agriculture departments as well as numerous other private companies to certify producers, growers and other agricultural entities. They are called certifying agents.(CA) EVERY certifying agent must adhere to the same national organic standards, laws and inspection requirements. Neither the NOSB, nor USDA is a certifying agent. They are the law making body of the NOP; they train, educate and authorize the certifying agents. Collectively the certifying agencies are known as ACAs (Accredited Certifying Agents). Unfortunately neither the OFPA nor the NOP regulations address food safety or nutrition.

ACAs - Accredited Certifying Agents

As of January 2008 there are 95 ACA’s. Fifty five are domestic, forty are foreign and only fourteen are state run certifiers; which means well over seventy-five percent are private certifiers. You may ask, ‘If all agents abide by the same rules, why then are there so many agencies? Please remember throughout this report that “Organics” is a multibillion dollar industry and continues to grow at 13 -20% a year”,* and that’s the most conservative estimates I found. Although some reports boast a 30% increase annually. (*theorganicreport.com)

State Agriculture Department Certifiers

There are a few states whose agricultural departments have been authorized as a certifying agent. As you might imagine these are largely the farming states such as California, Idaho, Iowa as well as our state.

Colorado Department of Agriculture
Division of Plant Industry
700 Kipling St., Ste. 4000
Lakewood, CO 80215-8000
Contact: Don Gallegos
303-239-4149
E-mail: Don.Gallegos@ag.state.co.us
Scope: crop, livestock, wild crop, handling
Accredited: 10/16/02

I spoke with Don (pronounced guy-a-gos) a couple weeks ago to get a few facts straight; particularly when it comes to soils and fertilizers. Fertilizers are registered with the state, and they can be tested but only as to the N P K statistics. Fertilizers are not registered as certified organic, nor synthetic. Soils, soil blends or compost are not directly governed by any state program. However Don stated, “Now if there was a big enough complaint, it would be directed to the state Ag department, and they may investigate. But they are under no mandates (under the NOS) to do so.” When ask who he thought did a better job of certifying, state or private he would not commit, but did mention that “…the private companies are in ‘the business’ to certify, where as the state offers the certification as a service of the Ag department. In other words, it’s no financial loss to the State if someone doesn’t pass the certification process (they still pay for inspections and paperwork). But, Don further stated, “there are private certifiers who do govern with as much integrity.”

Private Certifiers

With over eighty private certifiers out there it would have been overwhelming to check on all. A brief sampling of web sites from a few I thought familiar told me very little about how the companies actually do business. Out of the three I checked (One-Cert, Certified Organics and Oregon Tilth), I found Oregon Tilth’s site more helpful; with more emphasis on education and less emphasis on the “sale” of certification. Since it is against the law for the certifiers to offer assistance or give advice (other than to explain their process) that leaves plenty of room for the so-called consultant businesses like OMRI. The ONLY differences in private certifiers and state certifiers that I could find are prices and customer service. All promote the qualities of their services. All say that they monitor and inspect within strict guidelines of the NOS. However, companies such as Oregon Tilth that have been in operation since the early seventies, no doubt have considerably more experience, which in my onion has got to make a difference. However those differences aren’t always visible.

It was difficult to interpret or compare pricing information. While the actual certification varied from $300 -$1,500 for the smallest farms or operations, inspections fees varied drastically. Colorado State CA for instance, states that initial application and certification starts at $600 with inspections at a reasonable $32 per hour. (Some private firms charge more than $100 per hour.) But then it’s anyone’s guess as to how many hours it takes to perform the inspections. Personnel at the State AG department say the time it takes depends solely on the individual being certified. Accurate detailed records are paramount to this process. And then of course there is the annual renewal fee. (All certifiers have annual renewal terms.) So getting certified is not a one-time deal but must be renewed on an annual basis, including inspections. Annual renewal fees varied from half of the original certification fee, to fees based on the percentage of organic business the company does and/or acres farmed; i.e. the larger the company, the larger the fees.

As to the expense, one has to ask themselves of it’s worth it. Organic produce can sell for as much as two to four times the price of non-organic. I don’t know about you, but as a consumer, if I’m going pay that much more for something, I want to know it’s legit! I also want to know that I’m not just spending money on a “prestigious label” that in fact doesn’t give me any more assurances than the USDA’s certification. Being that this system is run by ‘the government,’ there are, no doubt, pros and cons inherent to this system. “It’s not perfect” said the Ag staff at the State level.

OMRI Organic Material Review Institute.

OMRI is probably one of the most misinterpreted organic companies I investigated. They do not ‘certify’ ingredients or processes, nor do they analyze any ingredients or materials in a laboratory. (”…approximately 1% of the ‘Brand Name Product List’ materials are tested. The subscribers voluntarily meet all our requests.) IF any kind of lab tests is required, the subscriber includes those lab results in their submission.

Here is where I think OMRI gets its clout. Headlines on the NOS dot gov site….

Technical Advisory Panel (TAP) Reviews Compiled by OMRI for the NOS

“The Organic Foods Production Act of 1990 (OFPA) requires that USDA establish a National List of synthetics allowed and non-synthetics prohibited in organic production (crops and livestock), as well as non-organic substances allowed in organic processing. OFPA requires the National Organic Standards Board (NOSB) to convene the TAP to evaluate materials that are petitioned for inclusion on the National List. The NOSB relies on information provided in the TAP reviews, as well as information supplied by the petitioners and other public input to make a decision, which is whether or not to recommend to the Secretary of Agriculture that a material be added to the National List. The Secretary then has the choice of whether or not to accept the NOSB’s recommendation. If the Secretary accepts the recommendation, the change will be published in a Federal Register notice for public comment before becoming effective.”

So, NOSB contracts OMRI for their Technical Advisory Panel (TAP) which reviews materials used in organic production. As well, OMRI’s services are designed to assist the organic industry in determining the compatibility of generic materials and brand name products for organic production under the USDA National Organic Standard. Within this regulatory framework, OMRI serves the industry in the role of an advisory and educational support agency. OMRI provides the NOSB with ‘independent’ technical reviews. OMRI is probably most known among consumers for their “Brand Name Product List”. *** Contrary to some beliefs, OMRI is NOT a certifying agent. They do not certify materials, and they say as much in their disclaimers:

1. “OMRI does not provide any guarantee or warranty, expressed or implied, for any of the products on the OMRI Products List.
2. Product review is conducted according to the policies in the current OMRI Policy Manual and based on the standards in the current OMRI standards Manual.
3. OMRI Listing is not equivalent to organic certification and is not a product endorsement. It cannot be construed as such.
4. Final decisions on the acceptability of a product for use in a certified organic system are the responsibility of the USDA accredited certification agent.
5. It is the operator’s responsibility to properly use the product, including following any restrictions.”

The one tool I did find that assists the general public the most: OMRI has now made available what they call the “Generic Material List”. This is more accessible and a little more readable than the “NOS” or the “National List”. The cost to get it in your hands is approximately $35.00. While I believe this information should be free, I guess everyone has to make a buck!

International Certifiers

I did not look in to international certifiers’ services or how those certificates vary from our national standards. But I couldn’t leave things here and not mention an international organization that (in my opinion) truly seems to be worth some time and space here. To me, they seem to put the “heart” back into the idea of organics.

IFOAM and IOAS

IFOAM - (International Federation of Organic Agriculture Movements).

IFOAM is the worldwide umbrella organization for the organic movement, uniting more than 750 member organizations in 108 countries. IFOAM’s mission is leading, uniting and assisting the organic movement in its full diversity. (Inception, 1972 France)
In order to fulfill its mission, five goals were set by the World Board for the medium term:

IFOAM GOALS

• Builds the global platform for the organic movement
• Develops, communicates and defends the principles of organic agriculture
• Advocates and facilitates the adoption of organic agriculture
• Promotes the development of organic markets
• Ensures an effectively managed organization with sufficient and sustainable resources

IFOAM’s long term goal is the worldwide adoption of ecologically, socially and economically sound systems that are based on the principles of Organic Agriculture of health, ecology, fairness and care.

• Health: Organic Agriculture should sustain and enhance the health of soil, plant, animal, human and planet as and indivisible.
• Ecology: Organic Agriculture should be based on living ecological systems and cycles, work with them, emulate them and help sustain them.
• Fairness: Organic Agriculture should build on relationships that ensure fairness with regard to the common environment and life opportunities
• Care: Organic Agriculture should be managed in a precautionary and responsible manner to protect the heath and well-being of current and future generations and the environment.

These goals and intentions sound almost too noble to be true. The idea that soil, plant, animal, human and planet are indivisible, (HELLO…and Thank you, some one gets it!) coupled with their goal to unite all organics under international guidelines is one that I can support whole heartedly. (If only I could afford to!) They included ethical and sustainable behaviors into their policies, whereas the NOP speaks strictly to the use or non-use of product. The only questions which remain are: Is it possible, or even practical to have congruent world-wide standards? Can one agency apply the same standards in Central Africa as in our mid-western farm belt? (Well, they say, when you dream, dream big!)

IOAS: International Organic Accreditation Service

In order to deal with the inadequacies of some and the differing national standards in international trade, IFOAM established the IOAS. This is NOT a certifying agency per se; however they have developed an international accreditation service for all organic production certifiers. Comparatively speaking the IOAS is in essence the global version NOSB.

“The IOAS is a non-profit organization which was established in 1997 by the International Federation of Organic Agriculture Movements (IFOAM),

The IOAS is an independent, non-profit organization that works on behalf of everybody involved in organic agriculture to ensure trust and fair trade in products labeled as organic”.

Having your products certified ‘globally’ or internationally is quite an undertaking. While there is no doubt in my mind that an accredited membership from this organization is quite a prestigious claim, it is extremely expensive. But given the wide spectrum of their goals and ideals, who’s to say that it’s overpriced?

The IAOS board members, and accreditation committee involves world-wide participation that assimilates the U N of the organic industry. They are people from all over the world who are committed to organics; not just the trade industry but from an ethical and environmental point of view.

It is quite possible that I am ‘dewy eyed’ with this company simply because they have some great writers on staff. Check out their site, you be the judge!

Believe me when I say there is so much information out there that no matter how much time I gave this topic when it comes to the facts I know I”ve only scratched the surface.

All sources are shown as links at the end of this report.

In Summary

All certified organic products (in the USA) must comply with the NOS, (National Organic Standard). All State as well as private certifying agencies must comply with these same rules and regulations. However…and that’s a big however, interpretations do vary, and while no company’s names were mentioned, a few of the folks that I talked to insinuated that there were in fact a few ‘bad eggs’ in the certification program. Well before the NOP was in place and well before 90% of the certifiers and organic retailers out there jumped on the band wagon, there were a handful of established organizations who believed in organic practices in both theory and their ecological concerns for our food and environment. They weren’t just in it for a buck. They believed. Knowing there are still a few out there makes the next few sentences difficult. While I do believe we need some parameters, some of these “independent certifiers” might as well be selling snake oil! Now, I’m sure snake oil is good for something, but I culled enough information from other certifiers, both state and private, to know that there’s a lot more politics being played here than any of these companies are willing to admit to.

Another area that concerned me (as a grower and someone who may at some time want that USDA stamp of approval) was the soils and fertilizer issue. After two months of fact finding on web sites and talking with several agencies, I still have no hard-and-fast rules to report when determining just what soils and fertilizers to use, or are accepted in organic growing. No doubt that’s why there are so many false claims about these materials.

The label “USDA Organic” (certified) products only refer to foods and fibers (and now I believe a class for cosmetics). They do not, for example, certify combinations of products such as bagged soils, soil amendments such as compost or many fertilizers that contain multiple nutrients. This is where the certification of such products gets, well at best, fuzzy and grey. There is no certification. From what I understand a product may be made from organic materials, however the processing or the products used in the processing stage may not be considered acceptable. At best we can look at the labeling of such products to determine that the ingredients are in fact ‘allowed’. This is where the generic material list may be most useful.

When doing some experiments last year, I bought three bags of “Organic” potting soil; one from Wal-Mart, one from Albertson’s, and another from Kings Soopers. Prices ranged for $2.99 to 3.99. (Pretty cheap, right?) Well, after opening and handling these soils, unfortunately I couldn’t recommend any of them. Two of them dried up hard as clay, the other just smelled foul. Lesson: you usually get what you pay for and I can’t imagine, even though they all had “Organic” in their title, that any of them could have qualified as something an organic grower could get by with.

The good news is well produced soils and amendments do have their ingredients labeled. More often than not, this is the only recourse the general consumer has; comparing ingredients on labels to those listed with in the criteria of the NOS (and hopefully the GML from OMRI). However, some processes of these ingredients vary; it’s not always identifiable but may preclude their certification because of such processing. The only party privileged to know the actual processing methods are the manufacturer and the ACA. (IF the product is being used in a certified program) Generally speaking, processes are not listed on the label with ingredients. Specific Latin as well as scientific names are often used on ingredient labels that the average back yard gardener may not be able to interpret. (In other words the regulations where ingredients are concerned are not easily understood by the average consumer.)

This is why I hope the Generic Materials List (from OMRI) is a step in the right direction when trying to keep the average consumer like you and me informed. This list catalogs over 900 substances that are allowed, restricted and or prohibited for use in certified organic plans. This ‘generic’ list may be a little more practical than 50 pages of NOP Standards when ascertaining a products’ organic qualification.

Generally if a producer has what they believe to be as “organic” they will state such in their labeling. One article I read from the “O Mama Report” suggested looking for any of the following statements on labels or packaging:

• “This fertilizer product is allowed for use in organic production;”
• “Meets National Organic Program requirements for organic production;”
• “Suitable for organic farming;”
• “Acceptable for use in organic production;”
• “Meets the requirements of the National Organic Program (NOP) for use in organic production;”
• “This product is listed by the Organic Materials Review Institute (OMRI) for use in organic production.” (theorganicreport.com)

But remember OMRI’s disclaimer? “OMRI Listing is not equivalent to organic certification and is not a product endorsement. It cannot be construed as such.”

All in all, being certified Organic is not easy, nor is it inexpensive. There are provisions for small growers, “Those whose annual sales of Organic products that are under $5,000, may use the term “Organic” but the product is not ‘certified’. I believe there are many small local framers and producers who in fact do produce truly organic products. They have good ethical standards; they care about the food they produce, and the earth we all share, as do I!

Those of us who love the dirt, love to be out in it regardless of weather, those of us who still hold a single seed in wonder and appreciation, in essence what I call the ‘green blooded’ gardeners; don’t care what the government thinks about what we do. In fact, most of the gardeners I talk to and relate to, go to the garden to get away from all this falderal! We like to play in the dirt as an escape from, if not finding a path to an alternate reality. Mother Nature, her earth, her seed and ultimate beauty have little or nothing to do with governmental industry standards.

It was not my intention to make cynics out of “organic believers”, nor is it my intention to dismiss the processes or the standardizing of organic produce. Some where, some how, these protocols and standards are a necessary step in the right direction. However I do believe that this information, these protocols and standards should be more transparent than they are, these “lists” should not only be readily available to consumers and small gardeners, they should be FREE!

Take the challenge, go into these sites, and navigate your way to a “list” of ingredients that are allowed or prohibited. Let me know what you find!

For now, I’ll stick to my logo phrase, “Grown With Conscience“™

I’ve done my absolute level best to get these facts straight. If anyone finds errors, misinterpretations of ‘the rules’ or in any way can offer some constructive criticisms PLEASE DO SO, either through email, or leaving a comment on this blog. That’s why I created it; a blog to discuss the pros and even the cons of organic gardening, the systems and the ‘Organic’ industry in general.

Tina M. Kellogg GivenTrees LLC “grown with conscience” ™

• http://www.ams.usda.gov/nosb/
• http://afsic.nal.usda.gov/ (Alternative Farming Systems Info Center)
• http://www.ota.com/ (Organic Trade Association)
• http://www.theorganicreport.com/
• http://www.theorganicpages.com/
• http://www.ifoam.org/index.html
• http://www.omri.org/

October 22, 2007

Yup, it’s official, the garden season’s done; thirteen degrees last night, but only a few inches of snow. Good thing I got most all that needed it mulched that past few weeks. Now to the pumpkins! There are a couple dozen waiting in the garage for my attention. I’ve collected some pretty interesting recipes; from Pumpkin Curry Soup to Venison Pumpkin Stew! Yummmmm, can’t wait to try these.