Certified Organic v.2.0

[Food Safety Guy]

Quick Preamble:

1. I really wanted to add my info to the last forum but was so demoralized by the interpersonal conflict.  So, I want this forum post to be all about facts, ideas, love and peace.  
2. I know my name is "Food Safety Guy" but can we leave safety out of this discussion.  Organic and Food Safety are both certifications and tend to get lumped together.  Go with me on this, they are two completely different topics and should be discussed separately.  It would like combining fish disease with lettuce disease, both are diseases but have completely different solutions. :) 

On to loving, peaceful post about organic aquaponics . . . 

It is not impossible to get an Organic Aquaponic Program, but REALLY difficult.

Why . . . Because the NOP wants soil?

How do I know they want soil?  Because they state it clearly here: http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5084677&am...

Observing the framework of organic farming based on its foundation of sound management of soil biology and ecology, it becomes clear that systems of crop production that eliminate soil from the system, such as hydroponics or aeroponics, can not be considered as examples of acceptable organic farming practices. Hydroponics, the production of plants in nutrient rich solutions or moist inert material, or aeroponics, a variation in which plant roots are suspended in air and continually misted with nutrient solution, have their place in production agriculture, but certainly cannot be classified as certified organic growing methods due to their exclusion of the soil-plant ecology intrinsic to organic farming systems and USDA/NOP regulations governing them.

Basically, a aquaponic grower needs to show how they are treating their media like organic soil:

§ 205.209 Terrestrial Plants in Containers and Enclosures (Greenhouses) 

(a) Container and enclosure (Greenhouse) operations must meet all applicable
requirements of subparts B (205.105) and C (205.200 – 205.206) except that:
(1) The producer operating a greenhouse with crops grown in containers using a growing media that does not include soil from the production site is exempt from requirements of 205.202(b), 205.203(a).
(2) In addition, the growing container based producer is exempt from the crop rotation and cover cropping requirements in section 205.203(b) and 205.205. In lieu of crop rotation and cover cropping, soil regeneration and recycling practices shall be implemented and documented for the certification agent in order to demonstrate that the required functions/goals of crop rotation and cover cropping listed in 205.205(a, b, c, d) have been achieved through these alternate practices, as applicable to the operation. Specifically:
(i) Maintain or improve soil organic matter content (a)- Examples include, but are not limited to, recycling and re-use of growing media, addition of compost and other compostable materials, earthworm replenishment, microbial re-inoculation, etc.
(ii) Provide for pest management in crops (b)- Such as soil borne damping-off control through various low temperature heating methods. Soil inoculation using disease suppressant bacteria and fungi.
(iii) Manage deficient or excess plant nutrients (c)- Recycle excess plant nutrients contained in drain water from media containers, avoiding so called drain-to-waste systems. Recycled nutrients must be re-used in the greenhouse, or alternatively, on a growing crop outside the facility.
(iv) Provide erosion control (d)- Though erosion is not generally applicable to greenhouse production, recycling of drain water prevents off-site movement of nutrients, a common consequence of typical field erosion.
(b) Growing media ingredients shall be verified by certifying agent and shall not include as ingredients any prohibited materials. Growing media shall be comprised of ingredients that allow for recycling and re-use as growing media within the operation, or alternatively, as a crop input outside the greenhouse. Growing media shall not be disposed of as waste, but  should be recycled or reused whenever possible. Growing media shall contain sufficient organic matter capable of supporting natural and diverse soil ecology. For this reason, hydroponic and aeroponic systems are prohibited. Growing media used to produce crop transplants should also be capable of supporting a natural and diverse soil ecology.

Now for some insight on the inside of a certifiers mind . . . . . . AHHHH, I know frightening thought.

I used to work for an Organic Certifier, and the company I am currently with partners with one.  Certifiers in general are a very conservative black and white bunch.  Auditors, tend to lean on the side of caution and stay away from any type of any potential risk.  Most would define Aquaponics as a niche risk.  

Many certifiers would get a call from a aquaponic company and think, "What The ____!  You do what, with WHAT!  WOW, this is interesting, I wonder what the NOP thinks about Aquaponics . . . "  Then they would read the above statement and conclude: this is a lot of work, for something that most likely will not get certified.  The next thought would be, is this risk worth the potential loss: I already have a hard enough time getting paid by farmers that do get certified. 

I give the information above not to discourage you, but to enlighten and encourage you.  Everyone has the power of persuasion at their fingertips.  Prove and persuade, baby, prove and persuade.

Loving & Peaceful thoughts, opinions, ideas are encouraged. 

[Damon Polta]

thanks for this... it further proves my point about the frivolous ponics...

yes, AP shares some practices that regular agriculture uses, it also utilizes practices that for the most part aren't involved with standard dirt farming... if organic certifiers have an issue making money certifying dirt farms, then maybe they need to broaden their scope of the term organic to allow a wider revenue stream... or at least create a sub-genre for aquaponics in the organic certifiability...kind of like being certified with stipulations... the same rules and regulations apply for AP and dirt farmers, the only difference is the soil... maybe they could then coin the term "soillessly organically certified," or something to that nature to accommodate the realms of growers that do not use pesticides and inorganic fertilizers but are lacking a credible stamp saying that they're doing so.

but then again things might be different if someone would show up with an aquaponics variation to the rules... following all of the guidelines of organically certified, but also showing how aquaponics closes up some of the grey zones when it comes to organically certified pesticides due to the fact that most cannot be used in an ap system, which would ensure the customer at the end of the day that absolutely no pesticides were used on their food, as well an no hidden soil additives that are hidden in farmhouse closets as well as a whole world of other hidden things that are being brought to light from people being dishonest after they get certified organic. aquaponics could stand to be the solution to the organic falsifiers...

[Earl ward]

My 2 cents I believe HACCP should be the dominate force here not organic or food safety certification.With HACCP you have to take in all considerations  for  the veggies, fish, and the facilty sanitation.

[Food Safety Guy]

Earl I agree with you, but that is a different post.  Good peoples on this forum are interested in Organics, and there is a large market for organics.  We can start a HACCP post . . . 

This post is for how challenges and successes of Aquaponic Organic Certification.

[Earl ward]

If you build a HACCP system with organic certification in mind you can kill 2 birds with one stone. HACCP deals with system thinking and critical control points now if you create a HACCP system with meeting the organic certification in mind you are off.  Look at your system with the organic requirements in mind but do it as a systems approach.

[Food Safety Guy]

Oh, I see where you are going . . .

Yes HACCP, or a simpler version "risk assessment", should be done regardless - organic or conventional.

If you want to use the NOP "Organic" label you need an organic certification.

[TCLynx]

I know I've posted something like this before.  But in media based aquaponics, how different is an aquaponic media bed from gardening in gravely soil or even sandy soil?  I mean we joke in FL that gardening here is like run to waste hydroponics, all the "soil" does is hold the plant up, we have to provide all else.

Anyway, aquaponic media beds are diverse in the same soil microbes that convert ammonia into plant usable nutrients, Aquaponic media is definitely not "inert" and aquaponic media beds use worms.  The above description of greenhouse and container growing requires that media be re-used and re-cycled as much as possible and never thrown away as waste.  Plant roots decomposing in media beds provide organic matter replenishment and we actively encourage healthy bacteria in our media beds because that is what makes the whole system work (wow much like healthy soil) and we also actively re-circulate rather than letting excess nutrient run to waste or cause erosion or pollution.

I can't really see how media bed aquaponics is really much different than organic container growing.

But since I'm not actively seeking to pay for certification for myself, I'm not sure that my argument is going to help much.  but if anyone wants me to go over it again for them, let me know.

[Earl ward]

 

You may find this interesting this is a data base with all the certified operations in the US

http://apps.ams.usda.gov/nop

When I searched aquaponics I only got 2 results unless aquaponics is in the company name It will not show up

[RupertofOZ]

Your certification legislation would appear to be similar to that here in Australia.. i.e it is restricted to "soil"...

 

And TCL raises a valid point as to the definition of what constitutes "soil"...

 

I agree with Earl.... HACCP should be the underpinning of any operation.... and as such comliance with Food Safety Certification...

 

Yes, they may be some benefit in "organic" certification... but I'm dubious as to whether or not organic certification carries the premium that it might once have....

 

I for one, for instance... would be as a consumer... much more dismayed to learnt of someone losing their Food Safety Certification.... than I would be to learn that they may have lost an "organic" certification...

[Food Safety Guy]

Congrats Peter and good luck on your inspection.  I'm not saying it's impossible to get certified organic, there are just extra expectations when you use media.  

Once again, Earl and RubertofOZ, I agree with you.  I also believe food safety is the MOST IMPORTANT and Organics is for marketing - that is why I go by "Food Safety Guy" and not "Organic Guy".

TLCLynx - You are too funny, and absolutely true. I was just having a conversation with one of my clients in FL about the same thing.  I live in CA wine country, the soil in certain areas is just sand and sand stone.  The vineyards love it because they can manipulate nutrient intake 100%. 

The Natural Resource Conservation Service (NRCS) within the USDA provides two definitions for soil: http://soils.usda.gov/education/facts/soil.html

Soil - (i) The unconsolidated mineral or organic material on the immediate surface of the Earth that serves as a natural medium for the growth of land plants. (ii) The unconsolidated mineral or organic matter on the surface of the Earth that has been subjected to and shows effects of genetic and environmental factors of: climate (including water and temperature effects), and macro- and microorganisms, conditioned by relief, acting on parent material over a period of time. A product-soil differs from the material from which it is derived in many physical, chemical, biological, and morphological properties and characteristics.

This definition is from Soil Taxonomy, second edition.

soil - Soil is a natural body comprised of solids (minerals and organic matter), liquid, and gases that occurs on the land surface, occupies space, and is characterized by one or both of the following: horizons, or layers, that are distinguishable from the initial material as a result of additions, losses, transfers, and transformations of energy and matter or the ability to support rooted plants in a natural environment.

The upper limit of soil is the boundary between soil and air, shallow water, live plants, or plant materials that have not begun to decompose. Areas are not considered to have soil if the surface is permanently covered by water too deep (typically more than 2.5 meters) for the growth of rooted plants.

The lower boundary that separates soil from the nonsoil underneath is most difficult to define. Soil consists of horizons near the Earth's surface that, in contrast to the underlying parent material, have been altered by the interactions of climate, relief, and living organisms over time. Commonly, soil grades at its lower boundary to hard rock or to earthy materials virtually devoid of animals, roots, or other marks of biological activity. For purposes of classification, the lower boundary of soil is arbitrarily set at 200 cm.

[TCLynx]

Soil or not soil, pretty "Arbitrary" isn't it.

[Food Safety Guy]

WOW I'm impressed TC - you are serious about this forum . . . I do not even think the ink dried on the post I sent before you responded.  

I Agree with your assessment - that is probably why there is still an ongoing debate about "media" and "soil".  Many in the Ag industry would combine the 2 and call media, "soil".    

[Food Safety Guy]

Oh, I forgot to add . . . it does not matter what our opinions are though.  We have to convince the members of the NOP committee.  I think they are moving more toward media is soil paradigm.  If you read the previous memos they flat out say hydroponic systems cannot be organic, but in 2010 they are redefining their decisions to allow it if you treat media like soil.