MOSA provides our clients with much more than just certification.

Joe Pedretti

MOSA Client Services Director

Organic Boundaries and Life’s Work: right choices for the long view

Organic Boundaries and Life’s Work: right choices for the long view

By Stephen Walker, Operations Manager

Organic Cultivator readers always have opportunity to weigh in on organic concerns, from standards improvement, to defining absolute values, to talking about how we should behave as an organic community. Your opportunity to make a difference is as close as your pen, phone or computer, and it also exists in every action, as we’re known by our fruits. In this industry news update, I’ll discuss opportunities for giving feedback, upcoming regulatory work, recognition of right choices, and good work coming to fruition.

NOSB in Saint Paul, MN

As this was going to print, a primary organic feedback forum was coming closer to home, for many of us. The next National Organic Standards Board (NOSB) meeting is October 24-26 at the Intercontinental Hotel in Saint Paul, Minnesota. Showing up can provide perspective of democracy at its best. Since this meeting is nearby, a bunch of MOSA staff will be on site and weighing in on the discussions at hand. Below is an overview of expected highlights. Full meeting details, including proposals and discussion documents, are available at the USDA NOSB Meetings website.

The NOSB Certification, Accreditation, and Compliance (CAC) Subcommittee worked on a number of proposals to stop products fraudulent organic claims and to fix gaps in the complex organic supply chain, especially as related to imports. Compromised supply chains erode consumer trust in organic integrity. Strong action is needed on many fronts. There are two related proposals this time. Developing Criteria for Risk Based Accreditation Oversight seeks suggestions for how USDA should assess risk when overseeing accredited certification agents, like MOSA. The CAC compiled a list of risk factors, and wants to hear about other potential areas that might raise concerns. Another proposal, Training and Oversight of Inspector and Certification Review Personnel, recommends a number of approaches to improve the quality and skills of inspectors and certification reviewers. Focus areas include accounting, technical and interpersonal skills, organic system plan management, and inspector training & oversight. We provided comments on these proposals. Our written comments are available on our website.

We also commented on the Crops Subcommittee proposal on Strengthening the Organic Seed Guidance. This continues discussion about keeping seeds used in organic production from inadvertent GMO contamination. This recommends a regulatory change and revisions to the National Organic Program’s existing guidance for seeds, seedlings and planting stock (NOP 5029). Proposed changes include: 1) amending the regulations (section 205.204) to require grower’s annual improvement in organic seed and planting stock sourcing until full use of organic seed is achieved; 2) clarifying that growers using non-organic seed may ask their seed supplier for non-GMO/purity assurance; 3) strengthening certifiers’ review of growers’ contamination prevention measures; 4) specifying that on-farm variety trials may be used to evaluate seed equivalency, and specific seed catalog descriptions may also justify a lack of equivalent organic varieties; 5) increasing the number and quality of organic sources that must be contacted before resorting to non-organic seed; 6) specifying that certifiers may require a corrective action plan and additional efforts if sufficient progress toward organic seed use is not demonstrated; and, 7) enabling non-organic seed use when there isn’t equivalent organic seed with the desired non-GMO/purity level.

Several other proposals also seek improvements toward insuring that organic reliably means non-GMO. The Materials/GMO Subcommittee has a proposal on Genetic Integrity Transparency of Seed Grown on Organic Land. Over six years, public commenters, including MOSA, have supported exploring the feasibility of a seed purity standard, to reduce the inadvertent introduction of GMOs into organic crops. However, setting standards without proper infrastructure could penalize farmers for genetic trespass that is the others’ fault. It could also narrow the availability of needed crops traits. We need public data on seed contamination, to inform a fair seed purity standard. The 17-point proposal would require: sampling, testing and transparency of GMO contamination findings on all field corn seed planted on organic land; NOP instruction to certifiers; tracking in organic system plans; defined threshold levels for seed purity; seed tag declarations; testing protocol, technology & labs specifications; certifiers tracking within a central database; and, seed lot sample retention by organic farmers. We’ll comment again. Another Excluded Method Determinations proposal makes organic-acceptability determination on two new technologies. Transposons are to be added to the list of excluded methods, not allowed. But, embryo rescue in plants was found to NOT be an excluded method, consistent with IFOAM’s position paper on techniques compatible with organic systems.

It’s also an NOSB meeting heavy on discussion of materials for use in organic systems. Over 40 currently allowed generic inputs are undergoing sunset review. The responsible subcommittees unanimously voted to renew all of the material allowances EXCEPT for sodium carbonate peroxyhydrate, aqueous potassium silicate, microcrystalline cheesewax, and sucrose octanoate esters. If you are using any of these or are aware of commercially available organic or natural alternatives, your feedback is important.

Another discussion on Marine Materials in Organic Crop Production looks at reducing the environmental impact of harvesting seaweed for use in organic crop production by requiring that such aquatic plants be certified organic, using the current wild crop standard (section 205.207).

Meanwhile, many new material petitions are under review. These include Oxalic Acid Dihydrate (a treatment to control varroa mite in organic beehives), Sodium Chlorite (for generating chlorine dioxide gas used as an antimicrobial, sanitizer, or disinfectant for fruits and vegetables), Silver Dihydrogen Citrate (an antimicrobial processing aid for poultry carcasses and fruits and vegetables, and used as a disinfectant/sanitizer for food contact surfaces and food processing equipment), Japones Chile Peppers and Ethiopian Pepper (as ingredients in a hot sauce product. These received split Handling Subcommittee votes), Tamarind Seed Gum (a thickener, stabilizer, or gelling agent, which exhibits properties maybe differing from other currently used materials), Pullulan (used in tablets and capsules for dietary supplements), Collagen Gel (for sausage casings), Allyl Isothiocyanate (a pre-plant fumigant for the control of certain soil-borne diseases and pathogenic nematodes. The Crops Subcommittee recommended against approval.), Sodium Citrate (an anticoagulant for drying blood meal subsequently used as a crop fertility input), Natamycin (to classify as a non-synthetic substance, but prohibited in organic), Ammonium Citrate and Ammonium Glycinate (as chelating agents, to supply micronutrients not readily available to plants in deficient soils), Calcium Acetate (a plant micronutrient, to prevent calcium deficiencies and sunscald), and, Paper Planting Pots (MOSA facilitated this petition. Nitten paper chain planting systems aid transplanting of closely-spaced crops like onions, salad greens, and herbs.).

Strength through transparency

Folks accustomed to seeing organic only through the romance language on product labels can be taken aback when exposed to regulatory details, like considering the materials listed above. They may not realize how materials we allow are subject to intensive review regarding necessity, safety, and alternatives. The organic toolbox is very limited compared to, say, the 900+ synthetic active pesticide products registered by the EPA for use in conventional farming. (By comparison, organic production allows just 25 synthetic active pest control products.) Sometimes, we must be more outspoken to show organic as the right choice.

Back in August, the Wall Street Journal ran an opinion editorial which made false claims about organic. Many organic organizations and farmers pushed back. In September, at the annual Organic Trade Association membership meeting, I heard about OTA’s thought process regarding how best to respond. Rather than trying to communicate organic’s benefits (stating what organic IS), but perhaps not doing them justice, OTA placed a full-page ad in the Wall Street Journal showing what’s NOT in organic, with a USDA link for readers to learn more. The ad featured a comprehensive list of hundreds of chemicals and processes used in conventional food production that are prohibited in organic. Organic’s strength is its transparency. Usually, that is used like a window into our standards and practices. But, in this giant ad in the largest selling newspaper in the US, transparency showed the conventional side, our boundaries, and the difference in choosing organic.

And, in recent months, the NOP presented several webinars for certifiers and other organic stakeholders, regarding various enforcement topics. We’ve appreciated this open communication and participation has been high. Jackie’s policy update notes forthcoming rulemaking topics. So, we’ll all have more opportunity for continuous improvement, and at every turn, more discernment toward good choices.

Good work and the long view

In September, along with Certification Specialist Stephanie Leahy (and some valued help from our respective spouses) I was pleased to represent MOSA in Baltimore at Natural Products Expo East. We set up a booth and walked the trade show exhibit halls, representing our certified clients, learning about trends, and making new connections. I also enjoyed an opportunity to be an “expert” panelist in an “Organic 101” presentation. I think we did well. The days were long, but energizing. Organic’s good fruit implies a lot of hard work on the ground, and I was inspired by recognition of good people doing important work in the weeds, the details, and in the soil, which ultimately feeds healthy community.

At the OTA’s Organic Leadership Awards dinner, many were moved by wisdom from Margaret Scoles, as she was honored with the “Growing the Organic Industry” award. Margaret’s involvement in our organic movement began in the late 1980s. After graduating from the University of Arizona, she was an Organic Crop Improvement Association reviewer and inspector, and she’s been a tireless educator and organic ambassador ever since. She helped start what’s now the International Organic Inspectors Association, at another meeting in Baltimore in 1991, and has served as IOIA’s Executive Director for many years. Her nomination letter noted, “It’s not an exaggeration to say that most every certified organic product on earth is only a few degrees of separation from Margaret.” She shared some of her story and offered reflections on how we make choices and move forward. (The following comes from her written draft.)

“My first inspection was 30 years ago. I never really looked back. It became my life work - inspections, inspectors, and inspector training. As one operator after another opened their books and their operation to me, I realized what an honor it was to be the inspector – often the first inspector. I always asked this question in my opening meeting, “Why did you decide to go organic?” I wasn’t a purist; I was curious. Their stories changed me – If I’d taken a slight left turn after university instead of a slight right, I’d probably be doing genetic engineering. I LOVED genetics. I went into plant breeding at university to save and feed the world. One Nebraska farmer said it was because his wife had died of cancer. When they planted corn, she helped, and her task was to pour the fungicide on the corn seed and stir it in. Another crusty old Montanan said, “One day I put the 2,4-D in the tank and headed out to the field in the tractor. I stopped and thought, “What the hell am I doing? I’m putting poison on people’s food!” He stopped right then and never sprayed another herbicide on his grain.

Most of what I know I learned from the people and operations I inspected. I learned that the world runs on people who say “yes” when it would be easier to say “no.” ... The most important thing I ever learned in my whole life was the concept of opportunity cost. You can’t do two things at the same time. You have to decide what to do and when you make that decision, it means you are deciding not to do other things. On the file cabinet is this saying, “There is a positive side and a negative side. At each moment you decide.”

We’ve done so much, built so much, have a National Organic Program, international trade agreements, growth every year, organic products on most store shelves. A lot to be proud of. One thing to be less proud of is something that was happening then and it is now: tearing down, fighting against, pride and arrogance. In Broadus (Montana, population 45), we have a variety of churches, political viewpoints, economic disparity. But our community is too small not to help each other bury our dead or pull each other out of a snowbank. There are no strangers. We have to get along. We know that we aren’t big enough to build walls and be isolationists. The organic community is like that. We are too little to allow ourselves to be fractionated. I’m not saying that we should all oppose any fractions. I’m saying the opposite. We are too small to fight. We just need to be clear that we are all in the big fight together. We are still neighbors and friends. We need to maintain bridges.


Leadership Awards winners Margaret Scoles, Stephanie and Blake Alexandre, and Javier Zamora (OTA photo)

R. Buckminster Fuller said, “You can never change things by fighting the existing reality. To change something, build a new model that makes the existing model obsolete.” This note has resided on my file cabinet since 2005. We are building a new reality. This summer, I inspected a farm on the plains where I was the first inspector about eight years ago and there was one crop. This year, there were several crops, cover crops, and birds everywhere in the organic fields, much more than in the no-till, sterile, Roundup’d fields next to them.

It is really easy to lose focus and fall into despair. It is harder to choose the positive, always. But we have that choice. The real fight is a fight to detoxify our planet, stop extinction, create healthy food systems, and stop CO2 buildup and hopefully reverse the worst impacts of climate change.” … I challenge us all to keep saying “yes” when it is easier to say “no” when it is the right thing to do. That’s how communities survive and thrive.

A similar call came from Rising Star award winner Javier Zamora, who immigrated to the U.S. in 1986 and worked in the service industry in California for 20 years before going back to school at the age of 43. He earned his GED and a degree in landscape design, then studied horticulture. With help from the Agriculture and Land-Based Training Association, he started farming organically in 2012 on 1.5 acres and now owns JMS Organics, with over 100 acres on California’s Central Coast. Now, as a mentor to other farmers, he hopes “to create more Javiers who can be successful.” He observed, “Many in this room have the opportunity to make a change. It’s entirely up to us.” And he cautioned, “A lot of people these days are being more divisive. Instead of fighting, let’s fight to make this bigger, domestically. We need more organic farmers.” And from his own experience, he reminded, “Some people need a little help to make things happen… If you only get five hours of sleep like I do, believe me, you'll go to sleep a lot better because you're helping someone.”

More wisdom came from Stephanie and Blake Alexandre. They operate the grass-based Alexandre EcoDairy Farm on the northern California coast. While accepting their Organic Farmer of the Year Award, Stephanie shared how they’ve learned, “It’s not about who’s right; it’s about what’s right. And what is right is producing cleaner, nutrient-dense food and getting it into the mouths of our babes.” They also shared some struggles and stressed the importance of never giving up. Stephanie shared words from Psalm 104, echoed by Blake’s metaphorical observation that “the fruit grows in the valleys.” They explained that being a force of good change requires they “do the right thing at every turn, no matter what the cost.”

Our good work comes to fruition through strong will, and faith in right choices. For consideration, I recently happened upon this poem from Miguel De Unamuno, which speaks to the work and the long view.


Shake off this sadness, and recover your spirit;
Sluggish you will never see the wheel of fate
That brushes your heel as it turns going by,
The man who wants to live is the man in whom life is abundant.

Now you are only giving food to that final pain
Which is slowly winding you in the nets of death,
But to live is to work, and the only thing which lasts
Is the work; start there, turn to the work.

Throw yourself like seed as you walk, and into your own field,
Don’t turn your face for that would be to turn it to death,
And do not let the past weigh down your motion.

Leave what’s alive in the furrow, what’s dead in yourself,
For life does not move in the same way as a group of clouds;
From your work you will be able one day to gather yourself.