Please Keep Organic Certification for Hydroponics and Similar Technologies Available!
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Disallowing soilless farming methods from Organic labeling comes at a significant cost to consumers, producers, and the environment.
Disallowing Organic certification for crops grown in the absence of soil will result in a tremendous inequity to farmers, communities, and consumers as access to crops grown according to Organic will continue to diminish. Furthermore, a ruling mandating soil for Organics will stifle technological developments that can produce crops of the same quality with less impact on the environment. As our population continues to increase and access to areable soil decreases, alternative methods of farming that don’t require soil is the only viable option to feed our communities.
What is “Organic”? According to the USDA:
- Organic is a labeling term that indicates that the food or other agricultural product has been produced and processed using approved methods. These methods integrate cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity. Synthetic fertilizers, sewage sludge, irradiation, and genetic engineering may not be used.
Further, the USDA instructs that Organic crop production standards require:
- Land must have had no prohibited substances applied to it for at least 3 years before the harvest of an Organic crop.
- Soil fertility and crop nutrients will be managed through tillage and cultivation practices, crop rotations, and cover crops, supplemented with animal and crop waste materials and allowed synthetic materials.
- Crop pests, weeds, and diseases will be controlled primarily through management practices including physical, mechanical, and biological controls. When these practices are not sufficient, a biological, botanical, or synthetic substance approved for use on the National List may be used.
- Operations must use Organic seeds and other planting stock when available.
- The use of genetic engineering, ionizing radiation and sewage sludge is prohibited.1
Hydroponics. Aquaponics. Bioponics. (Future technology)ponics. All of these farming methods are capable of adhering to traditional Organic production goals. Just because they don’t rely on soil as a growing medium does not mean that they are any less capable of complying with the basic principles behind the Organic standards. In fact, there is a very strong argument that these new technologies achieve the same goals while also improving sustainability standards.To meet the growing demand for future Organic produce will require the use of technology that produces more crops with fewer inputs. If soil is a necessary component of Organic, it is being incorporated at the disadvantage of other growing methods that could have strategic market advantages in certain markets; i.e. where year-round soil production is impossible.
Some argue that the Organic label isn’t necessary to sell produce that is pesticide and herbicide free. They posit that a different label could be used without detriment to these farmers. While that may be partially true, the lack of Organic certification undoubtedly puts farmers at a significant disadvantage. A separate label will require incredible investment in consumer education to denote a product that is produced according to the same standards and principles. As one colleague pointed out in response, “That label has been etched into the American consumer’s brain for decades. Grocery stores don’t call it the ‘grown under healthy standards’ section, it is the ‘Organic’ section.” Furthermore, creating a separate label will require an entirely new set of standards and regulations. That will take years to work through at a cost of millions. Most farmers, especially community-based operations, can’t afford the costs associated with a new label.
Our global population is expected to reach 9.7 billion by 2050. Resulting food demand will increase anywhere from 59% to 98%, which will surely redefine agricultural markets and food production expectations. The author points out that “Farmers worldwide will need to increase crop production, either by increasing the amount of agricultural land to grow crops or by enhancing productivity on existing agricultural lands through fertilizer and irrigation and adopting new methods like precision farming.” It is clear, however, that the social and ecological effects of producing more agricultural land comes at a significant cost. Additionally, Organic crop yields using traditional farming methods are growing far too slowly to meet the forecasted demand for food. If we don’t embrace new technologies used to accomplish the same principles then we might not even have the option to grow Organically. Alternatively, Organic crops will command such a premium (increased demand with consistent or reduced production) that they will be unavailable by the general public. Both outcomes being detrimental.
The Organic definition was created as a set of standards meant for producers to strive to achieve. It stands for a list of principles meant to signify good for the environment and good for the consumer. In a consumer’s mind, Organic is best. If we disallow alternative methods of farming then we run several risks none of which are as great as the risk of modifying the standards to include new technologies that embrace the principles of Organic. Furthermore, it is a known fact that most soilless farming methods require significantly fewer resources to achieve similar, if not better, results. For example, plants grow faster with fewer nutrient inputs, most operations use a fraction of the same water (10% is a common statistic), and the use of herbicides and pesticides can be completely eliminated. If the basic premise of Organic can be achieved while also improving crop quantity and quality and conserving natural resources then the answer to whether we should include new farming methodologies within the umbrella of Organic should be a resounding YES!
The original Organic standards created a set of guidelines for then-current technologies aimed at improving soil quality, avoiding fertilizers, conserving water, and improving biodiversity. It is unfortunate that the original drafting including the words “soil” since these same goals can all be achieved through the aforementioned technologies. Nobody is suggesting that all soilless farming operations be certified Organic, only that they are allowed to be certified Organic if they adhere to the same rules and principles long established. At the time of creation, farming in dirt was the most prominent method of farming around. “Soil” was a means to the end, not the necessary component, and differentiating factor, as some have suggested.
As Thomas Jefferson pointed out in reference to statutory interpretation (a practice lawyers employ when determining the intent of a law): "In the construction of a law, even in judiciary cases of meum et tuum, where the opposite parties have a right and counterright in the very words of the law, the Judge considers the intention of the lawgiver as his true guide, and gives to all the parts and expressions of the law, that meaning which will effect, instead of defeating, its intention. But in laws merely executive, where no private right stands in the way, and the public object is in the interest of all, a much freer scope of construction, in favor of the intention of the law, ought to be taken, and ingenuity ever should be exercised in devising constructions which may save to the public the benefit of the law. Its intention is the important thing: the means of attaining it quite subordinate." –Thomas Jefferson to William H. Cabbell, 1807.
Our position, here, is that the definition of Organic should evolve to keep up with changing technologies directed toward achieving the goals previously defined. This is not a matter of private right. Instead, it is an issue of public interest. The inclusion of soilless farming methods within the Organic standards is consistent with the original intention of the drafters and serves to benefit our entire community.
When the original standards were drafted, few were aware of other technologies available. The use of the word “soil” as it applies to growing medium is not meant to denote the only method of growing that the principles apply to; instead, it was the only method of farming accepted. Had the original drafters been familiar with soilless growing techniques surely they would have been persuaded to include a broader definition of growing food through the employ of biological activity, sustainable practices, and other inputs that fall within the scope of existing OMRI requirements.
Finally, and without trying to illicit incredible panic, it should be noted that removing Organic certification from existing operations could pose other problems. Many operations have spent considerable time and money to get certified Organic. They have altered production systems, changed inputs, and made concessions in certain efficiencies to subscribe to the guidelines. If these producers have their certification stripped it will come at a significant disadvantage for producers and a potential liability issue for both the NOSB and the USDA.
We respectfully request that you consider our pleas above and come out in favor of keeping the Organic label available to crops grown without the use of soil.
 “Organic Production and Handling Standards.” National Organic Program Office. November of 2016. Available: https://www.ams.usda.gov/publications/content/organic-production-handling-standards
 Elferink, M., & Schierhorn, F. (2016). Global Demand For Food Is Rising. Can We Meet It? Harvard Business Review. Available: https://hbr.org/2016/04/global-demand-for-food-is-rising-can-we-meet-it
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