Michigan Organic Listserv
March 27, 2012
Offered by: Center for Sustainable Food System at
Michigan State University
Note any product or commercial process mentioned in this newsletter is not promoted by MSU. Please use this information to improve your farm business and knowledge.
Note we have a new section at bottom of this newsletter: Farm Classifieds: Please send me any classified that are items for sale that are use in farming or items that you are seeking.
Planning to start a new business??
Before starting a new business or modifying a current one be sure you have the market to purchasewhat you are intending to offer. This is true even for those considering certifying their farm with National Organic Program (NOP). Farming as a certified organic farm should indicate you have markets that demand organic produce from your farm. To make this process worthwhile, you must identify a market(s) willing and able to purchase the certified produce or product at the increased price (as the value is higher). The reason for certification is typically more than just to expand market opportunity but if you are counting on profits from this business then this is an important consideration.
Before starting a new business you should do some investigative work before-hand. Write up these findings as a business plan to serve as a guide for you as you develop yourbusiness. This is an essential piece for a new business to plan wisely and investigate thoroughly. This is especially critical if you intend to seek funds, through loans or even grants. The cost to certify is more than just the fees with the certifying agency but also the time for the person(s) to maintain and complete the records that are required by NOP for organic certification throughout the year.
The cost to certify is more than just the fees with the certifying agency but also the time for the person(s) to complete and maintain the records that are required by NOP fororganic certification.
Some aspects to include in a plan before starting a new business include:
Do you have the skills needed or access to learning them or hiring someone with the needed skills?
Is there adequate demand for the product(s) and can you get a fair price that not only covers the production costs but also offers you a profit?
Don’t forget that production costs include your wages for the hours you work as well as hiredlabor.
Do you have the financial buffer if the demand for the product is low which is common for new business, especially in the first year?
If (when) the demand for the product increases do you have the ability to increase production tomeet the demand?
News about Farm Bill and NOP
USDA mulls tougher organic inspection rules
Federal officials are considering how to implement unannounced inspections of certified organic operations and beef up qualification criteria for inspectors, at the recommendation of the National Organic Standards Board.
In a March 21 memo to the NOSB, the deputy administrator of the National Organic Program, Miles McEvoy, responded to those and other recommendations the standards board made at its 2011 fourth-quarter meeting.
Recommendations for inspector qualifications are:
A baseline pre-requisite expertise for initial organic inspectors;
Continuing education requirements for inspectors; and
Accreditation criteria for certifyingagents to ensure adequate oversight.
McEvoy said in thememo that the NOP will use the recommendation to develop baseline criteria. He also said NOP has commissioned “additional work in this area” with the International Organic Inspectors Association.
In response to theNOSB recommendation for unannounced inspections, McEvoy said the NOP will “explore ways to implement inspection requirements to enhance organicintegrity.”
The standards board had three specific recommendations regarding unannounced inspections, which the board members contend would help “uphold organic integrity” for the U.S. Department of Agriculture’s organic certification seal.
The standards board wants mandatory unannounced inspections for at least 5% of certified operations each year. The board recommended the inspections could be random, risk-based or the result of a complaint or investigation.
The scope of unannounced inspections, as recommended by the NOSB, could be limited, with the collection of samples depending on individual situations. The NOSB recommended that an unannounced “full inspection” could serve as the annual on-site inspection for a certified operation.
The NOSB also recommended that the NOP regulate material review organizations. Currently NOP has accreditation processes for third-party organic certifiers for crops, livestock, handling and wild harvest, but not for the review of materials used in organic operations.
Members of the standards board recommend that accreditation of material review organizations include:
A requirement that they use the NOP material classification guidance — which is still in development — to determine whether a material is synthetic or non-synthetic;
Implementation of a quality management system with detailed review protocols and policies as required by ISO Guide 65 accreditation standards;
Mandatory use of the NOP’s guidance for permitted generic substances, which is under development;
A requirement that part of their financing come from manufacturers of products seeking review; and
Adoption of the appeals process used by certifying agents.
The standards board also recommended that material review organizations be subject to compliance and enforcement actions of the NOP.
McEvoy’s memo did not indicate whether the NOP would develop an accreditation process for material review organizations. He merely said the NOP would report back to the NOSB “on how we plan to proceed with these recommendations.”
Sen. Debbie Stabenow tells Michiganfarmers to expect changes
WASHINGTON, D.C. (Maureen Groppe, Gannett Washington Bureau) - Support no longer exists for the federal payments that some farmers get in both good times and bad, Sen. Debbie Stabenow told the Michigan Farm Bureau Friday.
The Michigan Democrat, who chairs the Senate Agriculture, Nutrition and Forestry Committee, told the farmers that she's working instead to get an expanded crop insurance program included into this year's rewrite of farm policy.
"Crop insurance really is the main foundation of risk management and we need to strengthen that as we make changes," Stabenow said. "There is not support to continue direct payments so we've got to find other options to support farmers."
Wayne Wood, president of the Michigan Farm Bureau which brought 120 farmers to Washington for three days of lobbying, said he backs that change.
"That's a great tradeoff," Wood said. "I (could) look you in the eye and tell you I don't get a check to farm."
Producers of corn,soybeans, wheat, rice and cotton get fixed payments based on their land's past production, no matter what the price of crops. Farmers also may collect additional funds from programs tied to fluctuations in market prices and for conservation programs. They also benefit from a federally subsidized crop insurance system.
The $73.5 million that Michigan farmers received in fixed payments in 2010 ranked 20th among states, according to a database compiled by the Environmental Working Group. One reason Michigan doesn't rank higher is the direct payment program doesn't cover specialty crops such as fruits and vegetables. Stabenow wants to include those crops in the expanded crop insurance program she's working on.
Rewriting farm policy, which has to be done before current law expires at the end of September, always requires juggling competing regional interests as southern cotton farmers have different risk issues than do Illinois corn growers or Michigan apple farmers.
Passing a multi-year farm bill, which also covers nutrition programs such as food stamps, is also complicated by the tightened federal budgets.
Wood said that's why this year it was more important than ever that Michigan's farmers came to Washington to be heard.
"We're such a small percentage of the population and we're dealing with a huge deficit," he said. "A small percentage of the population maybe doesn't have the voice because our country has never had a food shortage."
Stabenow said she hopes to have a bill completed by her committee and ready for the Senate totake up by early May. House action could be a tougher haul, she said, because there are many new House members who haven't worked on a farm bill before and don't know why it's important.
"So I'm really glad you're here because we have a lot of communicating to do," Stabenow said.
Ingham County farmer Jake Wamhoff said that's why he came.
"We kind of put a personal touch to it," he said. "They see a face. They get a name. It's better than a letter."
In addition to thefarm bill being worked on, another key issue for Wamhoff and other farmers is a rule proposed by the Labor Department to strengthen enforcement of child labor restrictions on farms. Children under 16 could work only on farms owned or operated by their parents.
"They couldn't run a wheelbarrow or nothing," said Brian Combs, who works on a farm in Homer that hires youth in the summer for part-time work.
The Labor Department has said it will rework the proposed rule to allow for different types of family ownership of farms.
Gwyn Lewis, whose husband works on a St. Clair County farm that has been in the family for five generations, said their children would not be able to help on the farm under the way the rule was originally proposed because her husband is not the sole owner.
"It's just so shocking," Lewis said. "Some of the things that they say are hazardous on the farm are not hazardous if you learn properly. And of course with any employee, especially your kid or your nephew, you're going to make sure they follow the safety precautions. You don't want them hurt."
Lewis and others said they were pleased that they heard support from lawmakers for their concerns.
"There has been a tremendous outcry from the farming community," Wamhoff said. "I think we've had an impact."
House and Senate Move Forward on Different Paths with FY 2013 Appropriations
March 22nd, 2012
On Tuesday, March 20, the National Sustainable Agriculture Coalition (NSAC) delivered its fiscal year (FY) 2013 agriculture appropriations testimony to the House Agriculture Appropriations Subcommittee. The testimony includes NSAC’s FY 2013 appropriations requests for critical conservation, rural development, marketing, research, credit, and beginning and minority farmer programs. We will deliver matching funding requests to the Senate Agriculture Appropriations Subcommittee next week.
You can visit our annual appropriations webpage to download and read the testimony.
Senators have until March 30 to deliver food and agriculture funding request letters to SenatorHerb Kohl (D-WI), Chairman of the Subcommittee. The deadline for member letters in the House was March 20.
While there is no set timeline, both subcommittees are likely to mark up their respective agriculture appropriations bills in the next few months.
House and Senate Budget Committee Action on Discretionary Spending
On Wednesday, March 21, the House Budget Committee passed its FY 2013 budget resolution, which sets a top-line funding cap for discretionary spending in FY 2013. The budget resolution caps discretionary spending at $1.028 trillion, which is $19 billion less than the top-line number that Congress agreed upon for FY 2013 in the Budget Control Act of 2011. That Act set up a series of automatic cuts, known as “sequestration,” which would begin to take effect in January 2013. The House budget resolution aims to replace the sequester for FY 2013 (but not for the following nine years)with an alternative set of cuts, including the extra $19 billion generated by further reducing the discretionary spending cap and much larger savings from mandatory programs, including Medicaid, Medicare, and the farm bill.
If the House passes the budget resolution, which they are expected to do next week, the House Appropriations Committee will have to conform to this extremely limiting spending cap. The next step for the House Appropriations Committee will be to use the top-line cap to set sub-allocations (also known as 302b allocations) for the various appropriations subcommittees, including the Agriculture Appropriations Subcommittee. The sub-allocation will determine how much money the Subcommittee has to work with when setting FY 2013 spending levels for discretionary farm bill programs.
The Senate will also be moving forward with its appropriations bills. Senator Kent Conrad (D-ND), Chairman of the Senate Budget Committee, filed a “deeming resolution” on Tuesday, which allows the Appropriations Committee to begin work on its FY 2013 bills. Unlike the House, however, the Senate willuse the spending cap agreed to by the House, Senate and White House in the Budget Control Act of 2011 to determine its sub-allocation to the Senate Agriculture Appropriations Subcommittee.
The House budget action to renege on last summer’s budget deal, assuming passage when it reaches the House floor next week as seems likely, puts the two chambers at odds over the funding bills. It thus quite possibly sets the stage for another showdown over a potential government shutdown at the end of September, this time just in advance of national elections.
House Hearings on Farm and Research Programs
Meanwhile, the House Agriculture Appropriations Subcommittee held two hearings this week, the first on USDA’s FY 2013 budget requests for the Farm and Foreign Agricultural Service mission area, and the second on the USDA’s requests for the Research, Education, and Economics mission area.
At the first hearing, the Subcommittee raised a number of questions about the Conservation Reserve Program (CRP). The President’s budget requests a CRP enrollment of 30 million acres in FY2013. FSA Administrator Bruce Nelson testified that there are now 29.7 million acres in the CRP, down nearly 20 percent from FY2007. About 18 percent of the acres are in the continuous CRP conservation buffer and special wildlife practices component.
Earlier in the year, USDA announced a new highly erodible land initiative and a new grasslands, wetlands and biodiversity initiative to target enrollment of land in the continuous CRP. In addition, CRP contracts on about 6.5 million acres are scheduled to expire at the end of September 2012. USDA has opened a new CRP general sign-up, which began on March 12 and will end on April 6. The Administrator emphasized, in response to questions from Subcommittee Chairman Jack Kingston (R-GA), that CRP not only conserves resources and increases water quality but also supports recreational businesses and jobs in rural areas.
Administrator Nelson also noted that USDA suspended the CRP Transition Incentives Program (TIP) in February because over $20 million of the $25 million provided in the 2008 Farm Bill has been expended. The CRP-TIP offers two additional years of CRP payments to retiring landowners who agree to transition their expiring CRP acres to a new or socially disadvantaged farmer who enters the land into production using sustainable growing practices. Referring to CRP-TIP as a success and “a great tool” in the conservation toolbox, the Administrator noted that FSA is now reviewing about $1 million in pending requests for contracts in addition to the 1,500 contracts already obligated.
Issues concerning beginning farmers and ranchers and socially disadvantaged farmers and ranchers (SDA) were also covered at the hearing. In FY 2011, 63 percent of FSA direct lending, just over $1 billion, went to beginning farmers. FSA also assisted beginning farmers with an additional $735 million in credit through loan guarantees in FY 2011. Since FY 2006, FSA has increased its lending total to beginning farmers by 63 percent.
Representative Sanford Bishop (D-GA) emphasized the importance of FSA loans to socially disadvantaged farmers and requested a state-by-state breakdown of such loans. He also questioned whether the funding provided to the USDA Office of Advocacy and Outreach is sufficient and urged that the Office do more outreach.
Following the Farm and Foreign Agricultural Service hearing, the Subcommittee examined the President’s FY 2013 request for the programs that fall within USDA’s Research, Education, and Economics mission area.
A number of questions were asked about the Agriculture and Food Research Initiative (AFRI) and Sustainable Agriculture Research and Education (SARE) program. Representative Cynthia Lummis (R-WY) voiced her concern that only 30 percent of AFRI funding is going to the foundational program. Currently, 70 percent of AFRI grants are administered through the “challenge area” component of the Initiative. In line with Rep. Lummis’ comments, NSAC has advocated for a better balance between foundational grants and challenge area grants. Similarly, Rep. Sanford Bishop (D-GA) urged USDA to ensure that increased funding for AFRI does not come at the expense of funding for other grant programs that offermore opportunities for smaller projects to successfully compete for funding.
Rep. Sam Farr (D-CA), Ranking Member of the Subcommittee, noted with favor that the Administration has requested money for the federal-state matching grants component of the SARE program for FY 2013. Rep. Farr asked the witnesses to explain how this component would enhance the keystone sustainable agriculture program at USDA.
The USDA witnesses at the hearing noted that the state matching grant component would allow the agency to integrate sustainable agriculture into the state experiment stations and extension service in order to serve and reach small and mid-sized farmers across the country. USDA Undersecretary of Research, Education, and Economics, Catherine Woteki, explained that there has not been any meaningful increase in funding for sustainable agricultureresearch in a decade. In fact, despite its $60 million farm bill authorization, the entire program was funded at just $19.2 million in FY 2012.
NSAC will continued monitor the appropriations process and will you apprised as events unfold.
Path to the Farm Bill: Stripped Down House Farm Bill by April 27?
March 22nd, 2012
Members and readers have been calling and writing asking for insight into what the House budgetresolution — introduced on March 20, passed out of the House Budget Committee on March 21, and headed to a vote on the House floor next week — means for the new farm bill. We will do our best to try to make sense of the complex and still unfolding situation in simple terms.
Budget-Driven Hurry Up Farm Bill…Ultimately Signifying What?
Most importantly, the House budget resolution calls on six authorizing committees, including the Agriculture Committee, to report a “budget reconciliation” bill by April 27. In the case of the Agriculture Committee, their specific instructions are to cut spending from the farm bill baseline (projected spending) by $33.2 billion over the next 10 years, including a whopping and disproportional $8.2 billion in 2012 and 2013.
This figure compares to the draft farm bill agreed to by House and Senate Agriculture Committee leaders last year that proposed to cut $25 billion (gross) from the farm bill 10-year baseline for a net savings of $23 billion. Besides the obvious difference of the additional $10 billion in proposed cuts in the new House budget resolution, the draft deal from last fall also had the cuts somewhat back loaded into the second five years of the 10-year budget window, compared to the heavy front-loading in the new House proposal.
Under the special budget reconciliation process, the only germane provisions are those that either save money or cost money in portions of the farm bill with mandatory or direct spending. Policy changes, however important they may be, that do not change mandatory funding under the Agriculture Committee’s jurisdiction are not generally allowed. This would include nearly all of the myriad farm bill provisions that establish policy and programs that are authorized by the farm bill, subject to appropriations in the annual (discretionary) agricultural appropriations bill. It will also include directives to USDA about new priorities, regulatory issues, and program consolidation and streamlining initiatives, among other categories.
Hence, it would not be entirely accurate to call the bill that the House Agriculture Committee must deliver to the Budget Committee before the end of April the farm bill per se. Strictly speaking it is not the farm bill, though with all the major farm bill funding decisions made, including presumably all of the specifics of new commodity subsidy programs widely assumed to beincluded in the new farm bill, it is also not at all clear when or how the Committee would return to take up all the other provisions that would normally go into a comprehensive farm bill.
More importantly, it is quite clear that the Senate will not be undertaking any similar budget reconciliation exercise. So once the House committee reports its $33.2 billion in net cuts to the Budget Committee, and the Budget Committee wraps it together with the cuts from the other five Committees with reconciliation instructions and sends it to the floor for avote on the whole package, that is likely the end of the story for this bill. There will be no similar reconciliation bill from the Senate with which to go to conference, and it would logically then die at that point. Should Congress decide late in the year to take some action to forestall some or all of the automatic spending cuts (see below), it is possible some of the ideas in the House budget reconciliation package could come back into play at that point in time.
However, having made some very big, tough, and fast decisions to come up with the $33 billion, those on the Committee voting in favor of the stripped down farm bill may hang onto some or all of the components of the budget reconciliation bill if, later in the process, there is actually a more normal farm bill debate and conference. Hence there could be an ongoing impact even if the specific legislative vehicle dies.
The purpose of thebudget reconciliation maneuver by the House majority leadership is to come up with a package of cuts that would delay for one year the automatic cuts (called sequestration) that are scheduled to take effect January 1, 2013 as a result of the failure of the Super Committee process last fall. A substantial portion of the automatic cuts fall on the defense budget and the House majority leadership wants to prevent any of those defense budget cuts from happening. The reconciliation bill, together with a proposed $19 billion cut to annual appropriations for FY 2013 below the levels agreed to between the House, Senate, and White House just last summer, would negate one year’s worth of the $1.2 trillion 10-year automatic cuts.
The ten-year impact of sequestration on the farm bill baseline would be less than half of the $33 billion mandated by the House budget resolution, yet the House reconciliation package is geared to just delaying sequestration by one year. That would suggest that if the House Republican budget leaders had their way, there would be a need for regular,repeat budget reconciliation packages each year, potentially with bigger proposed farm bill cuts yet to come, to continue to delay sequestration. In other words, rather than being disproportional by a factor of two, the accumulated effect could be even greater disproportional cuts to food and agricultural spending relative to other government functions.
While the programmatic changes to reach $33 billion is totally up to the Agriculture Committee to decide, and while they could essentially start from scratch and decide how much to take from nutrition, crop insurance subsidies, commodity subsidies, and conservation programs — the four big pots of mandatory farm bill spending – it is generally assumed the starting point would likely be something very close to the $23 billion net savings deal reached by the Agriculture Committee leaders last fall, but with the additional $10billion cut tacked on, including the big $8 billion immediate cut.
Unconfirmed rumors on Capitol Hill suggest that the working assumption about the extra cuts is that they would target nutrition programs for low-income Americans, primarily through cuts to SNAP (food stamp) benefits. Needless to say, that would be a highly controversial proposal. If it is latched onto as a crusade, it could by itself quite easily doom chances for a farm bill this year.
One final thing tonote about the stripped down farm bill on tap for April 27 — timing. After the House floor vote on the budget resolution next week, there will be only seven working days on the House calendar for the Agriculture Committee to report the bill, in large part due to the schedule two week Easter recess which will shut down the House from March 30 to April 15. So, absent a successful floor amendment next week to change the due date beyond the end of April, the House Agriculture Committee will have the herculean task of producing a bill in a week’s worth of legislative days.
Meanwhile, back over in the Senate, plans are still proceeding for a Senate Agriculture Committee mark-up of a more comprehensive farm bill under normal procedures sometime in April or May. With two very different processes in the two chambers, it is anyone’s guess as to how this whole thing plays out. It is like two trains heading down two different parallel, non-intersecting tracks. Whether a train can jump the tracks and actually get us to a 2012 Farm Bill will take a great deal of legislative ingenuity.
The two primary options remain passing a comprehensive farm bill this year, on time and on schedule, or, in the alternative, passing a one-year extension of the current farm bill, either exactly as is, or with modifications. Time will tell, but it would not be a bad bet at this point to think that sometime before summer a decision will need to be made about whether or not to start negotiating an extension of current law if it appears by then it will come to that.
What About All the Other Cuts We Have Been Hearing About?
The source of much of the confusion we have been hearing about from members and readers the last couple of days has to do with all the other farm bill numbers included in the political and explanatory document accompanying the House budget resolution and calculated into the big picture numbers in the resolution itself. In the document, Budget Committee Chair Paul Ryan (R-WI) proposes that farm bill spending be cut over the next ten years by over $180 billion, very similar to the budget he presented and the House approved on a party line vote last year.
Those bigger numbers include over $30 billion in cuts to commodity and crop insurance subsidies, $16 billion in cuts to conservation programs, and a whopping $134 billion cuts to nutrition assistance. The bulk of the nutrition cut would come from turning the federal program into a state block grant at reduced funding and with tighter eligibility standards.
We will report a bit more on those proposals in a separate later posting. For current purposes, we would just note two things.
First, these huge and highly disproportional farm bill cuts in the House Republican budget are very important to the various claims the Chair and the majority leadership are making about how much of a bigger impact their proposal would have on deficit reduction compared to the President’s proposal. In other words, they are part of the additive mix to come up with the macro numbers used to sell the budget proposal.
Second, however, they are unrelated to the immediate mandate to cut $33 billion from the farm bill through legislation that must be passed before the end of April. The latter is where the real action is, and the former are more like long-term suggestions (not to mention fodder for many upcoming campaign debates as we approach election day in November). The House Agriculture Committee will use its own judgments on how to reach the $33 billion cut and does not have to pay any particular attention to assumptions made for purposes of putting together the budget resolution.
We hope this explanation is helpful to those trying to follow along on the path to the farm bill. In a related post, we describe the impact of the new House budget resolution on the agricultural appropriations process.
Path to the 2012 Farm Bill: NSAC Releases 2012 Farm Bill Policy Platform
March 19th, 2012
Today, the National Sustainable Agriculture Coalition (NSAC) released its 2012 Farm Bill policyplatform, Farming for the Future: A Sustainable Agriculture Agenda for the 2012 Food & Farm Bill. The platform is the culmination of two years of policy work with a broad, diverse coalition of over 90 grassroots organizations from across the country. It reflects the real, urgent needs of farmers, ranchers, and food entrepreneurs.
With a round of Senate Agriculture Committee hearings complete and House Agriculture Committee field hearings underway, Congress is currently working to write a new farm bill before the current one expires September 30, 2012. The economic, environmental, and public health crises of our time demand decisive farm policy reform that will ensure a more sustainable future for American agriculture. Adoption of the National Sustainable Agriculture Coalition’s 2012 Farm Bill platform will expand opportunities to produce good food, sustain the environment, and contribute to vibrant communities.
“Slow job recovery, a rapidly aging farm population, accelerating erosion and nutrient pollution, and atrophied regional food infrastructure can be viewed as a crisis or an opportunity,” said Susan Prolman, NSAC Executive Director. “Done right, a new farm bill can be part of the solution, putting in place building blocks for a more sustainable future of thriving farms, healthy food, and strong communities.”
Farming for the Future spans nearly every title in the farm bill and reflects a comprehensive approach to farm policy reform that will –
Create jobs and spur economic growth through food and farms. Local and regional agriculture creates economic opportunities. NSAC supports policy that will improve processing and distribution infrastructure for such agriculture and expand access to healthy food for consumers, including underserved communities. A sustainable 2012 Farm Bill will also enable small business development and revitalize rural areas through investments in training, technical assistance, and microcredit for rural entrepreneurs.
Invest in the future of American agriculture. NSAC’s platform recognizes that agriculture is a growing sector of our nation’s economy, yet barriers make farming and ranching one of the hardest careers to pursue. The 2012 Farm Bill should include policies that enable beginning and socially disadvantaged producers to access land, credit, and crop insurance; to launch and strengthen new farm businesses; and to receive appropriate training and mentoring will ensure that more people canstart to farm and that the nation’s food supply remains viable.
Enhance our natural resources and improve agricultural productivity. As stewards of 40 percent of the landmass in the United States, American farmers and ranchers are important managers of our natural resources. Farming for the Future supports funding and strengthening working lands conservation programs to help producers protect and rebuild soil, improve water and air quality, and reverse habitat loss whilemaintaining productive farms and ranches. Nascent policy should modernize the farm safety net and protect the productivity of agricultural lands by ensuring that producers avoid environmentally harmful practices when they receive crop insurance subsidies.
Drive innovation for tomorrow’s farmers and food entrepreneurs. Investment in agriculture research is vital to continued productivity and innovation in diverse and expanding sectors of American agriculture. A research policy that funds and strengthens successful programs for sustainable agriculture, organic farming systems, and specialty crops; addresses new research and data collection needs; and improves coordination on essential public plant and animal breeding efforts will foster the innovations that farmers and food businesses need to be successful.
NSAC supports renewal and reform of the farm bill in 2012, on schedule. Congress will have to make tough choices to pass a farm bill that is forward-looking and fiscally responsible. Our measure of success will be whether Congress invests in the future of farming – and adoption of the policies in the platform can help lead the way.
“Congress should not delay the adoption of a new farm and food bill. It needs to do its job, this year, on time,” according to Prolman. “The new bill, though, should be comprehensive and forward-looking, not a rush job that ignores the big issues in favor ofshort-term expediency.”
Green Pest Management] Pesticide Use in Organic Facilities
Despite what you may have heard, pesticides CAN be used in organic food facilities. However, they must be used in such a way that no contact occurs between them and the organic food.
JAY BRUESCH | March 27, 2012 |
The title of this article, “Pesticide Use in Organic Facilities,” may have given you a little jolt. After all, organic food processing is all about avoiding the use of chemicals, isn’t it?
It most certainly is.
The accepted rules for doing pest control in organic food processing, packaging and storage facilities in theUnited States are laid out in the U.S. Code of Federal Regulations, Part 7 (Agriculture), subpart C, paragraph 205.271, which is called the “Facility Pest Management Practice Standard.” An equivalent rule is in place in Canada. This standard states that, prior to the use of any pest control material, non-chemical strategies must be tried and found inadequate to prevent or control pests. Non-chemical strategies include sanitation, pest exclusion and physical controls such as management of lighting, temperature, air movement and humidity. Mechanical controls, such as trapping, also should be attempted.
This means, in short, that your bait gun, sprayer, duster and other application equipment stay in the truck (for the most part) while you are servicing organic plants. Instead, your primary focus should be on inspecting and monitoring. As part of your inspecting activity, you should be looking for signs of pests and pest damage, and for any conditions that could allow pests to enter, hide, feed or breed inside the facility or near it. When you find deficiencies in sanitation, structural maintenance, lighting, air quality, personnel practices or any other factorthat contributes to pest invasion or survival, you must bring these to the attention of plant management, whose job is to correct those conditions.
Choosing Pesticides. Having established the primacy of non-chemical methods of preventing and controlling pests, however, there remains the reality that pesticides are necessary for prevention and control.
Every first-year pest control technician knows that cockroaches cannot be eliminated by cleaning alone; and that a food plant that is built within flying distance of a cattle feedlot is under heavy fly pressure, and some of those flies are bound to find their way inside — no matter how tight the screens.
Other pests — ants, occasional outdoor invaders and stored product pests — will find their way inside the plant, where they will get to work compromising food safety and violating the Federal Food, Drug and Cosmetic (FD&C) law that states that it is unlawful to prepare, pack or store food under conditions under which the food may become contaminated.
Even the organic rules themselves (the above-mentioned Facility Pest Management Practice Standard) acknowledge that pesticides are sometimes necessary, because the need for food safety under FD&C still trumps the organic rules. The organic rules say that, notwithstanding the obligation to use non-chemical measures:
A handler may otherwise use substances to prevent or control pests as required by federal, state, or local laws and regulations: Provided, that, measures are taken to prevent contact of the organically produced products or ingredients with the substance used.
So: What are the rules? How can I effectively apply pesticides in and around an organic plant when I need them, without running afoul of the inspection agencies that oversee these locations?
Sub-paragraphs (a) and (b) of the Facility Pest Management Practice Standard spell out the requirement that non-chemical measures must be the first line of defense against potential infestations, and the first line of attack against established infestations. Sub-paragraph (c) states that, in the event that non-chemical controls are not able to prevent or control pests, it is permissible to use a material named on the National List.
This brings up the question: What is the National List? Briefly stated, the National List is a portion of the National Organic rules that lists pesticide active ingredients that, by virtue of their natural origin or low-impact nature, are permitted for use in organic operations.
The so-called National List pesticides include those containing boric acid, natural horticultural oils, pheromones, vitamin D3 and elemental sulfur. You almost certainly have some materials in your truck or storeroom that qualify as National List pesticides — many cockroach and ant baits, for example, contain boric acid. Rodenticides are available that contain vitamin D3 (cholecalciferol) as an active ingredient. And several manufacturers offer sprays, dusts and other pesticides using horticultural oils as active ingredients. Refer to the listing of manufacturer Web sites on page 54 of this article for a more complete — though surely not exhaustive — list of manufacturers of National List pesticides.
Sub-paragraph (d) of the Facility Pest Management Practice Standard goes one step further, and states that, should a material named on the National List be found inadequate to prevent or control pests, we have permission to apply a pesticide whose active ingredient is not named on the National List.
Sub-paragraph (d) comes with two important conditions: in order to have the right to use a pesticide not named on the National List, you must update your written plan by indicating the product by name as a material you believe you might need; and you must apply it in such a way that there is no possibility it could come into contact with organic food, food-contact surfaces or food packaging.
Thus, your pest management program (proposal, service agreement or other formal written program) must include the names of products you might need; and it also should include a description of how you will apply each material, including how you will prevent contact of the pesticides with food.
Many pest management companies accomplish this compliance item by submitting, as part of their written pest management program, a list of authorized materials. The PMP and client can sign off on every material proposed for use, and this can then be shown to the representative of the organic certifying agency whose responsibility it will be to certify the organic operation, including its pest management program.
Applying Pesticides. Application of materials must be done in such a way that no contact occurs between the pesticides we apply and food, food-contact surfaces or packaging materials.When choosing and applying pesticides in organic facilities, refer first and always to the rules, as set forth in the Facility Pest Management Practice Standard. Then, live by these principles:
Low volatility. Baits, by virtue of their precise placement, very low volatility (low vapor pressure), low human toxicity and their tendency to remain where they are placed, are ideally suited for use in organic facilities. Given a choice of using a spray, a dust or abait, most would agree that baits are excellent choices for controlling cockroaches and ants in food plants. Use baits strictly according to label directions, and comply with all instructions pertaining to application methods allowed in food areas. Typically, crack and crevice or spot applications may be allowed; or applications will be restricted to crack and crevice in exposed-food areas. The relatively newer liquid fly baits are useful, but cannot be applied in exposed-food areas. They are, however, good for providing a zone of defense outside of exposed-food areas.
Retrievable placements. Cockroach bait stations, ant bait arenas, and even the use of treated cord wraps (described below) fall into the category of retrievable pesticide placements, which are deployed to do a specific job, and then removed soon after. Similarly, cockroach and ant gel baits can be applied to some kind of retrievable surface — a piece of stiff paper, rolled-up corrugated cardboard fastened with a rubber band, a sticky cockroach trap or one of the commercially available insect monitoring stations. These can then be placed in locations where cockroaches or ants feed, to be removed as soon as they are determined to have accomplished their purpose. By using retrievable placements, you can assure your client (and their organic certifying agent) that the only pesticide active ingredient left behind is that which remains in the bodies of dead cockroaches, ants or flies.
Limiting volatilization. Those products that may be of higher vapor pressure than baits, e.g. sprays, are not completelyunwelcome in organic plants. But they do have a tendency to become airborne, either as particles of overspray or by virtue of a higher vapor pressure when wet. You can overcome this problem by applying the products to a surface outside of the treatment area, and then bringing it inside after the deposit of insecticide has been allowed to dry. For example, in an area of high house fly pressure, panels of plywood can be painted white, treated with a residual insecticide whose label approves general treatment in food areas, and brought inside to a well-lighted area. They now serve as limited-time “attracticide” panels to reduce populations of flies as the flies come to rest on the treated panels. And they can be removed from the premises as soon as they have achieved their purpose of eliminating flies that invaded the area.
Here’s a summary of the rules for pest control in organic facilities:
1. We must first practice sanitation, exclusion, physical and cultural controls to both prevent pests and control them once they have invaded our organic food plant.
2. If those measures are found to have failed us, we are allowed to use a boric-acid, oil- or soap-based product, or one containing a pheromone, elemental sulfur or vitamin D3.
3. If those materials fail, we can use something else, provided we’ve obtained advance approval by listing the materials we want to have available in our approved materials list.
Above all, any product we apply must be used in such a way that no contact occurs between it and the organic food.
Similarly, hanging electrical cords and other prime house fly resting sites can be treated using cord wraps that are treated outside the exposed-food area, with an insecticide approved for spot treatment in food areas. Once the insecticide has dried, the wraps can be brought inside, placed around the hanging cords, and left in place overnight to kill flies that choose the cords for resting sites. The wraps can then be removed from the food area until another treatment cycle is determined to be necessary.
Removal for treatment. In some instances, an infested piece of machinery, equipment or other fixture can be unbolted from its base, brought outside the confines of the organic processing area, treated as necessary using whatever pesticides are deemed necessary, and then cleaned and brought back inside. In this manner, a complex piece of equipment or even an entire processing line could be removed, fumigated elsewhere, cleaned and returned to service without compromising the plant’s organic integrity.
Pheromones. Pheromones are allowed as a first line of defense against stored product pests. The trap grid you might have in place for Indianmeal moths, or the cigarette-beetle monitoring system you may be considering, are permitted in organic plants just the same as they are allowed anywhere else.
For facilities that are continuallyvulnerable to stored product moths, continue to monitor for them using pheromone traps, and continue to recommend sanitation improvements as a way of combatting food moths. But consider adding one of the newly introduced mating-disruption products, which consist of hanging plastic cards that, when used in relatively large numbers in a susceptible area, emit large amounts of insect sex pheromone. They put out so much pheromone, in fact, that male Indianmeal moths (and the males of some other food-moth species) are unable to home in on a receptive female. Eventually, the population suffers from the males’ inability to find females, and it “crashes.”
Allowed space treatments. Sometimes, night fliers, house flies or the exposed adult stages of stored product pests will need to be eliminated quickly in the interest of food safety, and space treatment will come to mind as the best way to deliver the needed treatment. There are space treatment options under organic rules; just remember that synergized pyrethrins are not allowed. Most commercially available pyrethrin concentrates and aerosols contain synergists such as piperonyl butoxide (PBO). Ask your company’s supplier to suggest a non-synergized pyrethrin space treatment material, and use it according to label directions in areas where its use is approved. You wouldn’t ever want to rely completely on space treatment, of course, but it’s one tool in an overall integrated game plan.
Fumigation. Except as noted previously (equipment removed from the site and fumigated) and except in the case of carbon dioxide treatments, fumigation is out of the question where organic food or packaging is exposed. It is in the nature of fumigants thatthey go everywhere and penetrate everything, so the NOP rule requirement that pesticides not come into contact with organic food cannot be upheld. If it were necessary to fumigate a plant area, all organic food would have to be removed and kept away for a period of time to be specified by the applicable organic certifying agent.
Exterior treatments. The more pests you can eliminate before they get into the plant, the fewer you’ll have to deal with according to organic rules. Just remember that pesticides used outdoors must stay there. For facilities that are under heavy fly pressure from neighboring sources (like the feedlot mentioned previously), do everything you can to reduce the number of flies that come to your organic location. You might even try to sign up off-site troublemakers as your own clients, and thereby have a little more to say about the numbers of flies coming to your organic plant.
Visit the organic plant during several different times of day (mid-morning and mid-afternoon, at least) to find out where flies rest and feed outdoors, and treat those areas with residual insecticides, liquid fly baits and other available products. Pay special attention to trash areas, outdoor break areas and other places to which flies may be attracted — and where they may congregate prior to finding their way inside, and apply insecticides to the insects’ resting areas. Always do this in such a way that employees’ hands or feet do not come into contact with treated surfaces, and so that the material you use cannot be carried or tracked into the building. When applying insecticides outside of a food plant (includingnon-organic facilities), stay away from air-intake vents, which might suck insecticide particles or vapors inside. If you want to use granular fly baits but don’t want to use the “scatter” method around an organic plant, consider using commercially available fly bait stations — or fashion your own using lengths of PVC pipe with a lengthwise slit cut into it, and hang them in locations where the chance of causing any contamination is zero.
Exterior pesticide applications might be needed for reasons other than flies. For example, plants under high pressure from local populations of crickets, ground beetles or other invaders might need to have these pests dealt with on the exterior so that pesticide applications are not needed on the interior. Again, when a need is demonstrated for suchapplications because sanitation, exclusion and “National List” materials are inadequate, make sure you make those applications in such a way that they cannot be blown on the wind, sucked in by air-intake systems, or tracked in on employees’ shoes or hands.
Also look at lighting, door policies and any other aspect of the organic facility you can influence in order to reduce the number of flies that are able to get inside. Are there mercury-vapor lights mounted over exterior doors? Have your client switch to sodium-vaporbulbs in those fixtures to reduce fly attraction. Are flies entering process areas via doors that employees use to go directly from process areas to the outdoor break area? Suggest a door-use policy that requires employees to access break areas via a more circuitous route — one that protects sensitive areas from direct exposure to the outdoors.
Progressive control. Look at the organic facility from outside to inside, identifying areas of successfully higher sensitivity. Try to focus all control measures — last of all, pesticide applications — most heavily on those areas of least sensitivity, including the plant surroundings, the immediate exterior of the building, waste and rendering areas, and then other non-food interior areas. In each successively more-sensitive zone, apply less-extreme prevention and control measures.
According to the rules discussed previously, do what needs to be done in the areas without exposed organic product. In most cases, it will either be unnecessary to use pesticides in exposed-food areas, or the need will be minimal and only occasional.
Rodent control. Traps are almost universally the control method of choice inside food plants, and this is especially the case in organic plants. Depending on the agency certifying your client as organic, it may be necessary to either switch to exterior traps instead of bait stations containing toxic bait; or you can use a block baitcontaining the active ingredient, cholecalciferol (vitamin D). Whether to use sheltered traps in outdoor rodent devices, or cholecalciferol bait, or whether to petition the organic certifying agent to allow another bait, depends on the rodent pressure from the surroundings, the facility’s history of rodent activity inside and the sensitivity of the product being manufactured.
Reminder. Remember that the organic rules apply within organic establishments, wherever you are. The rules say that you must first practice sanitation, exclusion, physical and mechanical controls, and that you may rely on National List pesticides if those non-chemical tools fail. Only when non-chemical measures and a National List material has been shown to be inadequate is it okay to use a non-National List material.
Depending on the specific organic certifying agent whose representatives visit and inspect your client’s organic facility, the actual importance of the National List — and the pesticides whose active ingredients are named on it — will be of greater or lesser importance. There are multiple organic certifying agents. Some require the use of a pesticide named on the National List as a required intermediate step, and some do not recognize the National List at all. In the case of agents that do not recognize the National List as an intermediate source of allowable pesticides, the rules are even simpler:
Practice sanitation, exclusion, physical and mechanical controls.
If that doesn’t work, you can use a pesticide (whether on the National List or not), provided you do so in such a way that you don’t contaminate organic food.
When using any pesticide, indoors or out, be sure to read and follow label directions pertaining to products andapplication methods permitted in and around food plants. In organic facilities as elsewhere, the label is the law.
You & the Organic Inspector. What kind of a relationship should you have with the inspector who visits the plant as a representative of the organic certifying agent? First and foremost, keep inmind that your client is your client, and your first obligation is to your client. Offer to your client that you are available for consultation, should the organic certifying agent’s representative want to speak with you about any part of your program. Within this context, it is a good idea for you to be available, in case any aspect of your program or any action your company took needs to be explained in more detail.
Especially when certification inspections are in progress, it’s a good policy to make yourself available to accompany the organic representative during the pest management portion of their site review if that person wants you to do so, or to be on hand for apost-inspection consultation or just to be on the grounds or available by telephone to answer questions. Ask your client what level of involvement they want you to provide, and then be available when and if they want you to be. Do not push yourself on anyone.
Summary. These are just a few ideas on the art of performing pest management in organic facilities. Beyond this, it is up to pest management professionals to learn the rules (see National Organic Program link below); know what products are available; and use their knowledge, creativity and problem-solving skills. Enjoy the challenges and rewards you’ll get from your organic accounts.
As always, the author invites anyone with ideas, questions or concerns to get in touch. We all learn and get better at our profession when we share with one another.
For links to the full text of the National Organic Program pest management rules (Facility Pest Management Practice Standard), visit www.ams.usda.gov/AMSv1.0/nop.