Crop Production Organic Certification

The Guidebook for Organic Certification has many questions in the area of crop production both agronomic and horticultural.  I have added a couple of comments and Missouri contacts within the questions. 

Q.  What is a buffer, and how do I know how big it needs to be?
     NOS §205.202(c) requires distinct, defined boundaries and buffer zones to prevent the unintended application of a prohibited substance to land under organic management.

     §205.2 defines “buffer zone” as “An area located between a certified production operation or portion of a production operation and an adjacent land area that is not maintained under organic management. A buffer zone must be sufficient in size or other features (e.g., windbreaks or a diversion ditch) to prevent the possibility of unintended contact by prohibited substances applied to adjacent land areas with an area that is part of a certified operation.”

     Because there are so many variables that can affect the kind of protection needed between organic and non-organic land, the national standards do not specify specific dimensions for buffer zones. Determination of buffer adequacy is left to the organic producer, the organic inspector, and the certifying agent on a case-by-case basis. A typical grassy buffer is between 25 and 30 feet wide, where the risk of drift or runoff would be considered minimal. Prohibited materials applied aerially by crop dusters or by high pressure sprayers can be areas where there is higher risk and the buffer zone required by the certifier may be larger than one where the conventional neighbor is using a typical ground sprayer.
     The Organic System Plan must describe how an organic operation will avoid drift from neighboring operations, particularly drift of prohibited pesticides and herbicides.
     Crops may be harvested in the buffer zone, but they cannot be sold as organic and documentation must be maintained detailing that they were harvested, stored and sold separately from the organic crops grown on the farm.

Q.  Genetically Modified Organisms (GMOs) are not allowed in organic production. However, if my product tests positive for GMOs even if I have not used them, will I lose my certification?
     The Preamble to the NOS regulation states: “This regulation prohibits the use of excluded methods (which include GMOs) in organic operations. The presence of a detectable residue of a product of excluded methods alone does not necessarily constitute a violation of this regulation. As long as an organic operation has not used excluded methods and takes reasonable steps to avoid contact with the products of excluded methods as detailed in their approved organic system plan, the unintentional presence of the products of excluded methods should not affect the status of an organic product or operation.”
     If a certifying agency has reason to suspect that an organic product has come into contact with prohibited substances or has been produced using excluded methods, the certifying agent can call for testing, which under certain conditions could result in that product no longer being considered “organic.”
     The markets where your organic crops are sold may require zero tolerance of GMOs, regardless of whether or not the crop loses its organic certification. GMO testing is frequently done by the buyers of organic soybeans sold to Japan and European markets and will be rejected if they test positive for GMOs. GMOs are part of the DNA of the entire plant and can be detected in the dust or other residue from GMO crops, so great caution must be taken to protect organic crops.
     If equipment used in planting or harvesting organic crops is also used for conventional crops it is important that you thoroughly clean the equipment before organic use to ensure that no contamination from non-organic or GMO crops occurs. You must document this cleaning in your records. Transport and storage of organic crops must also be in cleaned units, with documentation maintained.

Q.  Does any manure I use on a certified organic farm need to also be certified organic ?
No. You may use manure from any source, as long as there is documentation that it does not contaminate crops, soil or water with heavy metals or residues of prohibited substances, such as arsenic from feed, anti-odor compounds, genetically-modified digesters or prohibited synthetics from the bedding source. Note that European Union requirements are stricter than the NOP requirements in this regard, and specifically do not allow manure from confinement livestock operations.

Q.  Are there regulations on how I apply animal manure?
Yes. Manure is very closely regulated in organic systems, particularly for crops that are grown for human consumption. Raw animal manure may be applied to crops not for human consumption as long as it is applied in a manner that does not contaminate crops, soil or water. This may limit winter spreading. Your certifier may require a manure management plan as part of your certification application.  Manure that is composted following the NOS may be applied at any time to any crops. 
Raw manure may be applied to crops for human consumption only if:

- it is incorporated into the soil at least 120 days prior to the harvest of a product that comes into contact with the soil surface or soil particles, or
- it is incorporated into the soil at least 90 days prior to harvest of plants whose edible portion does not come into direct contact with the soil or soil particles.

Q. What are the rules for producing compost for use in my certified organic operation?
Rules for compost production are quite detailed. They are laid out in the National Organic Standards §205.203(c)(2). If compost is not produced in accordance with these rules, it must be viewed as raw manure.  To produce compost according to the NOS: an initial C:N ratio of between 25:1 and 40:1 must be established; a temperature of between 131º F and 170º F must be maintained for three days in a static, aerated pile, or between 131º F and 170º F for 15 days using a windrow composting system; during which materials must be turned at least five times.

Q.  Do the seeds I plant need to be organic? How about for a cover crop?
Organic seeds are required in all organic production, EXCEPT if the quantity, quality, form and/or variety of seeds desired are not available. If you do not use organic seed, you must keep records of your unsuccessful attempts to obtain organic seed. Higher price is NOT an acceptable reason to not buy organic seed.  Non-organic seeds must not be treated with non-allowed substances or genetically-modified inoculants.  Seeds must not be genetically modified.  Seeds for cover crop follow these same rules.  ATTRA and some certifying agencies can provide you with lists of seed companies that offer organic seed varieties. OMRI also has a seed source search function that can be very helpful. Organic seed is not required in the transition-to-organic years, untreated non-GMO seed can be used for crops and cover crops.  When it comes to buying seeds, there is a great resource in Missouri called Baker Creek Heirloom Seeds located near Mansfield.


Q.  Are treated seeds allowed?
Seeds may not be treated with non-allowed substances, including anything produced using GMOs. Examples of prohibited seed treatments are Apron and Captan. Legume inoculants are allowed if they are not genetically modified. Natural seed “treatments” such as clay for pelletizing small seeds like carrots are allowed, as long as there is documentation that only natural products are used in the treatment.

Q.  What are the rules for planting perennials, such as fruit trees, brambles or vines?
Producers must attempt to source organic planting stock, similar to attempts to source organic seeds. If not commercially available from organic sources, conventional planting stock may be used. Planting stock to be used to produce a perennial crop may be considered organically produced after it has been under a system of organic management for at least one year. The only exception to this is strawberries. If you manage strawberries as an annual crop, such as planting in the fall, harvesting the next spring and then tilling the plants in, resulting in only one harvest, then, in this case, you can use a non-organic strawberry plant if you cannot find organic plants. Strawberries harvested more than one year must be under organic management for a full year before selling organic fruit if you started
with non-organic plants.