NERC Compost Marketing Workshop. Compost and Potting Soils in Organic Production

Transcription

1 NERC Compost Marketing Workshop Friday, January 28, 2011 Sponsors Northeast Recycling Council, Inc. Northeast Organic Farming Association of NJ New Jersey Department of Environmental Protection Compost and Potting Soils in Organic Production Presented by: Erich V. Bremer Supervisor, Organic Certification Program

2 Topics Discussed: 1. General information on the NJDA Organic Certification Program 2. Explanation of which regulations govern organics in the US and the guidance documents concerning manure and composting. 6. Time disclaimer 3. Part 1: Compost / Composted Plant and Animal Materials 4. Part 2: Potting Soils & Materials Added to Compost and Potting Soils for use in Organic Systems 5. Wrap-Up 7. Questions

3 Contact Information for the NJDA Organic Certification Program Organic Certification Program New Jersey Department of Agriculture Division of Marketing and Development PO Box 330 (mail) 369 S. Warren Street (physical) Trenton, NJ (609) (voice) (609) (fax)

4 NJDA Organic Certification Program The NJDA is an "Accredited Certification Agent" The New Jersey Department of Agriculture is Accredited by the USDA to perform Organic Certifications for Crop, Livestock, Wild Crafting, and Organic Handling Operations as of April 12, 2007.

5 Organic certifications are based upon the USDA National Organic Program regulations officially titled: 7CFR Part 205, the National Organic Program; Final Rule We often abbreviate and just say "the Rule" Can be found online at

6 Additional NOP documents, aside from the Rule, are important when considering compost, potting soils, and manure for use in organic systems. The NOP has published guidance documents on: Compost and Vermicompost in Organic Crop Production (Doc # NOP 5021) The Use of Processed Animal Manures (Doc # NOP 5006) Allowance of Green Waste in Organic Production Systems (Doc # NOP 5016) (you can Google "NOP" and the number, and retrieve a link to each document)

7 Two of these guidance documents can be found in the new USDA Program Handbook: Guidance and Instructions For Accredited Certifying Agents & Certified Operations; Fall Edition Eventually all will be included in the handbook. The handbook can be found on-line at:

8 TIME DISCLAIMER! It is important to realize that regulations, such as the Rule, and interpretations of those regulations are constantly revised / adjusted. This presentation is being put together in the winter of 2011, and contains the most current information on the topics covered. Regulations, interpretations, and guidance documents can and will change over time, so it will be important to realize some of the documents discussed, and indeed some of the requirements, may change over time.

9 Part 1: Compost / Composted Plant and Animal Materials

10 Compost, a.k.a. decomposed plant and animal material, is an important tool for organic producers (farmers). The word "organic" in "organic agriculture" can be considered as describing the carbon sequestering that occurs through the careful management of soils in organic agriculture systems.

11 The Rule has specific requirements for the management and application of plant and animal materials. The soil fertility and crop nutrient practice standard is found at of the Rule. Part (a) requires growers to use tillage and cultivation practices that maintain or improve the physical, chemical, and biological condition of the soil.

12 Part (b) lets growers know that organic producers must use management techniques - such as crop rotations, cover cropping, and the application of "plant and animal materials" to manage crop nutrients and soil fertility. Part (c) then defines the appropriate plant and animal materials that can be utilized, and places restrictions on certain forms.

13 Soil fertility and crop nutrient management practice standard. (a) The producer must select and implement tillage and cultivation practices that maintain or improve the physical, chemical, and biological condition of soil and minimize soil erosion. (b) The producer must manage crop nutrients and soil fertility through rotations, cover crops, and the application of plant and animal materials.

14 Soil fertility and crop nutrient management practice standard cont' (c) The producer must manage plant and animal materials to maintain or improve soil organic matter content in a manner that does not contribute to contamination of crops, soil, or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances. Animal and plant materials include: (emphasis added by NJDA. This is what will be in mind during reviews of composts) (1) Raw animal manure, which must be composted unless it is: (i) Applied to land used for a crop not intended for human consumption; (ii) Incorporated into the soil not less than 120 days prior to the harvest of a product whose edible portion has direct contact with the soil surface or soil particles; or (iii) Incorporated into the soil not less than 90 days prior to the harvest of a product whose edible portion does not have direct contact with the soil surface or soil particles;

15 Soil fertility and crop nutrient management practice standard, cont': (2) Composted plant and animal materials produced though a process that: (i) Established an initial C:N ratio of between 25:1 and 40:1; and (ii) Maintained a temperature of between 131 F and 170 F for 3 days using an in-vessel or static aerated pile system; or (iii) Maintained a temperature of between 131 F and 170 F for 15 days using a windrow composting system, during which period, the materials must be turned a minimum of five times. (3) Uncomposted plant materials.

16 How will the NJDA evaluate the compost (and potting soils) your company makes so that NJDA certified organic growers can use for organic production? All materials used by organic growers must be documented as meeting the Rule requirements. Currently, there are three third party "organic materials reviewers" the NJDA Program recognizes. If the material has been reviewed and approved by the Organic Materials Review Institute (OMRI), the Washington State Department of Agriculture's Organic Materials Review Program (WSDA - is available on-line), or Pennsylvania Certified Organic (PCO), NJDA growers do not need additional documentation to use.

17 If not reviewed by one of these organizations, NJDA growers must have sufficient documentation to show compliance. The NJDA Organic Certification Program uses a Commercial Compost Production form that can be completed to document compliance. If companies wish to keep their information proprietary, they can submit information directly to the NJDA program and it will be kept confidential. We will discuss documentation in more detail under Part 2.

18 BACK TO THE RULE REQUIREMTNS: As written, the Rule requirements are quite restrictive. Until recent clarifications, if compost contained manure or other animal materials as feed stocks (to include mushroom soils), documentation that the C:N ratios, time (15 days), temperature (131 o F o F), and turning (5x if windrow) requirements were met were needed to determine compliance. If compost did not meet the requirements, the "days to harvest" restrictions had to be followed. This made using compost without days to harvest very difficult.

19 Negative comments from the public and interested parties ensued. The NOP advisory board, called the National Organic Standards Board (NOSB), convened two task forces that delivered comprehensive reports to the NOP on compost (2002) and compost tea (2004). The NOSB then made a final recommendation on compost, compost tea, processed manure, and vermicompost in November of 2006.

20 The NOP incorporated many of the NOSB recommendations to create a guidance on compost and vermicompost published in September of This guidance has some significant differences from the original Rule requirements. The document is still in the "draft" phase, and the public can provide comment to the NOP (end date was December 13, 2010, however, comments can always be sent to NOP). After reviewing comment, the NOP will release a final version that will become part of the new program handbook published by the NOP.

21 The new compost guidance does NOT specifically address compost teas; however, the NOSB recommendation for compost teas is included in the reference section of the guidance. The new compost guidance provides for additional methods to be used to create compliant compost, and places additional discretion into the control of the Accredited Certification Agent.

22 The Bottom Line: We will now discuss the requirements for various composts and for manure for use in organic systems as interpreted by the NJDA Organic Certification Program using the NOP Guidance For these examples we will assume the compost is to be used in organic production areas growing crops for human consumption.

23 The Bottom Line: (What the NJDA program will consider when reviewing commercial composts) 1. Composts with vegetative matter only: Will not have to meet time and temperature requirements in the Rule. Should still adhere to C:N ratios and be managed to ensure composting is effective at reducing weed seeds and pathogenic organisms. Composting procedures must be described in the Commercial Compost Production form - to include any and all feed stocks and materials added, and their source. Feed stocks and materials added will be scrutinized. For additional info see Allowance of Green Waste in Organic Production Systems (Doc # NOP 5016) 2. Composts with vegetative matter and livestock manure: Must adhere to C:N ratios, must document the three day minimum at temperature (minimum of F). Composting procedures must be described in the Commercial Compost Production form, to include information on duration, temperatures, and a description of the procedures used to ensure there are "practices used to achieve uniform elevated temperatures".

24 The Bottom Line: 3. Compost with "animal products" other than manure: *Other than manure includes offal, hides, feathers, bones, etc. Must be fully documented as meeting all the requirements in (c). Must document compliancy (in detail) within the Commercial Compost Production form, to include listing of any and all feed stocks and their sources, C:N ratios, approx. % of feed stock in the pile/system, temperature and turning records. Due to pathogen concerns, depending on the system and feed stock sources used, additional information may be needed to determine compliance, such as testing (pathogenic organisms, contaminates, stability, particle size, or other methods provided for in the NOP Guidance). It will not be easy to document this type of material. 4. For compost teas and vermicompost, the NJDA will use the NOSB recommendations to evaluate. 5. For processed animal manure, NOP 5006 guidance will be consulted.

25 Part 2: Potting Soils & Materials Added to Composts and Potting Soils for use in organic systems

26 Potting soils, like compost, must be documented as meeting all of the Rule requirements. In organic farming, certified growers can only use materials allowed by the regulations. Generally, most natural materials are allowed (natural = has not undergone a human-induced molecular change*), and most synthetic materials are prohibited. There are sections in the regulations that list exceptions to this generality. When grouped together, these "exception" sections comprise the "National List". Materials must be consistent with the National List to be used by certified growers. The two sections that impact crop production are: , Synthetic substances allowed for use in organic crop production, and , Nonsynthetic substances prohibited for use in organic crop production. * - perlite and vermiculite are two rare exceptions a certifier may make

27 Example: Peat moss is a natural material. Peat moss is NOT found listed in , Nonsynthetic substances prohibited for use in organic crop production, and so it may be used in organic production (potting soils used for organics). You will have to document the peat moss is only peat moss with no prohibited materials. Some materials may have restrictions listed that have to met to be used in organic systems. Sodium nitrate is a natural material; however, it has a restriction listed in : (g) Sodium nitrate unless use is restricted to no more than 20% of the crop's total nitrogen requirement; use in spirulina production is unrestricted until October 21, 2005.

28 The type and form of documentation necessary to document compliance varies depending upon the material and it's source. Mined materials, such as limestone, are easier to document and typically require a signed, dated letter / document from the company (mine) stating it is a naturally occurring mined material, which gives a brief description of the processing involved (such as "crushed / pulverized"), and a statement describing any and all other added materials (such as "no other materials added"). Other materials, such as extracted fish fertilizers, are much more difficult to document. In some cases, the NJDA program may not be able to evaluate a material (such as if it has a N rating above 3).

29 To evaluate a potting soil, the manufacturer will have to disclose a listing of all materials used, the source(s) of the materials, and a description of all processes used to make the potting soil product. If compost is used, a Commercial Compost Production Form must accompany the other documentation. The NJDA will evaluate the potting soil and render a decision if it meets the Rule requirements. If it does, NJDA growers can use without further documentation.

30 The NJDA will typically only review a material if a certified client or applicant asks the NJDA to do so. Locally made composts and potting soils are an exception, and the NJDA will accept requests from local / regional manufacturers. There is no charge to the client for a materials review. The NJDA can not be cited in advertisements or publications as an authority that has approved a specific material.

31 Other third party materials reviewers will likely charge a fee for review. Some, such as OMRI, publish their listings for use by the organic industry. OMRI has a "generic" list and a "Brand Name" list. Most certifiers subscribe to OMRI (and send copies of the lists to their certified clients). Some reviewers, like PCO, do not publish public lists, but make listings available to their certified clients and members. The NOP has recently requested the NOSB develop a recommendation that delineates the criteria that should be used by certifying agents and third party organizations to evaluate materials used in organic production and handling. Be mindful that the landscape may change based on these recommendations (some may stop third party review).

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33 WRAP UP: 1. Compost must be documented as compliant for certified organic growers to use. 2. Any and all materials used for organic production (such as potting soils) must be documented as compliant for certified organic growers to use. 3. The National List within the Rule governs what certified organic operations can use to produce and handle an organic product. 4. Third party review organizations, such as OMRI, can be utilized for compliance determinations, or disclosure can be made to the certifying agent.

34 Any Questions??