MOSES Organic Specialists are experienced organic farmers who can answer your questions about organic farming practices and organic certification.
Gardeners: Click here to find gardening help.
Farmers: If you don’t see an answer below, please submit your question.
Ask an Organic SpecialistAnswers
Get immediate help.
Organic Answer Line
888-551-4769 or 715-778-5775 (Staffed Monday-Friday from 8 a.m. to 5 p.m.)
A great place to start is the Farming dropdown on the main menu bar across the top of the page. Go on down to By Topic, where you can choose from Farming (in general), Field Crops, Livestock, Market Farming, Orchard, Season Extension, Soils & Systems. If your question fits in any one of these categories specifically, it’s a nice way to narrow down your search. Within each of these specific categories are links to a wide range of resources from a variety of sources, including MOSES Fact Sheets, an archive of MOSES Ask a Specialist answers to previously asked questions, latest research and articles from other sources like the USDA and SARE, and archived Organic Broadcaster articles.
For example, season extension is something we all think about as we ease into fall. It’s on my mind, so I wanted to see what I could learn from our website—I found a plethora of information! I started at the Farming dropdown on the main page, then clicked “By Topic” and chose the Season Extension link. From there I had the options of Resources, Research, Books, Funding, Suppliers and From the Organic Broadcaster. I also had the option of clicking on the Community Calendar button to look at various field days and events to see if any were focused on Season Extension information. I decided to begin with ordering a book that I could put on my winter reading list. I clicked on The Winter Harvest Handbook by Eliot Coleman, and the MOSES Online Store popped open, making it easy for me to purchase the book I wanted. I also saw that this book was in the “Season Extension” category. When I clicked on the category link,
I found more books plus several audio recordings from MOSES Conference workshops that covered growing in high tunnels.
Even if season extension might not be your burning issue, you can see what I mean about drilling down to find great resources on our website. If you don’t find answers for your specific topic, go over to the right side of the screen and click on the big question mark in the box that says “Questions about Organic Farming? Ask a Specialist.” This will direct you to the MOSES Organic Answer Line to call during business hours. If you’re on late night/early morning farmer hours, send a message by clicking the Ask an Organic Specialist button on that page. We’ll email or call you back with a response to your issue just as soon as we can.
At MOSES we strive to educate, inspire, and empower farmers to thrive in a sustainable, organic system of agriculture. We want to answer your questions, and support you in implementing those answers. Please take advantage of our website to ensure your organic farming success!
You must keep documentation that the seed planted during your transition meets these requirements as part of your application for organic certification. If you plant a corn seed treated with captan after two years of transitioning to organic, for instance, you must restart the 36-month clock on your transition, to the day you planted that seed on that field. If you are unsure if a seed treatment is allowed, ask MOSES, or the organic certification agency you are planning to use when you become certified for organic production.
If your operation is certified organic, you are required under the organic regulations to plant organic seed, unless you cannot find an “equivalent organically produced variety” in the form, quality or quantity that you want. For example, you may want organically approved clay-coated carrot seed for ease of planting, and it is not available on organic seed; or, you want 1000 pounds of bodacious sweet corn seed and you cannot find organic seed in that quantity; or, the germination rate for the organic barley you found is only 65%; or, you cannot find the specific variety of seed in an organic form that the buyer of your crop wants you to grow. In all of these cases, you can use non-organic seed. It cannot have prohibited seed treatments, as described above.
Note that the rule requires you to seek out an “equivalent” variety. If you are new to organic and are unsure whether the organic seed varieties are equivalent to the familiar non-organic varieties you are used to growing, you should trial out organic varieties with similar characteristics at the same time as planting your untreated non-organic seed, to see if you can find one to your liking. Higher price is NOT an acceptable reason to avoid planting organic seed.
Organic seed is an investment in our future as organic producers. Since organic seed is produced under organic management, and the seed breeders are specifically working to provide characteristics that organic crop producers need, it makes sense to purchase from these companies and support their efforts. For example, organic corn producers cannot plant in cold ground in the early spring, since their seed is not treated with fungicides. Therefore, they want a seed that will germinate quickly as well as canopy thick and early to help with weed control in their organic fields. Organic seed breeders work to have crops that respond well to natural, slower release forms of fertility inputs, whereas nonorganic corn seed breeders don’t do this.
The place to start your search is the MOSES website: mosesorganic.org/find-a-farm. Here are a few of the resources listed there:
The USDA maintains a national list of certified organic operations under “List of Certified Operations” at apps.ams.usda.gov/nop). You can search by state, products, and many other parameters. This is the only list that has certified farms all in one place. Every certification agency also has a list of their certified operations on their website, but since multiple certifiers operate in many areas of the country, it is difficult to determine the total number of certified operations in a state by searching these lists.
The USDA ERS also maintains a useful webpage with links to national and state organic production information. See www.ers.usda.gov/data-products/organic-production.aspx.
You can find a lot of information about organic production, including state and county data, from the last Farm Census (2012). See www.agcensus.usda.gov/Publications/2012.
The University of Wisconsin did a report in 2012 that has specific data for the state, including a map with the locations of organic farms and processors. It’s online at www.cias.wisc.edu/wp-content/uploads/2012/02/org12finalnewlowres021612.pdf.
The Minnesota Department of Agriculture also has a good webpage dedicated to organic agriculture in that state. See www.mda.state.mn.us/organic.
The standards used by all organic certification agencies are the same USDA organic regulations. Agencies compete for your business based on service and price. The research you do now to choose a certification agency that is a good match for your farm will hold you in good stead for years to come.
You can switch agencies if you are unhappy with the service. However, certifiers usually have an extra fee for a first time application. If you move from agency to agency, you will pay this fee more than once. It is easier and less expensive to stay with one certification agency that gets to know your operation.
To help you find the best agency to handle your certification, start by talking to other organic farmers about their experience with their agencies. The organic farmer community is an invaluable resource in many ways, but especially as you work to establish and develop the very important relationship with your organic certifier.
Ask how long the farmers had to wait for the inspection to occur, their application to be reviewed, and their yearly certificate to be issued. This certification timeline tells you when you can expect to be able to sell your products for the organic price.
Are the agency’s policies, sample forms and templates easy to understand and use? Good record-keeping is an important piece of responsible farming and organic certification. It’s essential that the agency’s policies and templates are accessible and easy for the farmer to use.
Does the agency offer educational activities or field days, and a newsletter? After you talk with the organic farmers in your community, talk to the potential buyers of your organic products. If your buyer has a certification agency preference, you could consider being certified by that agency. If the buyer wants your organic product to be approved for sale to foreign countries, you should verify that your chosen certification agency is knowledgeable of these special certification requirements.
Finally, call a few agencies to compare their fees and timelines for processing your certification. Our online Upper Midwest Organic Resource Directory lists contact information for certification agencies—choose “Certification Agencies” in the dropdown beside Category Name. The directory also is available in a spiral-bound book; call 715-778-5775 to request a print copy.
Some agencies charge a flat fee plus a surcharge based on the dollar value of your yearly organic sales. Others have a sliding scale dependent on your anticipated organic sales, or on the amount of acreage of various commodities. In addition, some charge a fee to review each purchased crop or animal production input (fertilizers, animal health materials, feed supplements, pest control products, etc.). There may be an extra “membership” fee or “administrative” fee. Make sure you have a clear understanding of all the potential costs so you can make an informed decision. Keep in mind that you get what you pay for. If you want a responsive and helpful certifier, you may need to pay more since it costs money to have trained people on staff to take your call.
Find out if the agency certifies other farms in your region. The cost of certification typically is shared between many producers in a region. It makes sense to share expenses for the inspector’s mileage, food, and lodging with other area farmers, rather than having to carry the financial burden of these costs on your own. Also ask if the agency certifies other operations similar in scope to yours. The agency you choose should be familiar with your type of production—dairy, vegetables, sheep, grapes, nut trees, maple syrup, food processing—so your certification goes smoothly.
Your organic system plan (OSP) organic certification application includes the locations that various practices and inputs are used on your farm. Your organic certification agency uses your written plan as well as your yearly on-site annual inspection to verify your farming operation meets the requirements of the organic regulation. Field maps, as well as maps that illustrate the location of all livestock housing, feed storage, crop storage, greenhouse or high tunnel production, input storage, other buildings and production facilities which are integral to your farming operation should be provided as part of your OSP.
For field maps, the USDA Farm Service Agency (FSA), can provide easy-to-read aerial maps for each of the farm fields that you own or lease for agricultural production. FSA offices are in every county or region. You can find the one nearest you by going online to offices.sc.egov.usda.gov/locator/app. All fields under your management should be present, even if you do not sell organic crops or pasture organic animals on some of those fields.
You could also use internet websites such as Google Earth (www.googleearth.com), or www.websoilsurvey.nrcs.usda.gov to get aerial photographs of your homestead, fields and pastures. Hand-drawn maps are acceptable, as long as they are drawn to scale. Many times it is easier to use a wider aerial view photograph as a map of your fields, and a hand-drawn map of your homestead to illustrate livestock housing and crop storage.
While it is not a mandate, it is useful to note items such as thick stands of trees in the fencerows, streams or roads that act as buffer zones between your land and adjoining land where prohibited materials are used. Describing the features of the buffer zones on the maps helps both you and the certifying agent determine if a buffer zone where no organic crops can be harvested is necessary, or if it is of sufficient size and type to prevent drift or runoff of materials that are prohibited in organic production.
You can also note which land adjoining your organic fields are managed by non-organic farmers. If you have an adjoining land-use affidavit from a neighbor stating they do not use any prohibited materials on their pastures (for instance), you could note that neighbor’s name on the map. This would help the certification agency understand which field borders are covered by which adjoining land-use affidavit.
Note all locations of grain and forage storage, and if you have both organic and non-organic (includes transitional) storage on the farm, note which types of storage they are on the map using a number, letter or other designation. If you are renting cropland or storage away from your home farm, note the street address or nearby road junctions on the map, as a way to aid the certification agency in understanding where these parcels are located.
If you are rotationally grazing using permanent paddocks, you could note each paddock on the map, or at least note which larger pasture field contains which paddocks. If you are using moveable fencing, you do not need to draw in these temporary fence lines on the map. Even if you are not selling your livestock as organic, if you have pasture on your farm, it should be noted. Locations where livestock have access to surface waters and other watering areas could also be noted.
Each farm field, pasture, and storage location should have a designation, such as a number, letter or name, with a corresponding field history or storage record. These designations should be present on both the map and your other documentation. Vegetable growers should note locations and names of permanent structures such as unheated high tunnels or heated greenhouses, cold frames and packing sheds or outdoor produce post-harvest areas. For those with great diversity in their fields, tracking which crops are grown by row or bed from year to year on a map can double as both an illustration of where the crops are grown as well as a field history of your crop rotation and the corresponding input or manure applications used on each crop. Areas where irrigation may be drawing from surface waters should on the map.
Making sure that all necessary areas are noted on clear maps, along with the corresponding descriptive information in your OSP, will help your certifier’s initial review of your application and your annual organic inspection go quicker, with less questions and confusion.
I am considering organic certification, but I am concerned that the recordkeeping will be too difficult. Any suggestions?
In my many years of organic inspection, the most profitable and productive organic farmers were those who also kept good records. The documentation you keep need not be burdensome, and should be considered part of running your operation. The historical reference these records provide is one of the most valuable management tools on your farm, helping you repeat successes and avoid repeating costly errors.
Your records will give you answers to questions such as: Which crop rotation results in lowered weed or plant disease pressure? Can you see a production increase where you purchased and applied an expensive fertility input? Which seed varieties did best in your soils and climate? Did you over produce a specific crop and not have enough of another?
For vegetable growers, keeping track of the timing of succession plantings and their harvest dates is very useful. By keeping track of your activities, inputs, harvests and sales, you will be able to have this information at your fingertips when making decisions year to year.
You are not required to keep records in a specific way. You can use a calendar by the door, a spiral book in your pickup truck, or your smart phone. The documentation must be easily understood by your organic inspector, though. So if you use code words, tell the inspector what they mean.
The records need not be excessively detailed. Every time you feed a bale of hay, you do not need to write that down. You should document how much hay you make and have on hand in the fall, and periodically take an inventory so you can track how much you are feeding. This way, if you need to buy more organic hay, you can plan ahead and probably get a better price now rather than waiting until early spring when the availability and market is tighter. This will also help the organic inspector track that you have sufficient organic forage for your organic livestock.
For items you purchase, make sure they are approved by your organic certification agency before you buy and apply them. Keep labels and invoices for all inputs and seeds as a useful reference for the future. They also happen to be part of the organic audit trail.
There are numerous computer programs you can search for on the internet to help you with your recordkeeping. ATTRA (attra.ncat.org) has recordkeeping forms on their website and many organic certification agencies also provide templates to help you with maintaining your activities and inputs from year to year.
I know I am supposed to plant organic seeds if I sell my crop production as organic. How do I accomplish this?
The National Organic Program (NOP) mandates the use of organic seed for crops that will be sold as organic unless you can show that you could not find the quality, quantity or equivalent variety of seed you wanted to plant. Under no circumstance can seeds treated with GMO nitrogen-fixing bacteria or non-approved synthetic fungicides or insecticides be used when you sell your crop in the marketplace as organic. This rule also applies to producers who sell less than $5,000 in organically labeled products, making them exempt from organic certification (but not from following organic standards). If prohibited materials are used on the seed, or a GMO seed is planted, the land cannot be used for organic production for three years.
More and more seed companies are developing organic seed varieties that function well in organic systems to meet the demand of the organic marketplace. By supporting organic seed suppliers, you encourage further research and development of organic seeds that compete well with weeds, grow vigorously with slow-release fertility inputs and are resistant to disease and pests. Also, certified organic seed would never have prohibited seed treatments.
An excellent resource for finding organic seed of all types is the website www.organicseedfinder.com. Field crops, vegetables, fruits, herbs and flower sources are all listed. This website is also helpful for finding seed suppliers that would be the most likely to carry organic seed varieties.
A broader list of organic seed suppliers is in the Upper Midwest Organic Resource Directory. The “Seed Suppliers” section lists not only suppliers of seed, but also farms that supply seed potatoes or grow crops for seed. The directory also is available in print. You may request a copy by calling the MOSES office at 715-778-5775.
If the specific variety of seed you want is not available, you are required to purchase organic seed of an equivalent variety. If you are unsure if the organic variety is similar or equivalent, consider purchasing some organic seed and trialing out new organic varieties to see if they do as well as the non-organic seed that you are used to growing. Remember, the NOP does not consider price to be a valid reason not to purchase organic seed.
If you plant untreated non-organic seed, you will need to document why your search for organic seed was unsuccessful—quantity, quality, and variety are all valid reasons for buying non-organic seed. For example, the organic seed only came in one-ounce packets and you wanted to purchase 20 pounds (quantity). Or, the organic seed germination rate was only 20%, and the non-organic seed had a germination rate of 95% (quality). Or, you wanted to grow an orange oxheart tomato, and could not find it from at least three sources that typically sell organic seed (variety). Searching at your local garden center which does not typically sell organic seed is not considered a viable organic seed search by most certification agencies. You should be trying to find organic seed from the many suppliers that offer it. Even a search on the Internet for organic seed varieties can be fruitful.
Organic seed can be in short supply. It is a good idea to start your organic seed searches in winter and not wait until late spring when they often are sold out.
I have the opportunity to rent some pasture from my neighbor who hasn't used it in many years. What do I need to do to get this certified, and what is the best way to start pasturing organically?
Make sure that prohibited substances have not been used for at least three years. It is not uncommon to find that the owner may have spot treated weeds or applied manure. If herbicides have been used, it will take a full three-year transition from the last application date before the land can be certified. Conventional manure is allowed, but be sure that the manure and bedding source does not contain prohibited materials like recycled lumber waste, has not been treated with herbicides or insecticides or had chemical treatments to control odor or nutrient loss. Ask a lot of questions to be sure there are no surprises.
A soil test should be a top priority. Fallow land may or may not be fertile. The soil type and previous land use have a large impact on the quality of the soil. Large fields may even have multiple soil types and can vary in fertility from location to location. It is extremely rare to find a soil that isn’t lacking in some nutrients, and may even have an overabundance of others. The soil test can help you plan for the right fertilizer applications.
In general, fallow land tends to need renovation: fertility amendments and, often, reseeding for improved forage quality. Fallow land tends to revert to lower quality grasses over time. So you should also take an assessment of the plant population and type. You can request an assessment and assistance with a grazing plan from the Natural Resources Conservation Service, (NRCS) which will have a grazing specialist available for consultations. If you look in the blue pages (government pages) of your phone book, you can find your county NRCS office. The grazing specialist can help you assess your pasture quality, help you design a fencing and paddock layout and can determine ideal stocking rates. The NRCS also has programs providing cost share for some of these improvements, if you have a long-term lease on this pastureland.
Pastures, too, can revert to low-quality grasses and plants will need to be renovated. Ideally you want a mixture of cool and warm season grasses and a mix of legumes and other broadleaf plants to provide a resilient mix of forages throughout the growing season and changing climatic conditions. Legumes can sometimes be seeded into existing pastures by broadcasting them at the right time of year, typically late winter. If the thatch (root mass and decaying materials) is very thick, you may need to use a no-till seed drill to open up the soil enough for the new seed to make contact. These drills can sometimes be rented through local grazing groups. Good fertility, the right plant population and a good rotational paddock design are the keys to getting good production on your new pasture. Make sure you follow all requirements for your seed, such as planting organic seed or using seed that does not contain any prohibited treatments or inoculants.
Fencing that is already in place can be used even if the posts had been treated with prohibited materials, although your certifier may require an interior fence to prevent grazing right next to these posts. Any new fencing must comply with organic standards and cannot contain these prohibited materials.
205.206 (f) The producer must not use lumber treated with arsenate or other prohibited materials for new installations or replacement purposes in contact with soil or livestock.
Natural wood, metal posts, and concrete posts are allowed. AC2 copper-treated posts are allowed with restrictions such as having a buffer in place between the posts and organic grazing land.
Check with your certifier for details about fencing.
Buffer zones are required along any pasture that borders conventional fields. A 25-30 foot buffer, which cannot be grazed or harvested for organic use, will help prevent contamination from neighboring conventional fields. In most cases, an interior electric or similar fence will be adequate. The buffer zone can be harvested mechanically, or by grazing non-organic livestock such as horses, it cannot be sold or used as organic.
Dairy farmers who want to ship organic milk and apply for first time organic certification during the winter months may need to have two inspections in one year. The first would be to review livestock activities and growing systems during the winter, and the second to actually view crops and pasture during the growing season in the summer.
Meat producers might need to purchase organic forages and grains this coming winter or spring in order to produce or sell organic animals next year. Brood animals must consume certified organic feed while they are in the last third of gestation in order for the offspring to be sold as organic meat animals. There cannot be retroactive organic certification for a previous year’s hay or grains, since they were not physically inspected while they were growing.
The ability to get certified this year also depends upon the certification agency’s workload and the inspector schedule. Most certification agencies can handle a limited number of “rush” applications. However, if the timeline is too short, or if the agency is already at capacity, it may be too late. In general, even a rush application will take a month to process from the time you submit your application to the date you receive your organic certificate. The initial review, the inspection and the final review are all required, and while they can be prioritized, they still take time and effort to be done correctly. A simple operation with only a few crops stands a better chance of getting a late season rush done than does a complicated farm with several crops, livestock and crops, or farms with processing facilities.
Ultimately, only the certification agency can tell you if you can obtain a late season organic certificate. Call your potential certification agencies immediately, explain your situation, and find out what your options might be.
My neighbor sprayed some sort of pesticide today. I could smell it, and got a little dizzy and had a dry mouth. My crops in the adjoining field were just coming up, so I am not sure if they were damaged. The neighbor is not willing to tell me what he sprayed. What can I do, and will this affect my organic certification?
If you can smell the pesticide, it has drifted to your farm. If you are not feeling well, immediately see your family doctor or go to the emergency room. Pesticide exposure should not be taken lightly.
The second thing you should do is contact your state’s pesticide enforcement agency—it’s usually within your state’s department of agriculture. Call the agency as soon as possible, ideally within 48 hours of the incident. The agency will send out an investigator to verify the drift incident, usually by the next day unless it is a weekend. Because it is difficult to find pesticide residue on soil or crops after a few days, you can help the investigator verify drift if you can locate a hard surface (such as a vehicle) where droplets of drift are collecting. Then protect that surface from rain until the investigator arrives.
All licensed applicators are supposed to keep written records of what and when they spray. When you contact your state’s pesticide enforcement agency, staff will contact your neighbor to find out what was sprayed, and they can then let you know what it was. They will also review if the pesticide was applied correctly, such as when wind speed was not excessive. To my knowledge, all states have some rules governing drift, and most states consider it a violation of the law if pesticides cross a property line without the permission of that landowner.
If the agency finds that the product drifted, and/or that the applicator sprayed when conditions weren’t right, and/or he did not document his activities, and/or he were supposed to be licensed to apply the product and he wasn’t, there is a pretty good chance the applicator will be fined. The amount of fines varies widely. These fines go to the state. If you want monetary compensation, you will need to discuss this with the farm operator, their insurance agency or, depending on the circumstances, other responsible parties including the custom applicator or landowner. If these negotiations are not acceptable, you may need to take legal action.
If you became sick or your crops were damaged, and you hope to get monetary compensation for crop loss or medical bills, it is very important to have an objective third party verify the drift incident. Doctors don’t usually attribute illnesses to pesticide exposure. However, if you have proof that you had a negative health incident right after exposure, it is easier to claim you have a problem than if you did not go to the doctor at the time of your exposure.
Certification agencies vary in how they deal with pesticide drift. Some may only decertify that year’s crop within the drifted area, requiring a 25-30 foot buffer zone from the end of the drift to the crop you can continue to sell as organic. The drift investigator may help you establish where the edge of the drift incident is in your field. If the drift was highly concentrated, the organic certifier may decertify that land for two or three years.
Many producers do not want the incident to create hard feelings with their neighbors. To avoid drift incidents, talk to your neighbors early in the season to explain the organic status of your land and the economic loss you will incur if prohibited substances drift over the property line. Most farmers will respect another farmer’s farming system. Drift is especially problematic on vegetable and fruit crops, which often grow on just a few acres. Even if you only farm 5 acres, you are still a farmer and have a right to farm as you wish.
Many landowners have leased out their land to a farmer and that farmer may hire someone else to spray. Figuring out who is responsible for that activity early in the season can save you valuable time if and when you wish to discuss a drift incident with the person who did the application. The landowner may not know who is doing the spraying, nor what is being sprayed. The farmer renting the land might not even know exactly what the applicator is using until presented with the bill.
When drift occurs, it is important to report the incident to the state so their statistics on pesticide drift incidents and possible negative human health effects reflect what is happening in the real world. When incidents are not reported, it appears that there are no problems, and unfortunately, we all know that is not true.
Your organic documentation is invaluable if you are requesting monetary compensation for your loss of organic premium or if you could not sell your crop for a variety of reasons. Most insurance companies do not seem to know that there is a rigorous third-party review within the organic certification process. The fact that your yield and sales records are verified yearly by an objective third party, who is approved by the USDA to perform this work, adds credibility to the dollar amount you may be requesting. Since some organic crops have very large differences between the organic and non-organic price, you will probably get some pushback from the responsible party or the insurance agency when you first present your request for compensation.
For example, some specialty organic potatoes could be sold for $2 per pound, and conventional potatoes at times sell for 10 cents per pound. Be prepared to have many conversations and letters with the responsible party or insurance company. You will probably need to compromise on your requested compensation, but do not give up! Other organic farmers before you have received compensation. You can get a reasonable settlement if you stick to the facts and remain steadfast even when they do not seem to accept the credibility of your request.
The Pesticide Action Network of North America, PANNA, has an excellent website with links to each state’s pesticide enforcement bureau and the state’s pesticide-use rules. See www.panna.org/subscience/if-youve-been-drifted. PANNA’s Midwest office is located in Minneapolis. The phone number is 510-788-9020.
If you sell bulk products with no retail label, you probably don’t need to go through the expense and time of registering a trademark–this is especially true if your farm name includes your family name, such as Smith Family Dairy or Johnson Farms.
The first step in getting a trademark for your farm name is to register the name with your home state and surrounding states if you plan to do business there. For many farms, this step provides enough protection and a national trademark is not necessary—you’ll need to assess your own risk to determine if state registries are sufficient.
To find a state registry, search the Internet for “trademark registry [state name].” These registry websites have a search feature that lets you enter the name you want to trademark to see if someone else has already registered that name in that state. If the name is available, you can follow the instructions on the website to register your farm name. The cost to do this can range from $15 to $100, depending on the state. Registering your farm name this way gives you legal protection to challenge others who try to use the same name. It does not guarantee that someone would not use your name outside of the registry system.
To obtain broader legal protection for your farm name, you would need to trademark it on the national level. Start by searching for your farm name in the Trademark Electronic Search System (TESS) at www.uspto.gov/trademarks. In fact, it’s worth your time to conduct a search even if you’re only going to enter your name in state registries. You could run into trouble, as I have, if you use a trademarked name even locally.
I have used my farm’s name for more than 20 years without a trademark or state registry. I recently received a “cease and desist” order from a company in California who had federally trademarked “Sweet Earth” 25 years ago in numerous food categories, including fresh produce. I am now in the midst of changing my farm’s name, a difficult and time-consuming process, but better than a lawsuit that I would lose if I tried to keep my farm’s name.
Obtaining your own national trademark involves a lot of searching, documentation and time. You can go through numerous confusing steps on the national trademark website and do it yourself, but I recommend hiring a lawyer that specializes in trademarks. The cost to hire a trademark lawyer to set up a national trademark will be $1,000 or more.
Once your name is trademarked, you must maintain that trademark by periodically informing the state or federal agency that it is still in use. This might be every three, five or ten years depending on the agency. Typically, there is not a fee for renewal of trademarks, but that might change.
Take time to think about potential future endeavors involving your farm name. If you decide you’ll market products under your farm name, do a thorough trademark search and register that name. Consider getting a trademark for your logo at the same time—it can save you time and money to do both trademark searches and applications together.
At farmers’ markets, where these exempt-from-certification growers often sell products, labeling can become an issue. It is unfair to producers who go through the strict requirements to achieve organic certification to see the label misused. In many cases, misuse is a result of ignorance, not malice. But, it can cause bad feelings between growers at a market, and impact a market’s reputation if patrons see “organic” being used loosely.
To ensure that vendors at a farmers’ market are using “organic” correctly, managers can ask them to sign a statement that they have followed organic rules. This not only makes vendors aware of the standards they must meet, but also satisfies certified organic farmers that their market neighbors are meeting the same strict rules.
The statement below covers many of the requirements that a smaller scale grower or livestock producer must meet in order to sell organically labeled products as a noncertified (“exempt”) organic farmer. It provides information on what practices and inputs are allowed in order to use the organic label, and can be a valuable educational tool.
Farmers’ market managers should feel free to modify this statement and have it reviewed by their own legal counsel. This type of statement should be updated each year to keep current with changes to organic regulations.
NOTE: Anyone may file an anonymous complaint at NOPcompliance@usda.gov to report someone who is making an organic claim who is not certified or exempt from certification requirements.
Statement for exempt-from-organic-certification producers to use the word “organic”
I am a producer that is not certified organic, but I use the word “organic” to describe my products or practices in the marketplace. The list below describes many of the requirements in the organic law that I follow in order to use the word “organic.” I have read and follow the full U.S. organic regulation, which is located at www.ams.usda.gov/nop.
I affirm that:
1. I sell less than $5,000 annually in organically labeled products.
2. I have not planted any seeds that had synthetic treatments, such as fungicides or insecticides.
3. I have planted all organic seeds if they were available in the variety and quantity I required.
4. I have either grown transplants myself using only OMRI* or organic certifier organically approved potting mixes and other inputs or I have purchased certified organic transplants.
5. I have only applied fertility, pest, disease and weed management inputs that have either been approved by OMRI or by an organic certification agency. I understand that there are numerous agricultural input products that make organic claims that are untrue and I have gone the extra step to verify what I am using meets the organic law.
6. I have implemented a soil building rotation on my farm, where annual crops of the same type are not grown in succession in the same field. I also use plant and livestock based materials such as cover crops and compost to continually improve my soils.
7. I have not applied manure to my fields growing crops for human consumption any sooner than 90 days before harvest for crops that are not in contact with soil (i.e. sweet corn), or 120 days before harvest for crops that are in contact with soil (root crops, tomatoes, peppers etc.).
8. I have documentation that compost containing livestock originated components used on my farm meets the requirement of having a Carbon to Nitrogen ratio of between 25 to 1 and 40 to 1, has had a temperature maintained of 131 to 170 degrees F for 15 days and has been turned 5 times, or if in a static vessel, had this temperature maintained for 3 days.
9. All mammalian livestock has been managed organically from the last third of gestation of their mother to the day of slaughter. All poultry has been managed organically from the second day of life. Organic management includes 100% certified organic feed.
10. All livestock has had access to the outdoors, with ruminants receiving 30% of their nutrition from pasture during a minimum 120 day grazing season. All animal health products and feed supplements have either been OMRI approved or approved by an organic certification agency.
11. I have maintained documentation that verifies what I have stated above.
*OMRI=Organic Materials Review Institute (www.omri.org)
I think that I am renting out my cropland for too little money. What is the going rental rate for organic cropland?
People often think that because land is certifiable as organic, and because the organic premium is higher than conventional prices, that organic cropland can command higher rental rates. This is definitely not true. Organic farmers are usually not willing to pay any more than the going rate for similar conventional cropland —nor should they, for a number of reasons.
Conventional farmers can focus only on the two most profitable crops: corn and soybeans. The advent of GMO, glyphosate-tolerant crops has allowed the two-crop rotation to become the norm. Spray for weeds, spray for pests, add synthetic fertilizer as needed and, as long as you have insurance to cover disaster and subsidies to cover low pricing, you have a “can’t-fail” system that is driving rental and land prices to historic highs.
Organic farmers cannot, by law, continually plant row crops year after year. They must use farming practices that protect and build soil. So they have more complex crop rotations that include cover crops, small grains and forages. They also cannot use the time- and labor-saving herbicides and pesticides. So they must have a much more long-term approach to build soil and control pests. It is not uncommon to see five- to seven-year rotations in organic row crop systems. Organic small grains and forages do not command the same premiums as corn and soybeans. Knowing that, organic farmers are unwilling to pay more than the going rate for rental land, and they usually want longer rental contracts to reap the results of soil building.
Organic farmers, also by law, have to protect the natural resources of the land they farm. The fence row to fence row, put-everything-under-cultivation approach of conventional row crop farmers may make perverse sense economically, but it has been a disaster for our natural re-sources. An estimated eight million new acres of previously unfarmed land, much of it sensitive wetland or previously conserved acreage, has gone under cultivation, mostly to conventional production, over the past five years due to the insatiable quest for more cropland.
Organic farmers must protect wetlands, streams and natural areas by rule, and because having diversity actually helps protect against disease and pest outbreaks. Landowners need to take into account long-term goals for their land, and not just consider the highest possible rental price when considering with whom to rent their land. If bulldozing down trees, ripping out fencerows, tearing out contour strips and terraces, filling in wetlands, spraying it all with glyphosate, and dousing it with anhydrous ammonia sounds incompatible with your land use vision, you should take that into account when negotiating rental rates with organic farmers.
Cropland rental rates vary considerably from region to region. Soil quality and land quantity are the main factors to consider. Marginal land that needs a lot of inputs to be productive will be on the low end, while larger acreages of high quality soil will command the highest rates. Rental rates may be as low as $125 and up to $250 or more per acre for the most desirable cropland. The best way to determine local rates is to talk with your county’s University Agricultural Extension Agent. They are usually familiar with the going rates in your area. Getting a soil test and understanding the results can help when negotiating rental rates.
It pays to talk with potential renters about their management practices. Ask them about their crop rotation plan, pest and weed control, their soil-building practices, and how they plan to prevent erosion and protect sensitive natural areas. Organic farmers should be able to explain their management practices. Landowners who care about the stewardship of their land should and will make their rental decision on more than maximizing rental rates.
For more information about organic contracts and rental agreements, see the the Farmers’ Legal Action Group (FLAG) website at www.flaginc.org/publication/farmers-guide-to-organic-contracts.
Organic farming is more than a season of putting seeds in the ground and harvesting the plants. It is a farming system that integrates cultural, biological, and mechanical practices to foster cycling of resources, promote ecological balance, and conserve biodiversity. As such, renting land to an organic farmer has advantages that come from improvements to your land. It requires more than just a lease. It’s a conversation between landowner and farmer, and an agreement based on a few shared understandings. Below are a few things to think about while coming to an agreement.
The price of leasing organic land, like any other farmland, depends first on the quality of the land. Is it rich bottom land, or rocky or sandy terrain? Whether or not it is managed using organic production methods, land has inherent qualities that make it easier to farm, and more valuable as such. This year, even with commodity prices dropping, land prices have remained relatively stable. However, there are other variables that factor into acreage cost. For example, if your land has been fallow for years, it’s likely the organic farmer would need to add soil nutrients and tillage to get the soil ready for planting crops. Organic pastures can be a good option for previously fallow land, but only with good and diverse forage, fencing and water in place to give the land value as pasture. Additionally, it’s very important to test the soil and have it evaluated by a professional consultant so you both know what it holds to begin with.
Organic farmers will want to rent the land for a longer term because they will need to plant a five-to seven-year rotation to build up the soil and grow a cash crop. The farmer and landowner should discuss if the price will fluctuate between when they are growing higher value crops like corn and beans and years they are soil-building by growing small grains and hay. The rental fee could be an average of these numbers and have the same fee each year, or the lease could reflect the crop rotation plan and be less during the lower crop value years.
Ultimately, the price you’ll receive comes down to a shared agreement between you and farmer, taking into account the benefits to your land from the conservation and soil-building practices of organic land use, lease term, and value of farmland. If you have good farmland that is ready to be certified as organic you might get 5-10% more than the average per acre fee in the county, but only if the above outlined variables are in your favor. Local extension agents are a great resource to use in finding out the price of cropland rental in their counties, and would be able to give an approximate dollar range for each county. Once all of these factors are determined, a lease can be drawn and upheld that meets the needs of the farmer and the organic landowner.
For more information about writing this type of lease, see the MOSES fact sheet “How to Write a Conservation-Focused Land Rental Agreement.”
I would like to purchase an older sprayer that had been used with prohibited synthetic materials. Can I do this and use this sprayer to apply products approved for organic production?
Yes, you can purchase and use this sprayer. However, you will need to perform some cleaning and refurbishment activities and document these before you may use it on organic land.
Most certifiers recommend a clear water rinse first. Completely fill the tank and spray it until empty on non-organic land. Second, fill the tank again with diluted household ammonia, such as one quart of ammonia per 125 gallons. Run this through the sprayer again on non-organic land. Perform another clear water rinse as above. If you continue to smell the residues of the prohibited chemicals, do another ammonia and clear water rinse again. Poly tanks are porous so you may need to repeat this procedure a few times.
Replace all rubber parts including hoses, washers, and nozzles with new ones, as these are very difficult to clean completely.
Many certifiers require that once you have converted this piece of equipment from non-organic to organic production, you can no longer use it for spraying prohibited materials. In other words, if you are sharing this piece of equipment with a non-organic farmer, or you manage split production on your own farm, you may need to dedicate this sprayer, once cleaned, to organic and not go back and forth between organic and non-organic use, even if you perform this cleaning activity each time. Check with your certification agency on its policy for sprayer use to see if it mandates dedication to organic.
There are a couple different cost share options for organic farmers across the country to help reduce the burden of certification fees. The most widely available is the National Organic Certification Cost Share Program (NOCCSP). It’s available to all certified organic producers and handlers in the United States, as well as several territories and commonwealths. Certain states also have access to Agricultural Management Assistance (AMA) Organic Certification Cost Share Program funds for producers. Only certified organic operations are eligible for these programs. To access them, contact your certification agency or state Department of Agriculture for the application.
These programs use a reimbursement model. Your organic operation will need to cover the costs up front and get a paid invoice from the certifying agency. Then, complete and submit all the required application components including a copy of your current organic certificate and the invoice(s) of certification costs paid during the federal fiscal year (Oct. 1 to Sept. 30). Organic operations can receive support for up to 75% of certification costs, but are capped at $750 per year by certification scope (livestock, crops, wild harvest, and handling).
Beyond those programs, some regions offer other opportunities. For example, Minnesota has a “Transition to Organic Cost Share Program” that supports state residents who are not currently certified, but are actively transitioning into certification. These funds will pay for up to 75% of eligible costs with a total annual cap of $750. ‘Eligible costs’ consist of charges for on-farm inspector visits, soil tests, and registration fees for up to two people to attend certain educational conferences, including the MOSES Organic Farming Conference and other organic conferences in the Midwest. It’s important to note that pre-certification inspections are not required in order to attain certification and are not offered by all certifying agencies, but can be a valuable learning tool.
There are also many broader avenues to gaining financial support for your organic endeavors. Local food co-ops or non-profits may have funds to assist farmers or processors – often managed through grants. Widening your scope may reveal opportunities through your county or Natural Resource Conservation Service (USDA-NRCS) grants, Fish & Wildlife partnerships, and other programs that support conservation, natural resources, and wildlife habitat. While they usually won’t cover certification costs, they may help you implement practices that are valuable to your farm operation and help you meet the requirements of certification. For example, they may help you purchase cover crop seed or mobile fencing or offer incentives for conservation practices. For those transitioning into organic, NRCS Practice Standard 138: “Conservation Activity Plan for the Transition to Organic Production” may offer professional help to identify conservation concerns and organic requirements to address on your land. Look for more opportunities on the “Funds for Farmers” page of the MOSES website.
Contact your state’s Department of Agriculture for more information about the NOCCSP and AMA Organic Certification Cost Share programs or other regional initiatives. Your certifier is also a valuable asset and may be aware of additional prospects. For insight into local opportunities, ask around your farming neighborhood, your buyers, and any farm or food organizations you may know.
For more about these programs and how to apply, see ams.usda.gov/services/grants/occsp.
I read a news story recently that said organic produce isn't pesticide-free. Please explain this so I have information to share with my customers.
“The U.S. Environmental Protection Agency (EPA) establishes the maximum allowed levels of pesticides, or EPA tolerances, which may be present on foods. Although most EPA-registered pesticides are prohibited in organic production, there can be inadvertent or indirect contact from neighboring conventional farms or shared handling facilities. As long as the operator hasn’t directly applied prohibited pesticides and has documented efforts to minimize exposure to them, the USDA organic regulations allow residues of prohibited pesticides up to 5 percent of the EPA tolerance.
In 2010, the National Organic Program worked with the USDA Agricultural Marketing Service’s Science and Technology Program to evaluate pesticide residues on USDA organic produce. The study involved 571 domestic and foreign fruit and vegetable samples bearing the USDA organic seal, which were obtained from retail establishments across the United States. Using sensitive equipment, an accredited Government laboratory tested each sample for approximately 200 pesticides typically used in conventional crop production.
Of these 571 samples, 96 percent were compliant with USDA organic regulations. This means that the produce either had no detected residues (57 percent) or had residues less than 5 percent of the EPA tolerance (39 percent). Four percent of the tested samples contained residues above 5 percent of the EPA tolerance and were in violation of the USDA organic regulations. The findings suggest that some of the samples in violation were mislabeled conventional products, while others were organic products that hadn’t been adequately protected from prohibited pesticides. The National Organic Program is working with certifying agents to provide additional scrutiny in these areas.”
In short, there are three reasons for contamination: pollution, mishandling, or mislabeling.
We live in a polluted world, where water, rain, soil and the air can contain pesticide residues. Organic farmers do everything they can to minimize this contamination, and largely succeed according to the testing, but it is not possible to completely avoid the ubiquitous contamination of our shared environment. This is why organic does not claim to be “pesticide-free.”
Mishandling in the distribution and retail process can lead to pesticide residues on organic produce. Most stores handle both conventional and organic produce. Warehouses, crates, storage bins, boxes, displays and human hands can all be contaminated with pesticide residue. If organic food is not handled correctly, it can pick up pesticide residue from conventional produce. This is called commingling, which organic farmers and processors take great care to prevent, but once the product is sold and distributed, the handling is beyond their control.
Mislabeling or violation of the rules, either by accident or on purpose, is very rare—only 4 percent of samples tested exceeded EPA tolerance. As with all human endeavors though, it is possible that some organic produce was either mislabeled (conventional mislabeled as organic), or organic produce that was treated with pesticides against the USDA National Organic Standards.
I am having my organic corn (or soybeans or small grains or hay) custom harvested. What should I do to protect the organic integrity of my crop?
When using a combine to harvest grains, soybeans or corn, the machine must be cleaned thoroughly between any non-organic crop and the organic crop. If the combine operator is working with another organic operator before harvesting your crop, you may not need to have the combine cleaned. You will need documentation that the last crop run through the combine was organic, and not a buffer strip, a transitional crop, or non-organic crop the other organic producer may have grown.
Cleaning a combine is labor-intensive and still may not remove all traces of a non-organic crop. Running the combine with all of the doors open is one way to shake out kernels and dust. Blowing out with compressed air and/or a shop vac is also an option. After either of these is done, you also must run the combine through a swath of your organic field, separating the first 30-60 feet or more of the crop that has been harvested. This harvest must be stored, used and/or sold as conventional. Keep a receipt or other documentation to show your organic inspector that this combine “purge” was either fed to your own non-organic livestock or sold as conventional. The distance you harvest for this combine “purge” depends on the size of the combine and the density of the crop. You should be able to justify to your inspector the amount of your purge. Typically it is 10-20 bushels.
Combine cleaning is done routinely by farmers who grow crops to sell as seed in order to maintain seed purity. Many custom operators know how many bushels they need to run through their combine to remove traces of the previous crop, especially if they combine small grains in mid-summer and then beans and corn. You must document who cleaned the combine, what they did and when. Some manufacturers may have information on how many bushels must be run through the combine to clean it out.
If the previous non-organic crop was Genetically Modified (GMO), even a trace of non-organic crop dust in your organic crop could result in a positive GMO test and rejection of your organic load if and when it is tested by the buyer. An ounce of prevention is definitely worth a pound of cure in this case.
If someone is custom harvesting your hay or swathing your small grains, make sure the equipment arrives at your organic field clean. The cutting and windrowing equipment is easy to inspect. If it is traveling any distance over the road it has most likely been shaken enough to remove any non-organic hay or straw. This is true for large round balers, as they are mostly self-cleaning. However, it is still your responsibility as the organic producer to verify and document that there is no residue of non-organic crop in or on the equipment before it is used to harvest your organic hay or straw. If a custom operator first harvests your own conventional hay, a buffer zone, or transitional hay, you will need to clean the equipment before using it on your organic crop.
Small- and large-square balers are more problematic since they typically retain a partial bale or two. You will need to run at least three small-square bales or one large bale of your own crop through the machine as a “purge,” and document that these were stored and sold or used as non-organic. Many large square balers have some sort of preservative that is injected into the large bale. The preservative container should be emptied of any prohibited substances before the baler is used to harvest your organic crop; note this in your records. If the product is a bacteria or other naturally occurring substance you should verify with your certification agency that it would be allowed on your organic bales. Ask your custom operator what type of preservatives might be used in the equipment, and check it with your certifier at least a week before the operator shows up to bale your hay.
Rented storage areas as well as any transportation vehicles also must be verified clean and free of previous crop residues or prohibited substances before being used for organic crops. Document that you verified they were clean before you used them. This documentation can be part of your field activity log or calendar, or you can use the various forms your certification agency may provide.
I shipped one load of organic corn, and it was rejected by my buyer as having GMO contamination and was then sold to a conventional buyer. What should I do for my next load?
Before signing a contract for purchase of your crop, or selling a crop on the spot market, it would be a good idea to find out what, if any, GMO testing is done and what level of GMO contamination would cause the load to be rejected by the buyer you are considering. You can also find out what level of GMO contamination your previous load had, and try to take some precautions next year when planting corn to lower your risk and level of contamination. You might try planting later than your neighbor to avoid cross pollination, increasing the size of your buffer strip, or choosing to grow corn where it is more isolated from neighboring GMO corn. Even though corn pollen will travel great distances, higher levels of contamination will occur when the non-GMO and GMO corns are grown in close proximity.
Typically, all organic crops sold for direct human consumption are tested for GMOs, sometimes numerous times in the process of cleaning and readying for sale. However, most livestock feeds are not tested for GMOs. In 2011, a report by the Office of Inspector General noted this lack of GMO testing of organic livestock feed, and encouraged the National Organic Program to require more testing of livestock feeds, especially those sold to organic dairy farmers. At this time, there is no specific direction from the NOP on GMO testing of organic livestock feeds.
It is unfortunate that the organic farmer bears the brunt of the weakness of GMO technology; that it is promiscuous and does not stay on the user’s side of the fence. Depending on the amount of GMO contamination, you may have the option of selling your crop as organic to another buyer with lower requirements, telling that buyer about the GMO contamination.
I have some organic corn and hay to sell, but see the prices have dropped from last year. Why the change?Answer by Organic Specialist Joe Pedretti:
Prices for both organic and non-organic corn and hay are lower than in recent years because the supply is greater now, and the demand is lower. Weather was one factor behind the unusually high grain and forage prices in 2012 and 2013. Drought during the summer of 2012 caused a lot of crop failures and substantially reduced yields everywhere. Forage production suffered, too, causing many livestock farmers to dip into their stored feed supplies much earlier than normal. The unusually long and cold spring of 2013 only increased the shortage problem.
Demand rose for purchased feed because of these shortages, but also due to increased demand for organic dairy products. Most of the organic milk companies were expanding their new farm base during this same time period to meet consumer demand. These two factors created strong demand for a very limited supply of feed and drove prices up to historic highs late in 2012 and through the first half of 2013.
2013 saw a reversal in fortunes for both supply and demand. Despite the slow, cold start, organic grain and forage production was good to excellent in most areas of the country. Pasture was ample, so farmers were able to restock their hay and silage stores. 2013 also saw a softening of the organic dairy market. The downturn was not as bad as 2008-09, which saw quotas and flat sales, but sales did not meet budgeted increases and efforts were, and are still being made to reduce organic dairy production.
A year ago organic feed corn was $14.14; now it’s $10.25 to $12. The recent USDA forecast put non-organic corn at $3.90 per bushel in the coming crop year.
This product is OMRI listed, but only kills by direct contact, so it works best on annual weeds, and will kill anything it comes in contact with. Vinegar burns all of the above ground growth, which is why it is less effective on perennial plants with a strong root system. It might work with multiple applications on buttercup, but it will also kill your grass and clover.
A better approach is probably to change the conditions that promote buttercup growth. It likes wet, compacted and acidic soils, so liming the soil to increase the pH, adding needed nutrients to enhance grass growth and improving drainage will work better in the long run. A soil test will help sort out how best to improve the soils in that pasture.
I suggest contacting the Southern Sustainable Agriculture Working Group. They are an excellent organization of farmers that are committed to sustainable and organic production and are much more familiar with conditions in your region, and have likely dealt with this weed before: http://www.ssawg.org/
200 West Center St.
Fayetteville, AR 72701
P.O. Box 1552
Fayetteville, AR 72702
I am harvesting organic grain and want to make sure it retains quality in storage. What can I do to prevent insect infestations?
Many organic producers use diatomaceous earth, commonly called DE, to control insect infestations in organic grain storage. This fossilized remains of an ancient hard shell algae is used in many food-grade products, including as a filtration aid for liquids and in toothpaste. The fine powder kills a wide variety of insects or larvae by absorbing lipids from their exoskeletons’ waxy outer layer, causing them to dehydrate. Due to these characteristics, anyone handling this product should use a tight-fitting filter or respirator over their nose and mouth and goggles over their eyes to prevent health problems. Long sleeves, pants and gloves would be a good idea, too.
Typically, DE is scattered on the floor of the grain bin and periodically added to the grain as it is being loaded into the bin. Add 1 cup of DE to every couple of bushels or so of grain for good coverage. If you have a perforated floor in your bin with a fan, you can have the fan running on low as you load the bin to incorporate the DE into the first few feet. It is also a good idea to lift up the floor and clean underneath before loading it with this year’s crop.
If you can, run the grain through a spiral screen air cleaner before storage (pictured below). This will lessen the chaff, screenings, and insect load in your stored grain. It also dries grain better for higher quality long-term storage. Running your grain through the same cleaner before loading to your buyer would also be appreciated, since DE can be abrasive to their cleaning equipment. Shipping clean grain also means there will be less dockage from your payment due to screenings and foreign matter.
Make sure you leave head space at the top of the bin to allow for moisture to escape. If you are concerned about vomitoxin or other issues, test before you put it in the bin. The grain will not improve in quality when in storage, so knowing what you have at the start will help you make decisions on where to sell your crop and how long to store it.
Note that burning of crop residues, such as burning off residues either before planting or after harvest—a typical non-organic practice in some crops such as wheat, cotton, sugar cane, and rice—is not approved under organic regulations and may be subject to further restrictions under state or local laws that deal with impaired visibility and air quality.
Burning branches from pruning your fruit trees or brambles would also be allowed, since disposal of these items would prevent the possible spread of disease.
If you plan to use the ash from your burning as a soil amendment or in potting soil to provide potash or for pest control on vegetable crops, the ash cannot come from a material that was treated or combined with a prohibited substance. This means that synthetics not listed as “allowed” on the National List or a natural product listed as “prohibited” cannot be part of the vegetative matter being burned or mixed with it.
Section 205.203 (d) covers the use of ash. Pay attention to the specific annotations for limited use, such as copper.
Do not burn treated lumber, since toxic chemicals can be produced in the smoke and the ashes.
All agricultural feed, such as corn, beans, small grains or forages, must be certified organic in order to be fed to organic livestock. Organic crops grown by small-scale producers who are exempt from organic certification can’t be used. Feed supplements or additives that might contain agricultural products (e.g. soy oil as a dust suppressant), carriers such as wheat middlings, binders or ingredients to improve palatability (e.g. molasses) also must be certified organic.
While no rule says you must purchase feed supplements from certified organic feed mills, this does make it easier to ensure you’re meeting organic rules since they will have acceptable feeds, feed additives (a nutrient, such as an amino acid, vitamin and/or mineral) and feed supplements (nutrient blends added to feed or fed free choice).
As with all inputs, all natural (non-agricultural) items are allowed in organic production—salt, diatomaceous earth, kaolin clay, or enzymes
—as long as there are no synthetic additives, such as anti-caking agents, flavorings or colorings. You will need to get information from the supplier verifying this. Be aware that yellow prussiate of soda (sodium ferrocyanide), an anticaking agent common in bagged livestock salt, is not allowed. You can typically find this product listed as an ingredient on the salt bag. Also note that kelp is considered an agricultural product and must be certified organic to be used in livestock feed.
Organic regulations have some allowances for synthetic materials when a product is used to promote health, such as a homeopathic remedy. Items you give to your livestock on a regular basis, or seasonally as part of their feed, are considered feed additives or supplements and not healthcare products. For example, if you feed eggs to your calves to help them avoid diarrhea for a week, the eggs are a healthcare product and do not need to be organic. But, if you feed eggs regularly until the calves are a certain age, the eggs would be considered a feed and would need to be certified organic.
Yeast and bacteria cultures do not need to be certified organic, even though some may be available in an organic form. However, you must have documentation that they are not from a genetically modified source.
Fish and crab meal, usually seen as a “natural” form of the amino acid methionine, may be allowed by your certifier as a feed additive. Fish and crab meal that are not organic, would not be allowed as a significant ingredient in organic livestock feed. DL methionine is the only synthetic amino acid allowed in organic livestock, and only for poultry in specific amounts. Fish or crab meal is not considered agricultural at this time, but some might contain a prohibited preservative: ethoxyquin. Make sure you and your certifier have complete information on any ocean-sourced product to determine if it is acceptable.
The organic regulations also clearly prohibit some ingredients and uses. For example, you cannot feed supplements or additives above the amount needed to supply the nutritional needs of the animal. Plastic pellets, urea or recycled manure cannot be fed to organic livestock. Drugs, hormones, antibiotics or ionophores (ion carriers) cannot be fed to organic livestock. No poultry or mammalian slaughter byproducts can be fed to organic mammals or poultry. This includes blood meal, bone charcoal, bone meal, or gelatin. Any minerals that have been proteinated or derived from slaughter byproducts or GMOs are not allowed. Some of this information will be in the ingredients statement and some will not.
Since the label might not provide all the information you need to judge a product’s acceptability for organic production, you should work with your organic certification agency to verify acceptability of feed supplements for your organic livestock or those you’re transitioning to organic.
If you are working with an animal nutritionist who is willing to help you verify products are allowed in organic production, you can recommend finding acceptable sources of vitamins and minerals by checking these sources: the Food and Drug Administration (FDA) Code of Federal Regulations Title 21, (in the 500s) or, the current edition of the American Association of Feed Control Officials (AAFCO) Official Publication. If a nutrient is listed in either of those publications and meets the parameters outlined previously, it would be acceptable. Minor ingredients used in vitamins, such as any type of carriers or diluent that are part of the formulation, are allowed.
There is a fee to view the AAFCO Official Publication that is based on how often you want access. See www.aafco.org/Publications. The Code of Federal Regulations is searchable here.
I know farmers who are growing short grass fodder through the winter in an indoor fodder system for rabbits, pigs, sheep and dairy animals. From talking with them, I can see both benefits and challenges with this system.
The first challenge would be making sure you are meeting the nutritional needs of the livestock that will be fed the fodder. You will need to know the crude protein, fiber, calories and other nutrients needed by your animals during the time of year you will be feeding fodder, and what your short grass fodder will contribute toward those needs. Typically barley is grown for fodder, but any grain could be used. Obtain information on the feed values of the various types of grain fodder and compare that to the nutritional needs of your livestock by age and stage of production. That will help you understand what further feed supplementation you would need, and how much of the ration will be provided by the fodder on a daily basis.
You should also consider a nutritional analysis of what your animals would be receiving in an unsprouted grain, dry hay and feed supplement system. You could then compare the costs between the usual winter feeding system using stored feedstocks versus the cost and maintenance of setting up and managing the intensive fodder growing system. There are numerous resources on the internet that could help you with this important comparison. Search first for the nutritional needs of your specific livestock and then search for the nutrients present in the fodders. The fodder system manufacturers could also provide some basic information on the nutritional content of what is grown. Remember to compare the nutrients in various feedstocks by dry matter, since this fodder is 90 percent water, while dry grain is only 5 percent, which is much more concentrated on a pound-for-pound basis.
While it is very attractive to think of feeding your ruminant and non-ruminant animals green and growing forage when the ground is frozen in winter, you should put pencil to paper to make sure that it makes economic sense for you as well. Sprouted fodder systems grow either in a heated greenhouse or under lights in an insulated building. They require automatic watering systems—and these systems do use a lot of water. Lights and fans for cooling may also be needed. The upfront cost of the building, continual water and electrical needs, not to mention the actual growing containers and forage transfer equipment, all need to be part of your economic analysis.
Find other farmers who are doing this forage system, and see if they would be willing to have you visit and ask some questions. There is nothing like seeing a system functioning in a farm situation to help you imagine a similar production system on your operation. The fodder system suppliers could help you find others who have already purchased their systems.
Depending on your current farm infrastructure (buildings, water availability and energy costs or alternative energy production) and the number of animals you wish to feed, the obstacles above might not be a barrier. Growing this highly palatable feed could make for healthy and very happy livestock on your farm.
I read your article on sprouted barley fodder, and I would like to know if I have to use certified organic barley seed to do this?
The scarcity of certified organic meat processors in the Midwest is one of the biggest issues facing the organic industry. The recent loss of the organic processor Premier Meats in southwest Wisconsin has brought this issue to the forefront. There are very few certified meat processors left in Wisconsin and only two of them handle poultry. The lack of certified plants places organic farmers at an economic disadvantage. Either we are unable to label our products as organic, or are forced to raise prices due to the greater distance and time to haul and process our animals.
I encourage you to ask meat processors near you to consider adding organic certification to their services. The rapid growth in consumer demand represents real opportunity to expand clientele and services. Processors can learn more from MOSES or the Organic Processing Institute (www.organicprocessinginstitute.org).
I’ve compiled a list of certified organic meat processing plants in Wisconsin, Minnesota and Iowa. Many of these are included in our Organic Resource Directory. Farmers in other states can find a certified organic processor by searching the USDA website (apps.ams.usda.gov/nop/, select “handling” and your state for a list).
Black Earth Meat Market
1345 Mills St., Black Earth, WI 53515
608-767-3940 | www.blackearthmeats.com
Weber Processing Plant (beef, hogs)
725 N. Jackson St., Cuba City, WI 53807
608-744-2159 | www.webermeats.com
Sonday Produce, LLC (poultry)
E870 Highway 54, Waupaca, WI 54981
715-572-1477 | www.sondayproduce.com
Pete’s Meat Service, LLC (beef, pork, sheep)
1665 Main St., Rudolph, WI 54475
Springbrook Meats, LLC (beef)
N3485 810th St., Elk Mound, WI 54739
Twin Cities Pack (poultry)
5607 East County Hwy J, Clinton, WI 53525
608-676-4428 | www.twincitiespack.com
Halal Food Processors
900 66th Ave. SW, Cedar Rapids, Iowa 52404
319-366-8327 | www.halalfoodprocessors.com
Amend Packing Co (beef)
410 S.E. 18th St., Des Moines, Iowa 50317
515-265-1618 | www.amendpackingcompany.com
220 W. 1st St., Earlham, Iowa 50072
515-758-9545 | www.lpb-inc.com
Premium Iowa Pork, LLC (pork)
108 First Ave. S., Hospers, Iowa 51238
712-752-8666 | www.premiumiowapork.com
Northern Pride Inc. (turkeys)
401 S. Conley Ave., Thief River Falls, MN 56701
218-681-1201 | www.northernprideinc.com
Kb Poultry Processing LLC (poultry)
15024 Sandstone Drive, Utica, MN 55979
507-932-9901 | www.kbpoultryprocessing.com
Ledebuhr Meat Processing, Inc. (beef, pork, lamb)
5645 6th St., Winona, MN 55987
507-452-7440 | www.ledebuhrmeats.com
Swanson Meats, Inc. (beef)
2700 26th Ave. S., Minneapolis, MN 55406
612-721-4411 | www.swansonmeats.com
Lorentz Meats (beef, poultry, hogs)
705 Cannon Industrial Blvd., Cannon Falls, MN 55009
507-263-3618 | www.lorentzmeats.com
TFC Poultry (poultry)
103 Melby Ave., Ashby, MN 56309
218-747-2749 | firstname.lastname@example.org
Organic feed prices also have moderated in the Midwest and East (but not in the West, due to the California drought). These factors, combined with strong conventional prices, make this is an ideal time to transition to organic dairy—but, you do need to do some homework first.
Before beginning your transition, you should make sure there is a market for your milk. Start by contacting one or all of the organic milk buyers in your area. (Search the online Organic Resource Directory for “milk” to find a buyer near you.) Most of these companies manage their supply closely and commit to transitioning farmers far in advance of the date they can start shipping organic milk. This commitment is key, as it makes no sense to undergo the expense of certification, or of buying organic feed, until you know when and if you can start selling organic milk.
Most companies like to bring on new producers in the fall or winter rather than the spring and summer when their milk supply is naturally at the highest peak. The milk buyers will deter¬mine if they need your milk (supply), if you are on or near one of their milk truck routes (location), and determine when you can be ready to ship organic milk (timing).
If they need your milk, and the logistics and timing works out, they will put you in their milk plan and, as you approach your one-year herd transition, make a commitment to pick up your milk once your organic certification has been completed. This commitment is very help¬ful if you need to secure bank loans during the transition. The timing also will determine how you manage your transition—specifically, when you begin your one-year herd transition.
To transition a dairy, the land needs to be managed without prohibited inputs for three years and the herd needs to be managed organically for one year. The National Organic Standards allow a dairy to transition the herd along with the land during the third year of transition. This is a critical point, and one that can greatly reduce feed costs. During that third year, you must manage the herd without antibiotics or prohibited herd inputs, and feed them exclusively your own third-year transitional feed, or purchased certified organic feed.
If you have been managing your land without prohibited inputs already, you may only need to complete the one-year herd transition. Contact MOSES or a certification agency to determine your transition timetable. MOSES also can assist with finding an organic milk buyer in your area.
The rain we've had has made my pasture too wet to graze my herd. How can I meet the livestock grazing requirement of 120 days?
In addition, the National Organic Program regulations are very clear that the grazing sea¬son for your organic ruminant animals need not be continuous, just must total a minimum of 120 days when they are grazing. Your organic system plan must provide for acceptable grazing opportunities for the full grazing season, when weather cooperates. If there is a dry spell for two weeks at the end of August, you can feed hay to your cattle. Once the pastures improve in September, the animals should be allowed to graze.
You should have enough pasture acreage to provide a minimum of 30% dry matter intake from grazing for all of your ruminants for the full grazing season during a “normal” year. The minimum 120-day requirement is only for areas where the typical grazing season is that short, or there is a significant weather event that causes you to have a shortened grazing season. The typical grazing season in the Upper Midwest is 160-180 days. Use of intensive or rotational grazing management systems can greatly improve the quantity and quality of pasture for your animals.
The percent of dry matter taken in can be averaged over the whole season to meet the rule. For instance, your cattle may receive 60% dry matter intake from grazing in May, June and July and 10% dry matter intake from grazing in August, September and October (due to drought). You would average 35% with this scenario and that would be acceptable. The National Organic Program also has allowed a special exemption for less than the 30% dry matter intake from grazing when the USDA Secretary declares a region a disaster due to drought. However, there is no provision in the regulation to allow non-organic hay, forage or other feeds to be fed to organic livestock, even when a disaster has been declared.
This product combines soap with enzymes to destroy the exoskeleton of the lice. It is very effective and non-toxic.
As always, you must call your certification agency to get approval on the use of any new product. Never apply any new product without prior approval.
What can I do now to ensure my herd will have enough pasture this summer to meet the 120-day grazing requirement for organic production?
Even if you feel that you have plenty of land to pasture animals on, mid-season dry spells and the need to let pastures rest means that you may need to consider particular management alternatives in order to have enough forage this summer. Beyond finding more pasture land, some options to consider include grazing your hayfields, growing summer annual forages, frost seeding, and stockpiling pasture.
There are many resources and guides available to help you choose the forage option that’s best for your operation. Wisconsin Extension offers grazing resources at http://fyi.uwex.edu/grazres/; so does GrassWorks: http://grassworks.org. A resource that directly addresses your question is “Extend the Grazing Season with a Forage Chain,” a workshop presented by Laura Paine at the 2014 MOSES Organic Farming Conference. The audio recording of that workshop is sold through the MOSES Bookstore under Conference Audio Recordings at mosesorganic.net.
Many producers bring hayfields into the grazing rotation after one or two cuttings. These can be dedicated hayfields, or different fields cut each year. Rotating hayfields with pasture use may increase species diversity and control certain weeds.
We’ve recently seen an increase in the practice of grazing summer annuals, such as sorghum sudan, as a supplement to cool-season forages. Graze only after plants have reached 18-24 inches. It works well to strip-graze a bit of the field each day in addition to the perennial pastures. Care must be taken to avoid prussic acid poisoning, but if you graze this crop during summer slump that is not an issue. Also, avoid grazing during or after frost.
Fall grazing of broadleaf crops such as turnips, radish, or mixtures of several species can be utilized in some cases. Introduce these slowly and do your homework as to the health effects of grazing these species. You cannot rely exclusively on these for grazing, and they should not be more than 75% of the animal’s diet while being fed. Supplement with dry hay, and allow access to grass pastures while grazing brassicas. In some cases, it might work to no-till the broadleaf seed into existing sod, creating a grass/broadleaf mixture.
Frost seeding of red clover at 2-3 pounds per acre and white clover at 1-2 pounds per acre separately or in a mixture in early spring is common in the Upper Midwest. Some graziers frost seed a third of their acres each year to try to keep the 30-50% recommended legume in swards, which is essential for providing nitrogen in an organic system.
Stockpiling forages for late season grazing can work to feed non-lactating animals with lower nutritional requirements. Rest these acres after mid-August, and graze when dormancy sets in due to freezing temperatures. You might be able to graze animals with lower nutritional requirements on CRP (Conservation Reserve Program) fields, if there is access to water. You will need to notify your organic certification agency to include these in your annual inspection and add them to your Organic System Plan. Before doing this, make sure there has been no chemical spraying of invasive weeds, which landowners are required to control under CRP rules. In addition, approval to graze must be granted by the FSA and NRCS (Farm Service Agency and National Resources Conservation Service).
I intend to pursue organic certification this spring for the first time for my orchard and some yearling organic feeder beef cattle I am purchasing. My farm has some older copper-arsenate treated fenceposts in place and I recently started to install some posts with the newer chromated copper arsenate (CAC) treatment. Are these allowed, or is there another type of treated wood I can use instead? If these are not acceptable, do I need to remove them?
There are no synthetic wood treatments currently listed as approved for organic production. Any new fencing must comply with organic standards and cannot contain these prohibited synthetic materials. However, fencing that is already in place before your first organic inspection can remain even if the posts were treated with prohibited materials. Your certifier may require a specific distance between the treated posts and soil where organic crops are grown. For your grazing animals, an interior poly fence might be required to prevent grazing right next to these posts.
Natural wood, metal, fiberglass and concrete posts are allowed. CAC-treated posts contain many synthetic compounds that are not allowed under organic regulations, including copper, ethanolamine, ammonia, and possibly formaldehyde. Copper is allowed on the National List of synthetic substances, but not specifically for wood preservation.
If you have purchased, but not yet set in place your treated posts by the day of your first organic inspection for organic certification, it is pretty likely that you will not be able to use them where they are in contact with soil growing crops that animals or humans may consume, nor where animals may touch them in any way, such as a corral or fence. Technically, you cannot set in place posts treated with synthetic materials once you are certified, which would mean the date of issuance of your first organic certificate. However, many certifiers ask that these posts not be used after your first inspection, since they will not be back to verify that you’re not using treated posts until your second inspection the following year. There is some slight variability between certifiers on how they handle this issue, but none of them allow the installation of posts treated with prohibited substances once you are certified as organic. The size of the buffer area they may require between existing or newly installed treated posts also can be different between certifiers.
Many times, the treated wood posts are preferred by some for fence corners, and I have seen certifying agencies allow this use, as long as there is a wire strung across the hypotenuse of the right triangle formed by this corner, that way, the animals stay back from the corner where the wooden posts are located and cannot consume grass near the wood.
All of these treatments do leach into the soil, and plants have been known to accumulate the synthetics in their vegetative matter. This is especially an issue in organic orchards. Stabilizing posts placed next to new trees should not have any synthetic treatments. Perimeter fencing around an orchard usually would be far enough away from your trees that treated wood may be used, but the distance required can vary between certification agencies. Many times, the dripline of the outer branches of a mature tree would be sufficient distance to the treated post. To be sure, check with your certifier about the required distance to maintain between treated wood fenceposts and your trees before you install perimeter fencing. Also ask what date they will allow the installation of treated posts in close proximity to your organic plants or grazing area before you are officially considered a certified organic operation.
Market Farming & Orchard:
Can I sell organic fruits and vegetables from plants and planting stock I buy at my local garden center?
You probably will not be able to buy plants at your local garden store. When using annual transplants (tomatoes, peppers, onion plants etc.), the plants must be certified organic in order to sell organic produce from them in any given crop year.
The land you raise them on must be free of prohibited materials for 36 months prior to your first organic harvest. If you have planted nonorganic annual transplants in the same fields in the past, your certification agency may consider the land to be nonorganic, and require you to wait three years after that planting to have your first organic harvest. This decision may depend on whether the plants were bare root or were transplanted with their nonorganic potting mix. There is some difference between certifiers.Some allow one year to pass and others require three years. The interpretation of this regulation is something you want to discuss with your certification agency if you are requesting organic certification for the first time.
Your transplants cannot be purchased from an “exempt from certification” (under the $5,000 limit) operation. They must be certified organic, grown by you or someone else who has a valid organic certificate. Some natural food stores may be able to provide you with an organic certificate for the plants they sell, but most garden centers do not sell certified organic transplants.
You can grow the transplants yourself, using approved planting media which does not contain any synthetic fertilizers, fungicides, wetting agents or other prohibited materials. These items are not mandated to be listed on the label of commercially available potting media, so you must get information in writing from the manufacturer detailing the ingredients, stating that the media has not been treated with prohibited fungicides, insecticides, etc. There are many organically approved potting mix and input suppliers. For resources, see the MOSES Resource Directory or the OMRI Products List.
Be very careful when purchasing any fertility input or potting mix, since the word “organic” on these items does not always mean the same thing as “approved for organic production.” Long before the USDA organic regulation, the word “organic” on a label meant it contained the element carbon. To find products you can use, you must look for the OMRI seal and the words “approved for organic production.” Always verify with your organic certification agency that whatever you want to use is acceptable before you buy it.
For fruit trees, raspberry bushes, or other perennials, you are mandated to search for organic planting stock. However, if you cannot find the variety, quality or quantity you want as organic, you can use non-organic planting stock. You must document this search.
In a recent National Organic Program guidance it was clarified that an organic harvest from non-organic planting stock can be done immediately after beginning organic management and planting into organic soil. However, you cannot create and sell organic planting stock from parent nonorganic stock until it has been managed organically for 12 months. For example, you can plant non-organic strawberry plants and harvest an organic crop that same year after planting (after failing to find commercially available organic plants) whether you manage the strawberries as an annual or a perennial. If you buy a non-organic tarragon plant, you can sell the tarragon as organic immediately after planting in organic soil, but could not make cuttings and sell those as organic tarragon plants for 12 months.
Items such as potatoes, garlic, and sweet potatoes (in other words, roots, tubers, rhizomes, shoots, leaf or stem cuttings) are subject to the organic search, and can be planted as non-organic if none were found. However, each year there is more and more availability of these items as organic, and your search must truly cover not just your local store, but also the many mail order and internet operations that sell these items.
I can’t find enough certified organic blueberry plants to upscale my certified organic berry farm. What do you suggest?
The National Organic Program defines planting stock as “any plant or plant tissue other than annual seedlings, but including rhizomes, shoots, leaf or stem cuttings, roots, or tubers, used in plant production or propagation.” The NOP regulation applies to the details of the growing methods of the plants. Certified farms must use organic planting stock, bulbs, roots and cuttings except when these are not commercially available. If you cannot find your preferred blueberry variety, or can’t get sufficient quality or quantities for the scale of your operation, you can use non-organic planting stock.
As with all seed and planting stock searches, you have to provide your certifier with good documentation of your search. And of course, price cannot be a consideration for determination of commercial availability.
Each year, the availability of certified organic planting stock grows. More varieties, better quality and bigger quantities become available. It’s the age-old high school economics supply-and-demand lesson in action.
To find planting stock, you can Google “certified organic planting stock” for your area, or “certified organic blueberry plants,” using the specific variety you‘re looking for. This will help you find local plant nurseries that carry certified organic plant stock. Another great resource may be the organic growers in your area. Networking with the other certified organic growers in your area can be a great benefit in many ways to everyone involved.
If you’ve exhausted all your options for finding the variety, quality and quantity that you need, and you’ve kept really good records of your search, you can begin to explore other options. NOP regulation states that you can purchase a non-organic plant and sell its fruit the next day as certified organic fruit with some exceptions—the regulation is in the details. If the purchased non-organic plant has been grown in planting media containing any synthetic fertilizers, fungicides, wetting agents or other prohibited materials or has been treated with prohibited fungicides or insecticides, these are prohibited substances, and so the fruit cannot be certified organic. Not only that, if you introduce these prohibited substances to your certified organic soil, you may risk needing to re-transition your soil for another 36 months.
Buying non-organic bare-root plants rather than potted plants is the best way to avoid these unwanted materials. If you can verify and document that your bare-root planting stock hasn’t been treated with any prohibited materials, you can plant the new planting stock in your organic soil and sell the fruit as certified organic.
Only the fruit can be sold as organic. The planting stock, crowns or bulbs off the newly purchased non-organic plant must be in your certified organic ground, grown according to NOP regulation for 12 months before the plants can be sold as organic. Since most perennial fruit-stock will not produce a commercial crop the first year of planting, this probably would not be an issue.
For example, after failing to find commercially available organic plants, you can plant non-organic blueberry plants and harvest an organic crop that same year after planting. However, you cannot sell any excess planting stock as organic blueberry plants for 12 months.
Ultimately, the search for certified organic planting stock is similar to the search for seeds. You have to keep good records of your steps. And while it’s best to find and support certified organic suppliers, you have other options if you’re unable to find what you need. As with all certification questions, call your certifying agency to be sure of what you’re bringing into your certified organic farm operation.
First, you need to make sure that they are actually fruit flies. Fruit flies are often confused with a different insect called a fungus gnat. Fruit flies have red eyes, a round body and tend to hover or fly pretty slowly. They are slower moving while walking on the ground, too.
Fruit flies need overripe, damaged or rotting fruit in order to feed and breed. They are also known as vinegar flies, and are attracted to the smell of acetic acid (rotting fruit and vegetables). If you keep these materials out of the greenhouse, you are not likely to have fruit fly problems. Clean up damaged fruit and remove ripe fruit as soon as possible. The old baited fly trap with vinegar and a little soap works well to reduce their numbers, but you have to control the food source with good sanitation to get rid of fruit flies completely.
If your sanitation is good, and you are still seeing small files, they are likely fungus gnats. Fungus gnats are quite fast, both in the air and on the ground, are more thin bodied and do not have colored eyes.
Fungus gnats breed in the organic matter of soil mixes that are kept too wet and thus breeds molds, which the fungus gnat larvae feed upon. The solutions to control fungus gnats are to avoid overwatering plants in the greenhouse, improve drainage, and allow the potting soil to dry in between each watering.
Fungus gnats are not harmful to plants, but the conditions they like are also the same conditions that can lead to fungal and bacterial diseases.
Either fly problem is best solved by cultural techniques, rather than approved sprays.
Yes, you can plant non-organic strawberry plants and sell the fruit as organic with no waiting period, provided you have documented a search and could not find commercially available organic strawberry plants.
The requirement for planting stock is similar to that for commercially available organic seeds. You must use an organic version unless you cannot find it in the variety, quality or quantity that you need. You must document your search for organic strawberry plants or other types of planting stock. If you cannot find them in the type, quality or quantity you need, then you can plant non-organic plants and sell the fruit as organic.
In February 2013, the National Organic Program (NOP) updated guidance on whether or not “planting stock” such as strawberries, raspberries, tree fruits, and herb plants needed to be under organic management for one full year before selling the production from these plants as organic. Many certification agencies had required a year of organic management. With the update, the NOP clarifies that the one year of organic management is only required when a grower is selling the planting stock itself as organic.
You can sell strawberry fruit as organic at any time from a non-organic strawberry plant. However, the runners from that plant must be under full organic management for a year before you can sell them as “organic planting stock.” Also, you can sell rosemary or lavender leaves as organic from non-organic plants recently planted on your organic farm, but you must manage the plant organically for one full year before you can make cuttings and root them to sell as organic plants.
Before you take drastic steps, determine if the damage is at an economic threshold where you need to take control measures. Knowing the life cycle of the pest bothering your vegetables will tell you if the population numbers can rise very quickly, or if they tend to lessen over time. Your understanding of the insects’ needs and dislikes will help you manage them over time. In a war where only numbers are considered, insects tend to win. In a war where knowledge is the main weapon, humans have the upper hand.
The organic regulation has a pest control hierarchy that mandates you start with cultural, biological or mechanical practices to manage pests, weeds and diseases. When those don’t curb the problem, you can use natural products. After that—but only as a last resort—you can use synthetic materials that are on the National Organic Program’s National List of Approved Substances. Use of synthetics should be avoided as much as possible; broad spectrum insecticides kill beneficial pollinators or predatory insects along with problem insects.
Organic agriculture is a system of production, not just a way to grow food by substituting organically approved materials for non-approved ones. Keep track of problems you have had in the past and seek out resistant varieties (cultural control). Grow habitat beneficial to insects that prey on your pests (biological control). And, use exclusion devices like netting or floating row cover (mechanical control) to protect the tender young plants so favored by insects.
Research has shown that insects favor weak and stressed plants; healthy plants are less attractive to pests. Try foliar feeding your plants with a fish emulsion and seaweed blend to boost their immune system, both to help them recover from the insect damage and to discourage further infestation. Consider starting a regimen of foliar feeding when your plants are usually stressed, such as right after transplanting, when they flower and when they set fruit. Improving the health of the plant also helps you achieve higher yields of quality crops.
Another management technique is to plant a trap crop that is highly favored by your problem insects, and then spray an approved pesticide only on that crop. If you need to move to your last resort of approved synthetic materials, check out Peaceful Valley Farm and Garden Supply’s pest solution chart (www.groworganic.com/weed-pest-control/organic-pest-control. html). This cross-referenced chart of problem insects and control materials is very useful.
As you learn more about insect life cycles and how insect pests interact with your environment, you can help your plants become less vulnerable to insect problems.
I am washing roots, squash and other vegetables for short- and long-term storage. Is there something I should add to my water to help them keep?
There are three common wash water additives used for washing organic vegetables. One is food-grade hydrogen peroxide, 35%. This should be diluted down to 3% in the wash water. That would be one part 35% H2O2, to 11 parts water. This product is corrosive, so handle it at full strength only when wearing long rubber gloves and goggles. H2O2 can degrade organic materials, bacteria, and organically approved or non-acceptable pesticide residues.
Another product is peroxyacetic acid, with Tsunami, a brand name for this blended product. Use this at dilution noted in the instructions. It is advisable that a final clean water rinse be done after the use of hydrogen peroxide or peroxyacetic acid before putting into long-term storage.
Let the root vegetables mostly dry before putting into storage. Some producers put these in large food-grade plastic bags in open-top totes to retain some moisture. Periodically check to make sure the roots are not too moist and getting moldy. For very long storage, you want some moisture so the roots do not dry out. Packing root vegetables in clean, slightly damp sand also works.
Chlorine also can be used, but only in fairly low concentrations. The organic regulations require that the effluent after washing contain no more than 4 PPM chlorine, which is the level allowed in drinking water. You can have your concentrations higher when washing the produce, but the chlorine must basically all be consumed and volatilized by the action the chlorine has on the bacteria and organic matter in the water. This makes the use of chlorine on a small-scale farm more problematic, since you will need to test the waste water to verify you meet the regulatory requirements.
Aphids are sucking insects that weaken plants by sucking up sugars and other fluids from crops. They are not easy to see, since they are the same color as the plant stem and generally like to feed on stems, buds, and underneath leaves.
Step one for control is to monitor your crops on a regular basis. Infested plants are often stunted and can be a lighter green or yellow. Look closely at the stems under the leaves for aphids. A magnifying glass or loop can help. A good approach that saves time is to flag “sentinel” plants. Mark plants in a grid pattern and only monitor those specific plants on at least a weekly basis. If you find significant numbers of aphids on these plants, you know it is time for control options. Yellow sticky cards are another good monitoring device. Adult female aphids have wings and are strongly attracted to the color yellow, which mimics the color of sickly plants. The cards are coated in sticky glue, which traps them. Check cards at least weekly for signs of adult aphids. Sticky cards need to be replaced frequently to work well. Fortunately they are cheap and available through any greenhouse supply company.
If you have any infested plants in a greenhouse or high tunnel, you should begin control options since their numbers can explode quickly.
Here are your options as an organic farmer:
There are a number of predators and parasites available for purchase and release. Ladybug larvae are the most familiar, but there are parasitic wasps, lacewings and others available now as well. Biological controls work best to keep aphid levels down, but may not give good control if you already have a problem. They simply cannot reproduce as quickly as aphids (which can actually reproduce without males- females give birth to clone daughters). Beneficial insects work best as preventative controls. A number of companies sell beneficial insects, including:
Soapy water will kill aphids. The soap strips away their waxy cuticle and they die of dehydration. In order for this to work, they must be directly sprayed with the soapy water. Use a sprayer and mix one tablespoon of liquid soap per gallon of water. (Dr. Bronner’s is pure soap. Be careful not to use soaps with perfumes, dyes or other synthetic additives.) There are also many ready-to-use brands that are OMRI listed including the common Safer Insecticidal Soap.
Allowed Chemical Sprays
Remember that all insecticides approved for organic use are “restricted use” products. You can use them only when your other control options have failed, and you must notify your certifier if you intend to use a new product and the reason you must use it. Pyrethrum/pyrethrin-based sprays will work on aphids, but have a very short residual effect and must come in contact with the aphids. The product Pyganic works well, since it is pyrethrin mixed with oil, which coats and kills aphids and many other insects. Your certifier should be able to provide a list of approved pyrethrum/pyrethrin sprays or check the OMRI website for a list: www.omri.org.
Aphids also love plants that are over-fertilized with nitrogen. If they are a constant problem despite other control efforts, you might be adding too much nitrogen to your potting mix or through fertilizer applications. A tissue test to determine nitrogen levels may be in order if you are having ongoing issues with aphids and other sucking pests.
As always, crop rotation and good sanitation practices can help control aphids in the long run.
Soils & Systems:
Feed and bedding: Arsenic is the only prohibited feed input that could have been fed to non-organic animals, which would prohibit use of manure on organic land. Arsenic has at times been added to conventional broiler chicken feed. It is an element, and will remain in your soil since it does not break down. You must document that this is not in the feed if you are using broiler manure. Other than this, animals could have been fed genetically engineered (GE) feed, or given antibiotics or hormones, and the manure is still allowed on organic land.
However, if the manure includes bedding, it cannot contain prohibited synthetics, like treated wood shavings or glues/paints/heavy metal-based inks. On the other hand, GE corn stalks, or any conventionally raised crop is allowed as bedding in manure that can then be spread on organic land.
Piles and Lagoons: You must obtain a document from the manure supplier that a manure pile or manure lagoon did not have prohibited synthetic items used in or on the manure. For example, no non-approved fly sprays or herbicides may be used on manure piles, or non-approved synthetics put in manure lagoons to control odor. A natural lactobacillus bacterium is allowed as a manure lagoon additive, as long as it does not contain non-approved synthetics. Manure that has been piled outside or in a barn for 10 years with no turning and/or no documentation that it reached the high temperatures required for compost (see below) is still considered raw manure, and can only be used according to the manure restrictions on human consumed crops.
Human-consumed crops: If you are growing crops for human consumption, and the manure is not composted or processed, the manure must be incorporated either 120 days before harvest of the crops where the crop has contact with soil (either growing in or on the ground, or where rain might splash soil on the crop, such as beets, tomatoes, peppers), or wait 90 days before harvest where the crop does not have contact with soil (i.e. corn or soybean seed).
Compost and processed manure: Manure that has been composted (documented temperature of over 131 degrees for 15 days and turned 5 times) or processed (150-165 degrees for one hour and tested to have less than 1000 most probable number (MPN) of fecal coliform and 3 MPN salmonella per 4 gram sample) can be used up until day of harvest with no restriction. If you are composting only vegetative matter, without any animal by-products, then there is no requirement to track the compost reaching a specific temperature. Non-animal product compost can be spread this on your organic crops at any time.
Using manure: Be aware that raw manure that has not reached the high temperatures of composting or processing will contain viable weed seeds. You will be adding more, and possibly different, weed seeds to your fields. It is a good idea to obtain an analysis of the manure you are using so you can better manage for the nutrients it provides.
Compost that might contain manure must meet the composition, temperature and turning specifications in the National Organic Standards:
(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 5 times.
The county/city must provide the documentation to show these standards were met before you can use a material as compost. If they cannot prove they have met these standards, it may be possible to still use it, but it will not be considered compost, it will be considered raw manure, and will have different handling requirements:
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;
Composted and un-composted plant materials without manure have no application restrictions, but the composting center must verify that the compost contains only 100% plant materials. If there is a possibility that it contains pet waste (animal manure) then it must be handled as raw manure.
Whether or not it contains animal manure, you still must make sure compost contains no prohibited materials:
•Recycled building materials/lumber (due to paints, varnishes and glues)
•Plastics and other un-compostable synthetics
Check with the composting facility to see if they have the necessary documentation. If other organic farmers have been using their product, it is quite likely they have this paperwork on hand. Also check with your certification agency, which can do a product review if it has not already reviewed this compost for other farmers. Ultimately, your certifier makes the final call on whether a product is allowed or not. All new inputs should always be verified and added to your crop input list before use.
My neighbor is certified organic by a different agency than I am. He uses a blended fertilizer product on his certified organic land. Can I use the same fertilizer on my organic land?
Since the materials you use are part of your specific organic system plan, you must verify with your own agency if it has reviewed and approved this product before you apply it to organic land or crops. Some, but not all, certification agencies will accept any OMRI-listed products, but you still must inform your agency if you choose to add an OMRI-listed product to your Organic System Plan’s list of inputs used on your organic land or crops. You can ask your certifier what the agency’s policy is on OMRI-listed brand name products to help you when deciding which products to purchase.
Since product formulations may change periodically, certifiers will want you to update each year what inputs you are purchasing and using, so they can check that they have current ingredient information to verify the product is still in compliance with the organic regulations.
It can be frustrating to know that some certifiers accept a product and others may not. However, the National Organic Program is currently working with the National Organic Standards Board to develop procedural guidelines for certifiers and organizations like OMRI, who review and approve these inputs for organic producers. Once these guidelines and NOP oversight are in place, this should provide a level of confidence between certifiers where they feel comfortable allowing the use of brand name products that have been reviewed and approved by another certifier who has met these NOP guidelines.