Our farm has been certified organic for 5 of its 7 years in business, including our transition from a market & restaurant focus to a CSA, but we’ve decided to drop our certification for 2014 and the forseeable future, effective March 15. This decision has been developing for a long time, and was the topic of countless hours of discussion over the last year. Over the next three posts, we’ll attempt to discuss and explain some of the myriad experiences and reasons behind this decision, though we can’t possibly cover everything.
PART I: Some of our concerns with the USDA Organic system as a whole
The rules defining what’s allowed in organic production are increasingly at odds with our beliefs and standards for sustainable & ethical food production. One major example involves fertility: organic farms are allowed to use feedlot manure on their fields. We find this abhorrent, both because of the potential for various agri-chemicals, antibiotics, and pathogens to be transmitted to the organic farm, and because allowing feedlots to dispose of their waste problems into the organic system is indirectly supporting a system organic is supposed to be countering. This reality is one reason that drove us to produce our own on-farm fertility by raising goats & chickens and doing the composting ourselves, but ironically this creative and self-sufficient solution has created more paperwork and hassle in the organic system than just buying loads of pre-approved fertility.
The current system also favors organic growers with less diversity. When the paperwork and tracking have to be done for every individual crop or product, it’s a lot easier to be a large, low-diversity farm than a small, diversified one (our 2013 certificate listed over 100 crop types). Organic was founded by and for diversified small farms, but the bureaucracy has evolved to favor a very different approach, even if that’s not the intention.
We’ve found that organic rules tend to favor the purchasing of manufactured inputs over the creative development of on-farm replacements. Commercial products allowed for use on organic farms are generally reviewed by the Organic Materials Review Institute (OMRI); if a product has the OMRI label you can be pretty certain it’s allowed (though in many cases with restrictions). It’s worth noting that the word “organic” on a product means little or nothing without the USDA or OMRI seal; hardware stores and garden centers around here are full of products mislabeled “organic” that are not allowed under certification; the USDA doesn’t track or enforce the term with respect to farm inputs. This also contributes to the misuse of the term by some non-certified farmers, who think they can use “organic” inputs and be Organic even though they haven’t gone through a certifier who would flag the use of those products.
In theory this is a fine system; the OMRI label makes purchasing decisions easier, and it’s more efficient for a centralized institute to research commercial products than a bunch of individual farmers or certifiers. The problem is that it ends up favoring off-farm manufactured products over creative on-farm ones. Using the fertility example above, if we just bought OMRI-approved compost or fish fertilizer, our paperwork in that regard would be relatively simple. But collecting our own on-farm manure and doing our own composting means every step of that process has to be documented and approved by our certifier just for our farm, creating a lot more work & cost for everyone involved even though we consider this method far more “organic” in the philosophical sense. Trying to use our own resources in a creatively sustainable way created an unusually-shaped peg that the organic system’s round holes don’t expect. And thus there’s a lot of subtle pressure on organic farms just to buy stuff rather than be more diversified and creative in their farming approach, meaning that organic as defined by the USDA is increasingly resembling a mirror-image of conventional agriculture, in which purchased inputs and sprays take the place of holistic, skilled, on-farm solutions.
The availability of a long list of OMRI-approved inputs, including pesticides, fungicides, and herbicides, means that some organic farms can get away with being not all that different from conventional farms; they just substitute the OMRI version for the synthetic version. That’s not our style, as noted by one of our organic inspectors:
“These organic farmers are not ‘spray-happy’ (like some organic farmers relying on organically-approved silver-bullets), thus the ‘substance list’ by choice is virtually absent.” – 2011 organic inspection report for Chert Hollow Farm
However, organic is a one-size-fits-all certification: our farm carries the exact same label as the biggest industrial organic chicken houses or large monocultured vegetable farms. In theory we’d like to see some kind of LEED-style gold-silver-bronze categories of organic that would allow for a more nuanced and rewarding approach to farm quality, although that might just confuse consumers even more. But as it stands farms like ours are effectively the face of Organic, obscuring the less ideal reality underneath the tip of the organic iceberg.
“Great organic setting of an organically-minded operation run by two folks who live & breathe organics…. This will become a ‘mighty’ organic form for the area.” – 2009 organic inspection report for Chert Hollow Farm
Finally, we’ve come to feel that there’s a significant flaw in the established relationship between the USDA, certifiers, and farms. To achieve organic status, a farm applies to a certification agency, which is accredited by the USDA to enforce the rules. These agencies can be non-profits, for-profits, or state agencies (Missouri cut its state organic program years ago). The farm is inspected every year, either by an employee of the certification agency or an independent inspector hired by them, and their report goes back to the agency along with the farm’s own paperwork, and a decision is made. The problem here is twofold.
One, it’s a pass-fail system; you only have to be organic enough not to be kicked out. There’s no internal or external reward for being more than minimally compliant, or more organized with your records than the worst certifiable farm. We routinely received high praise from our inspectors for the quality of our records, our compliance,and our ethics, but this had no effect on the cost of our certification or our ability to market our products. A dismally disorganized farm costing the certifier far more time and hassle to force into minimal compliance gets to use the exact same marketing and cost structure that a really professionally run farm does. We’re tired of our dedication subsidizing lesser competition.
“The seed search appears valid and indicates profound integrity – it was obvious to me that they truly searched for organic seeds and planting stock, eg, how many producers pay for the extra cost of organic raspberry plants – when they can buy conventional stock and the plants will be managed organically for a year before harvest anyway?” – 2013 organic inspection report for Chert Hollow Farm
Two, it’s a system that lends itself to kid gloves. Both certification agencies and inspectors rely on farms choosing to patronize them; you’re allowed to change agencies as desired or object to a given inspector. So any agency, or inspector, who’s too strict in enforcing rules is going to face a competitive disadvantage for staying in business. At a national organic conference years ago, I was surprised at how much shop talk among farmers dealt with which certifiers were easier-going than others. This is not to imply any outright corruption; there are lots of good people involved in this system. It’s simply a concern that, any time a regulator relies on the regulatee for income and existence, something is lost from the idea of the system. Would anyone accept the energy industry being able to choose from a selection of public and private EPAs based on their cost and their cooperativeness? We feel that, like the concern above, this structure diminishes the value of being a really compliant organic farm.
In Part II, we’ll discuss some of our specific negative experiences with the organic certification system.