[Compostteas] It makes you really wonder, doesn't it.

Jeff Lowenfels jeff at gardener.com
Sun Jul 7 20:00:07 EDT 2002

Folks, this is a long message, but one I feel is very important for all of
us to read, read carefully and do something about...especially those of us
in the US. If it happens here, it can spread to Australia, Holland, New
Zealand and the other non-US locations that have members on this list.

I am a lawyer in another life and I agree that the process here is faulty
and can be legally challenged with a high degree of probability of success.
However, the costs and the time involved are high. It will be much easier to
defeat this now. Write your congressmen and your senators. All have email.
Attach Dr. Elaine's correspondence but say this in your main message"


I need your help. The USDA's National Organic Standards Board is about to
arbitrarily set a standard that will impact me, my business, thousands of
your constituents, organic gardening and farming in general and a growing
domestic industry making.

The specific issue involves nutrients for making compost teas. Sugars are
being banned. Studies that were supposed to have been the reference were not
seen by members of the task force and scientific standards were not

Please bring the power of your office to bear on this issue. I am asking you
to contact the NOSB individuals (NOSB is a USDA/Congressional creature) and
demand an explanation and reexamination of the issue with FULL public

The individuals involved are:

NOSB and compost task force contacts
Eric Sideman (task force member): esideman at mofga.org
Zea Sonnabend (task force member): zea at well.com
Owusu Bandele (NOSB member; crops committee chair):
obandele at su.jags.SUBR.edu

USDA/AMS/NOP contacts
Richard Mathews (NOP manager): Richard.Mathews at usda.gov
Barbara Robinson (AMS administrator):
Barbara.Robinson.AMS at usda.gov


Big voter and contributor and grassroots organizer who will get you if you
don't help me.


The attachement you might want to add is as follows:

Subj:Scientific evidence
Date:7/6/2002 3:01:34 PM Pacific Standard Time
To:esideman at mofga.org
CC:Obandel, jriddle at luminet.net, nosb.crops at usda.gov, bobpooler at usda.gov,
de.carter at attbi.com, info at soilfoodweb.com

July 6, 2002

Dear Mr. Sideman and others -

It is unfortunate that the COMPOST recommendations were tied to
recommendations about compost TEA, and that the compost tea recommendation
was so off the mark.  The recommendation to limit the use of sugar, molasses
and soluble carbon materials in compost tea has to be excised from the
revision to the NOP, because the recommendation-making process was so
completely flawed.  The lack of solid science requires that this part of the
decision be removed.

Last April, I was told scientific research papers were used as the basis of
the decision of the Compost Task Force.  Certainly the recommendation sent
to the National Organics Standards Board suggests that science was actually
reviewed in making the decision.  I, and many other people, asked for the
papers that the recommendation was apparently based on, at the time the
recommendation was released by the Compost Task Force.

Will Brinton wrote me in an e-mail sent just last week that four papers were
used to develop the recommendation from the Compost Task Force.  But, NONE
of the members of the Compost Task Force can show anyone these research
papers.  Will Brinton has not supplied anyone with these papers.  No one on
the NOSB or in the National Organic Program knows anything about these

In an e-mail that I received just two days ago from Eric, it was revealed
that the members of the Compost Task Force never received these papers.  The
Compost Task Force made their recommendations based on conversations and not
on the basis of any written scientific evidence.

Two months after the fact, we discover that these papers were never seen by
anyone on the task force, that, in fact, no documents were reviewed to make
these decisions.

It is difficult to believe that a decision about compost tea, a decision
that could affect millions of people, was based on a conversation with only
Will Brinton and Pat Milner.

Neither Will Brinton nor Pat Milner have significant experience with the
new, 24-hour compost tea brewing machines.  Will Brinton has experience with
long term tea brews, ones that take 3 weeks, for example, but not the newer
24-hour technology.  I respect Will greatly for his knowledge on compost,
but to ignore a great deal of other expertise about newer technology for
compost tea in making the recommendation was inappropriate.

I am not aware that Pat Milner has any knowledge base involving compost tea.
The compost group at the USDA that she heads may have funded two studies
that were presented at the recent Biocycle meeting in Ohio.  But, the
materials produced in the two studies were not compost tea, did not meet the
definitions of compost tea, and at least one of the studies has serious
flaws from a scientific point of view.  Neither study makes Pat Milner an
expert in compost tea by any means.

There is a broader knowledge base about both compost and compost tea in the
United States than these two people.

It was not a wise decision to base any recommendation to the National
Organic Standards Board (NOSB) on the opinions of two people who do not have
the breadth of experience required in this area of science.

Regardless of whether Pat and Will can now produce the papers on which they
based their opinions, the recommendation by the Compost Task Force on
compost tea was not based on science involving compost tea and should be

Any decision made must be based on sound science, and clearly, this
recommendation was not based on a review of all the facts.  Regardless of
whether the Task Force still stands behind the recommendation, the
decision-making process was flawed, inappropriate and cannot stand.

The basis of the process of review and development of recommendations and
rules in the National Organic Program had better be reviewed as well.  Rules
that will affect many, many people are being based on conversations, not
real science, with people who do not represent the full spectrum of
knowledge in the United States, much less the world?

Any EPA, USDA, UN, NSF or FDA group or committee I have been involved with
has always had the supporting evidence available for people who wish to see
the basis of any decision.  If important data are not available for review,
then the decision must be set aside for consideration at a later date.  ALL
pertinent information needs to be considered.  Hasty and ill-considered
decisions will result in unacceptable situations, such as the one we are in

Perhaps those people who are volunteers for the NOP need to be instructed
about the requirements necessary for making decisions, and the written
evidence necessary to support those decisions.  The conversations with Pat
Milner and Will Brinton should have been recorded.  The evidence they quoted
should have been collected for the committee to review BEFORE making any
recommendation about compost or compost tea.

Policy for the entire nation could be set based on this recommendation.  It
is an awesome task, and should be treated as such.  Decisions that affect so
many lives cannot be based merely on a conversation with two people.

Two of the four papers mentioned by Will Brinton as scientific evidence were
presented at a Biocycle meeting in Ohio in May 2002.  This was not a meeting
of a scientific organization.  The papers were not peer reviewed.  The
people who review papers for Biocycle meetings are, based on an e-mail from
Nora Goldstein at Biocycle, herself and Bob Rynk, who is an employee of
Biocycle.  This is not scientific peer review.  These papers have not gained
approval from the scientific world.

Seven days AFTER the Compost Task Force forwarded their recommendation to
the National Organic Standards Board, these two papers were presented at the
May 2002 Biocycle meeting.  So, papers that were not reviewed in any way by
the scientific community, that were never seen by the committee so the
science could be assessed, were used as the basis of the Compost Task Force

Letters of support were written for these studies?  These letters of support
are being used to state that the majority of the Compost Task Force stands
behind the recommendation?  Did the Task Force see these letters?

If letters of support were written for the not-peer reviewed studies never
seen by the committee, let's see those letters too.  If I point out problems
with a piece of science and the people who did the science get to rebut my
points, the very least that should happen is to ask me to respond to those
rebuttals.  Is seems clear that someone wants to restrict this decision to a
very limited set of opinions, not on a full basis of understanding the
information available.

What happened to transparency?  Clear and open communication?  In my
opinion, and I hope in the opinion of others, what has been discovered here
constitutes a clear violation of the decision-making process that should
occur in these situations.

If any credence is placed on these letters, they had better be from
independent researchers.  Pat Milner's group at the USDA gave BBC Labs money
to do work on compost and compost tea.  Any letter of support from BBC Labs
has to be viewed as too strongly influenced by the relationship to be
counted as independent support.

Any "letter of support" from any USDA lab has to be viewed as questionable
as well, because of the bias that Pat Milner imposes on people in her area
of influence in the USDA.  These "independent researchers" may well be
dependent on her to obtain continued funding.  Letters of support about the
credibility of any science performed require external, not-involved
reviewers.  Letters of support from people who did the questionable work is

Let's have a panel of non-biased, not-previously involved experts in water
aeration technology, in the growth of E. coli in environmental conditions,
and sewage treatment processes assess the quality of these papers and of Pat
Milner's program at the USDA.  Let us have this whole process done with
transparency and open and clear communication.

No more hiding the fact that there were no scientific papers on which the
recommendation was based.  No more secret rebuttals used to dismiss valid
scientific concerns.

There is something very fishy going on here.  Something is being hidden.

Without a chance to see these responses that "heavily rebutted" my concerns,
I don't know for certain what I need to say in response to them.  Let me
point out, however, that Pat Milner has been reported to me as telling
people that I do plate count assessments.  That is laughable.  I use direct
count assessments, no indirect methods.

I am the head of a research and testing lab in Corvallis Oregon.  I was at
Oregon State University for 15 years, as a research fellow, an assistant
professor, and an associate professor both in Botany and Plant Pathology,
and in Forest Science.  I released my position at Oregon State University in
December of 2001, because I prefer working with growers doing real
production methods.  I teach people how to grow plants without the use of
pesticides or inorganic fertilizers, by getting back the soil and foliar
organisms they need.

My work at Oregon State University since 1994, and after leaving the
University at the end of 2001, has given 24-hour compost tea scientific
credibility.  I have worked on the microbiology of liquids, soil and
numerous amendments both solid and liquid, since the mid-1970's, and
continue to work on compost tea extensively.  I have published a
peer-reviewed Manual on compost tea, but have not published my work about
compost tea in the scientific peer-reviewed literature YET, because there
are many, many parameters that go into making compost tea that can,
reliably, prevent disease, improve nutrient availability to plants, build
soil structure and decompose toxic materials.

When I satisfy my own sense that we have the correct set of parameters
understood, then I'll publish in the scientific literature.

I have been given to understand that people have been told that I haven't
published anything, but please, go look at my long list of peer reviewed
papers, book chapters, and publications on my website, www.soilfoodweb.com.
I haven't updated my list of publications since 1999 because it isn't the
top priority thing I do anymore, but you'll get an idea about what I do.

If you read my papers, you will realize that I have written a great deal
about the paradigm involved with why compost and compost tea provide the
benefit to plant growth that they do.  Just because I haven't written
anything titled "Compost Tea Saves the World" doesn't mean I haven't written
about why compost tea works.
But now, let's go through the problems with the two papers presented at
Biocycle that are being used as the basis for the Compost Task Force
recommendation.  The BBC Lab paper contains flawed science.  Neither paper
addressed issues with compost tea, because in neither paper was compost tea

A note about E. coli in compost is needed here.  E. coli contaminated
organic matter should have nothing to do with compost tea.  By definition,
compost must be used in compost tea (ahem, that's why we call it COMPOST
tea, not manure tea, not stinky straw tea), and therefore, by definition,
there should be no E. coli present.

Testing should be required to show that no E. coli is present in compost.
Clearly, that means, the compost used for compost tea should have no E. coli
in it.  To make up a rule about the food resources that can be put in tea,
based on the fact that manure or some such pre-compost material was used, is

In the instance of the Duffy et al. paper, E. coli contaminated organic
matter (sounds like manure to me) was placed into vessels which were then
sealed.  This sealed condition has nothing to do with any compost tea making
machine on the market.

Long before Duffy's work was done, people have known that spraying E. coli
contaminated material would result in the E. coli being spread to the
material sprayed.  Read the sewage treatment and bio-solid literature.  This
paper does not apply to the production of compost tea.  It is nonsensical to
use this "evidence" as something to limit what food resources can go into
compost tea.

The second paper, from BBC Labs, has at least three MAJOR flaws in the
science.  There are major flaws in the statistics used (a University
statistician was asked to review this paper and they were very critical of
the approach used.  I can e-mail you the analysis if you want it), in the E.
coli contaminated organic matter used, and in the data about oxygen.

Compost was not used in this study.  Pre-compost material, that I interpret
to mean putrefying organic matter, containing E. coli, was used.  However,
no data on the E. coli levels in the "compost" were given in the paper.
This paper would never pass scientific peer review, because of the lack of
data about the numbers of E. coli in the starting material, and the
inappropriate statistical analysis used.

Ms. Bess claimed that E. coli grew in the aerobic conditions in this tea
maker.  For that claim to be true, oxygen concentrations must be given.  The
data given in the paper purporting to show that the liquid was aerobic have
nothing to do with the tea in which the E. coli were grown.  The evidence to
say this is in the paper.  If you don't believe me, show the data to someone
who works with water and aeration.  Don't depend on the people doing the
study to "rebut" my criticism.

Perhaps a bit of an aside about oxygen concentration in water would be
useful here.

It is not possible for water to contain more oxygen than the saturation
level of oxygen in water.  Check any text book about oxygen in water.

The maximum amount of oxygen in water changes with temperature and
The higher the temperature, the less oxygen can be held in water.  The
higher the elevation, the less oxygen in the water.  Because air pressure
and thus the partial pressure of oxygen is less as elevation increases,
water cannot hold as much oxygen at higher elevations.

Attempts to force more oxygen into water than water can hold under the given
temperature and pressure conditions (elevation) are not beneficial to
organisms in that water.  E. coli could not survive if the water was
super-saturated with oxygen.

The BBC Lab write-up showed that the temperatures used in production of the
"compost tea" were in the range of 21 to 27 degrees Celcius (Table 2 in the

The dissolved oxygen concentrations stated in the BBC Labs paper were 10.1
to 10.9 mg/L.  These levels are not possible, based on the temperatures
given in the paper.  There is no way dissolved oxygen in water at 21 to 27
degrees Celsius, at around 2000 feet elevation, could have dissolved oxygen
concentration readings that high.

The maximum possible oxygen concentration in the place and time the
experiment was purported to have performed is in the range of 8.5 to 9.1

Therefore, the oxygen data given in the paper are for something other than
that brew where E. coli was detected.  There is no evidence that the tea
brewed by BBC Labs for this study remained aerobic.

If perchance the water was super-saturated with oxygen, which is the only
way this brew could have oxygen concentrations as high as reported in this
paper, there is no chance that E. coli could survive to be detected.

Did the brew go anaerobic?  You do not know, I can't tell, and neither can
BBC Labs.    The science is flawed, because they did not take oxygen
readings on the brew they made for this experiment.

Any post-experiment re-do is not acceptable.  To take oxygen readings from a
tea maker in Eugene, Oregon and call it representative of what was done in
Tempe, AZ is not acceptable.  The experiment has to be re-done, and adequate
controls have to be included.  E. coli presence in the "compost", in the
sugar, in the yeast, in the fish, etc BEFORE BREWING have to be documented.
Oxygen must be monitored in the brews where the E. coli testing is being
done.  The presence of other bacteria, fungi and protozoa must be

Good compost has all kinds of bacteria, fungi, protozoa and some nematodes.
If the "pre-compost" material used by BBC Labs, and by the USDA Albany CA
Lab did not contain adequate numbers of other organisms, then E. coli would
be able to grow because the liquid is not compost tea.

Everything we have done indicates that when millions of other bacteria and
fungi are present and competing with the E. coli, oxygen has to be
significantly reduced in order for E. coli to grow.  Talk to sewage
treatment microbiologists about this.  This is not unknown, novel or
astounding information.

But hear me when I state the necessary conditions.  Competing organisms,
aerobic conditions, good compost, food resources for the competing organisms
to grow.

Neither am I talking about the situation in a plate count for E. coli.
Those conditions select for E. coli through the use of selective chemicals,
such as antibiotics or particular food resources like blood agar.  E. coli
can grow, albeit poorly, in aerobic conditions but only when other
conditions are optimal.  For example, the correct temperature, the right
foods, and no competing organisms.

Our current research is showing that if compost tea is kept aerobic through
the whole tea brew, E. coli never appear, regardless of whether sugar,
molasses or other soluble organic materials are used.  Of course, compost
has to be used.

If E. coli is in any material used in the tea brew, and the tea goes
anaerobic, E. coli is likely to grow, regardless of the addition of sugar,
molasses, or soluble carbon materials.  But, BY DEFINITION, 24 hour brew
cycle compost tea should be completely aerobic.  It should not be allowed to
become anaerobic.

If you are going to make a rule specific to compost tea, the rule should be
made that 24 - hour compost tea must remain in aerobic ranges through the
whole 24 hour production cycle.

But there is more to the story.  We're doing research that shows ONLY if the
tea is driven anaerobic, can E. coli GROW, that is, increase in number of
individuals.  For this to happen, anaerobic conditions must develop as the
result of rapidly growing bacteria and fungi using over-supplies of added
food resources, and using up the oxygen as they grow.  Addition of foods
that the organisms in the aerobic liquid will not use results in the water
staying aerobic.  The organisms don't use up the oxygen if they don't grow

If you continue to aerate "tea" that has high numbers of E. coli, the
numbers of E.coli will be reduced.  For example, in liquid that has 44,000
E. coli per 100 ml, produced through anaerobic brewing, the number of E.
coli will be reduced to 870 individuals if aeration is continued for the
next 20 hours.

Can we reduce E. coli numbers to undetectable levels?  We have some data
that indicates it can be done, but we need to work out just what conditions
in compost tea production allow achievement of removal of E. coli, even if
the starting material has E. coli in it.  Again, not novel, not astounding,
this is done in sewage treatment plants all the time.

I believe that Will Brinton gets these same results when he brews tea for
several weeks.  He hasn't documented these results that I am aware, but I
haven't read everything there is to read.  Early in the tea cycle, the tea
MAY go anaerobic if enough food resource is added to get the bacteria and
fungi growing rapidly enough to use up the oxygen in the water.  But then
the organisms run out of food, they go to sleep, stop using oxygen up, and
oxygen diffuses slowly back into the tea.  By the time the tea is used,
three weeks later, it is fully aerobic again, and the E. coli, if they grew
early in the brew cycle, were inhibited, consumed and removed by the
increasing aerobic conditions, by the other organisms that grow in the tea
as oxygen returns to the brew, etc.

I hope that I've made it clear that making a ruling about food resources
used in compost tea at this time is not wise.  The Compost Task Force did an
insufficient study of the science of compost tea.  The recommendation made
about compost tea should be removed from the revision of the rules.

Should there be a ruling about compost tea made in the future?  Most likely.
But base it on a full understanding of all the factors involved in making
compost tea.

Please realize that there are not only 24 hour brews, but 12 hour brews and
48 hour brews, and 10 day brews and 3 week brews.  There is a machine that
makes non-stop, continuously extracting compost tea.  There are four
commercial tea machine-making companies on the market, and you need to test
each of their machines before making a rule about what food resources should
or should not be put in their machines. The machine that Pat Milner had
tested at BBC Labs was a prototype machine from one machine manufacturer
only.  That unit is not even available on the market any more.

There are compost extracts and compost leachates.  What about them?

If the NOP moves into this area, they have to address:
1.  the definition of compost tea,
2.  length of extraction and mixing times
3.  aeration conditions,
4.  the quality of the compost used to make the tea,
5.  the kinds of foods added to the tea to grow bacteria and fungi,
6.  how bacteria and fungi affect the protozoa and nematodes extracted into
the tea
7.  interactions of temperature, aeration, the kinds of bacteria, fungi,
protozoa and nematodes present in tea (and the compost) and the nutrients
present in the tea
8.  nutrients added to the tea to relieve plant nutritional stress

There are more factors, but I think you get the point.  The ruling on
compost tea was unwise.  The Compost Task Force was misled to believe that
compost tea production was so simplistic that a recommendation such as they
made could apply to all compost tea production.  Please, don't base a
decision on such a limited amount of input.


Elaine R, Ingham
President, Soil Foodweb Inc., Corvallis, OR
Treasurer, Illinois Tilth
Director, Sustainable Studies Institute, Eugene, OR
Affiliate Faculty, Graduate Research Studies, Southern Cross University,
Lismore, AU
Director of Research, Soil Foodweb Institute, Lismore, Australia
Research Director, Soil Foodweb New York

Hard copy to follow
In a message dated 7/4/2002 5:34:26 AM Pacific Standard Time,
esideman at mofga.org writes:

Subj:Re: Request for information has been ignored
Date:7/4/2002 5:34:26 AM Pacific Standard Time
From:    esideman at mofga.org (eric sideman)
Reply-to: esideman at mofga.org
To:    Obandel at aol.com
CC:    jriddle at luminet.net, Soilfoodweb at aol.com, nosb.crops at usda.gov,
bobpooler at usda.gov, de.carter at attbi.com

Hi Owusu, I am sorry I did not reply to your first request.  It is buried in
a pile of emails that built up while I was doing farm visits.  I am working
on my pile from the most recent back. We, the Task force, do not have copies
of the research. We based our decision on discussions during conference
calls. Will Brinton and Pat Milner presented the information.  We have heard
much disagreement from Elaine Ingham but it was heavily rebutted by Wil and
Pat and supportive letters they got from research labs.  A majority of the
Task force stands with its original recommendation.  If you want to see the
research papers please contact Wil and Pat. I am perfectly willing to have
that area of our recommendation on the use of compost teas reconsidered.
BUT, PLEASE let's not hold up the action on compost because of the compost
tea issues. At this time, I have sent a draft policy statement to NOP for
their consideration.  Barbara Robinson has asked me ! to do this and she
said the NOP would review it and post a policy.  I sent it on June 4 and
still have not received a response even though I have repeatedly asked about
it and Barbara said they will work on it. This area is perhaps the second
biggest problem certifiers and growers have (next to inerts).  Certifiers
around the country are enforcing different levels of restrictions on
composting and this is very unfair to growers. I hope the NOSB can help push
NOP into posting our recommended policy, even if the tea section is removed
for further discussion. Eric

Obandel at aol.com wrote:

Hello to all;
As crops committee chair, I was a part of the compost tea task force.
Although I think that the task force work was a vast improvement over what
is  now  in the rule,  I did not and do not agree that molasses and other
natural sweeteners should should be prohibited from being used in the
compost tea making process.  In fact, I am not sure that molasses  could be
prohibited from being used without it being added to the national list.  I
have raised this issue with Richard Mathews on more than one ocassion, but I
have not yet received his interpretation on this. I  also requested to see
the documentation of scientific evidence upon which the aforementioned
recommendation was based, but I never saw it to date.  Last week, I
requested the same from Eric Sideman who was Compost Task Force Chair.  As
soon as I receive it, I will pass it on to all parties who have requested

PLANT A ROW FOR THE HUNGRY: Through PAR, over 3 million pounds of food have
been donated by home gardeners like you to feed the hungry. Ask me how you
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