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  • From: Road's End Farm <organic87 AT frontiernet.net>
  • To: Market Farming <market-farming AT lists.ibiblio.org>
  • Subject: Re: [Market-farming] clarification of use of "organic"
  • Date: Fri, 9 Sep 2011 22:49:48 -0400


On Sep 9, 2011, at 10:14 AM, Vern and Amy wrote:

Thanks, Rivka!

If I thought it would pay to be in the system, I might join. Right
now, my markets are small enough all our customers are happy when we
honestly say that we can't use the word "organic", but we grow the same
way. Before we started, I asked a larger vendor about it, and they said
they were sticking with NOP, but if they were starting out knowing what
they do about the paperwork, they wouldn't join.
Someone else in the system said inspectors don't know what you are
spraying when the inspector is not there--and I know that person doesn't
cheat. Not knowing may change somewhat with a testing new rule. I also
know a conventional grower who tells customers "I am as close to organic
as you can get." I think he means "I am as close as *I* can get!"
Which explains why we have NOP.
Then we have certified growers who buy starts from another certified
grower who buys in conventional stuff for resale. He doesn't advertise
that as organic, but people assume or knowingly cut corners because
"organic" starts and seeds are too expensive. I'm not going to rat
people out--it isn't my system.

Vern

Depending on what you're spraying when, the inspector may see direct evidence of it. The inspector also can and probably does go through barns and storage spaces, and also through farm purchase records; so it's not just a matter of whether you're spraying at the moment, but of what materials you have on hand, and what materials your records show you as buying. They check whether you have the equipment, and/or the hands, likely to be needed to accomplish weed or insect control by the techniques you say you are using. They know what actually organically managed land looks like, in a lot of different permutations and conditions. And they are entitled to do surprise inspections.

Could somebody cheat anyway? Possible, I'm sure. But not nearly as easily as by just not spraying while the inspector's on a scheduled visit; and not without taking a significant chance of getting caught.

The problem with testing for unaccepted substances is that, without a clear suspicion of something to test for, it's just plain impractical. If the certifier suspects that the farmer used something in particular, or if a neighbor or customer reports such a violation, then it makes sense to test. Otherwise: there are thousands of possible contaminants. Testing for any one of them can cost anywhere from tens to thousands of dollars. It would be possible to spend hundreds of thousands of dollars running tests -- and still miss testing for a specific item that was used. Or the item could have been used long enough ago that it doesn't show up on the test.

Random screening of samples of both organic and conventional produce for some of the most likely substances can make a certain amount of sense; some things are much more used than others, and such testing can turn up useful information. But why test only the organic produce? Conventional growers are allowed to use more substances; but they're supposed to be using only certain items, on certain crops, within a certain amount of time before harvest, and at no more than specified rates. If we're going to test organic produce to make sure it doesn't have a specific pesticide at more than background levels, shouldn't we also be testing conventional produce to make sure it doesn't have the pesticide at greater than allowed levels, or on crops it's not supposed to be used on at all? Some of this is done, of course, in both cases. It's certainly arguable that more of it should be done. But it needs to be done in a sensible and even-handed fashion; not in such a way as to put small growers (conventional or organic), or organic certification agencies, out of business.

Oh -- and if I were buying transplants from a grower who sold both organic and conventional transplants, I'd be required to have invoices stating clearly, in writing, that what I had bought was the organic ones; and the agency inspecting the transplant operation would be checking to make sure that the grower had methods of keeping the two separate that satisfied the agency. If the people you're talking about are certified, either some specific certifying agency is falling down badly on the job, or the transplant grower and the purchasers are illegally conspiring with each other (the transplant grower would have to be providing invoices that falsely state both the price and the organic status of the transplants, and the buyer would have to know this was false if the buyer was in fact paying a cheaper price); in which case, sooner or later somebody very likely is going to "rat" on them; and ought to, in my opinion. They are deceiving and stealing from every purchaser down the line, and from every organic grower who actually is following the rules. -- a competent inspector may well notice something funny, eventually, if they're making any sort of habit of this. The number of transplants they're claiming to sell in each category won't add up with what is actually in the certified and noncertified greenhouses, or in the certified greenhouses and on the outside purchase receipts. People do get caught; though sometimes it takes a while.

If your markets are happy without your being certified, I wouldn't recommend that you bother; in your case it would be an expense for no benefit. But, while the paperwork is indeed a bear, I've found the better recordkeeping that it requires actually very useful to me in other ways.


-- Rivka; Finger Lakes NY, Zone 5 mostly
Fresh-market organic produce, small scale





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