Many organic farmers and livestock producers were intimately involved in the process that created the National Organic Program. They wanted a set of national, harmonized regulations, and the vast majority of them, from operators of five-acre family farms to managers of large-scale operations, are already in compliance with the NOP or on track to be there soon.
But life under the umbrella of a federal authority will take some adjustments, and will change the culture of organic farming. Although the nationwide regulations pose some immediate challenges, most producer concerns are beyond the horizon: how actual implementation will occur and how the industry will bear enforcement costs.
Paperwork has always been part of organic certification, but submitting forms to federal agencies might be a burdensome adjustment for many farmers, especially smaller ones. "It's gonna be about as much fun as filing your IRS forms," said Cissy Bowman, who farms on seven certified organic acres and runs Hoosier Organic Marketing Education, an education and consulting group in Clayton, Ind.
In the past, farm plans and organic operations details could be more narrative. "An organic farm plan has always been part of certification, but now this is a plan that [must include] specific characteristics as determined by the rule," Bowman said. "For those people who've been certified for a long time, it won't be as much of a no-brainer."
The NOP also uses some alternate definitions for products and processes. For example, the term compost now means something different. The rule includes the Environmental Protection Agency definition and involves composting production methods outside the ability of many small-scale producers, such as heating to certain temperatures, having verified mineral ratios and criteria for number of times to turn.
Some seemingly subtle changes made to the certification requirements as part of the new rule will also be challenging for farmers. There are generic and branded farm inputs that organic producers were accustomed to using that are not on the national list, said Kathleen Downey, director of the Organic Materials Review Institute, based in Eugene, Ore.
The way the program is designed, someone has to petition for anything synthetic, benign as it may be, to be reviewed by the Department of Agriculture. "No matter what it is, if it's synthetic and not on the list, it can't be used," Downey said.
Another concern for producers of all sizes is seed procurement. "We're trying to grow vegetable varieties that are commercially viable," said Denesse Willey of T & D Willey Farms in Madera County, Calif., "and getting that seed untreated is tricky."
Most seed companies use fungicide preservative sprays in their warehouses. Organic certification companies formerly allowed producers to use seed that had been treated if untreated seed wasn't commercially viable. The NOP doesn't make that accommodation.
"The federal requirements on organic and untreated seed are a real challenge to producers," said Brian McElroy, certification services manager for California Certified Organic Farmers, based in Santa Cruz. Seeds that haven't been sprayed are hard to find, and with the new federal mandate, farmers are forced into a bad bargaining position. "If you think about the economic food chain," McElroy said, "the farmer is on the bottom. They're price takers, not price makers."
Small producers will be squeezed if they can no longer obtain seeds for popular vegetable or fruit varieties. Large operations can be pinched as well, according to McElroy. If the seed cost per acre doubles, those farms can't just pass along that cost.
Beyond adjustments and minor challenges, costs associated with certification and specifics of implementing the program are what concerns farmers. "In order to pay for federal enforcement, you have to assess somebody," Wiley said. And under most certification systems, assessments are capped at a certain level, so in effect, those costs come at a lower rate for larger producers.
In fact, the new costs associated with certification may push many small farmers to abandon their organic program. Growers whose income is just above the $5,000 gross minimum face a tough decision, said Ray Green, supervisor with the California Department of Food and Agriculture. Those who have been certified in the past must decide if they can afford to pay as much as 10 percent of their gross income to certification agencies. Those who used to sidestep the issue by selling their produce to packing sheds, instead of boxing, storing and marketing it themselves, now have to be certified and incur the extra cost.
Even for those who participate in the program, further problems loom. It will take a couple of years for some implementation specifics—such as access to pasture for livestock or crop rotation requirements—to be worked out, said McElroy of CCOF. "It's going to be awkward for awhile to sort out how we implement this thing consistently, given how broad the language is."
Series Part 1: Retailers Ready For The National Organic Program
Series Part 2: Fine Line Between Certification And Responsibility For Organic Retailers
Series Part 3: NOP Just For Food Products
Series Part 4: Certified Organic Delis Offer Opportunities And Challenges
Series Part 6: Federal Program Little Help For Foreign Trade
Series Part 7: National Program a Culture Shock for Certifiers
Series Part 8: Distributors Score High Marks for Organic Commitment
Series Part 9: California Retailer Turns a New Leaf on Organic Retailing
Series Part 10: Consumers Know Not What They Eat
Natural Foods Merchandiser volume XXIII/number 5/p. 7