Food safety has never been a more critical issue for the entire food industry. The increasingly common outbreaks of foodborne illnesses over the past decade have led to a growing concern surrounding the safety of our food. It is today’s reality that more stringent food safety regulations are here to stay. For the organic sector, the good news is that organic systems have always relied on effective preventive practices to maintain organic food’s high safety standards.
Organic producers and handlers have excellent management protocols in place, access to crucial and organic-
compliant tools for preventing foodborne illnesses and are at no disadvantage in terms of food safety. Organic producers, in fact, are ahead of the curve: The preventive control methods required under organic regulations are in line with the U.S. Food and Drug Administration (FDA)’s preventive approach in its new food safety regulations. Furthermore, organic growers and handlers are inspected at least once a year, and ingredients and products can be tracked from the farm to the grocery store shelf because of the traceability requirements included in organic regulations.
The Organic Trade Association (OTA), the membership-based business association for the organic industry in North America, was an early adopter of food safety reform. Recognizing the essential role food safety plays in organic food production and the unique requirements of organic regulations, OTA was fully engaged in the legislative process leading to congressional passage of the sweeping Food Safety Modernization Act (FSMA).
In 2009, OTA launched a Food Safety Task Force to track and analyze pending legislation for any impact on the organic sector. OTA lobbied the Senate Health, Education, Labor & Pensions Committee staff and several Senate offices to include language in the Produce Safety Rule prohibiting any new regulations from contradicting or duplicating the requirements of the U.S. Department of Agriculture’s National Organic Program (NOP). OTA’s efforts were successful, and the final version of FSMA signed into law on January 4, 2011, included language to this effect.
A New Focus for FDA on Prevention and Produce
FSMA amends the Federal Food, Drug, and Cosmetic Act concerning the safety of the food supply and is aimed at helping prevent food safety problems by shifting the focus to food contamination prevention rather than responding to outbreaks. This represents the most significant reform of food safety law in 70 years. In addition to giving FDA new enforcement authorities and new tools for managing imported foods, FSMA requires food facilities to identify potential food safety hazards and to develop and implement preventive control plans. It also requires FDA to create new federally mandated food safety regulations for fresh produce farms growing fruits and vegetables.
FSMA’s enactment marks the first time FDA will have real authority to regulate food production and handling on farms growing produce. For the organic sector, the language in FSMA specifically addressing organic growers is of critical importance and has become the major focus for organic stakeholders. Consistent with OTA’s work on FSMA legislation, FSMA requires the produce standard to avoid conflict with or duplication of NOP regulations, and to take into consideration conservation and environmental practice standards established by federal agencies. Also of significant importance, FSMA requires all regulations to be scale appropriate and science based.
Over the course of 2013, FDA released multiple proposed rules for public comment. The Produce Safety Rule establishes science-based standards for growing, harvesting, packing and holding fresh produce on farms. The Preventive Controls for Human Food Rule requires that food processors implement controls that prevent food contamination with human pathogens. Subsequently, FDA released proposed rules addressing preventive controls for animal food, the safety of imported foods and accreditation of third parties to conduct inspections on FDA’s behalf. This group of proposed rules reflects FDA’s preventive approach to food safety established by FSMA.
In 2013, following the release of these rules, OTA reconvened its Food Safety Task Force to prepare comments on behalf of organic stakeholders. OTA’s focus was to ensure that proposed food safety regulations reflect the law and fully take into account organic practices. Accordingly, the task force’s mandate was to analyze the proposed rules and ensure that they 1) do not duplicate or contradict organic methods and materials; 2) are science based; and 3) do not put an unnecessary burden on organic producers and handlers.
Widespread Concerns about the Produce Rule
FDA’s proposed Produce Safety Rule requires farms that grow, harvest, pack or hold fruits and vegetables to establish and follow science-based standards for the safe growing, harvesting, packing and holding of produce in its raw or natural (unprocessed) state. FDA proposes to set standards associated with identified routes of microbial contamination of produce, including agricultural water, biological soil amendments of animal origin, health and hygiene, animals in the growing area, equipment, tools, buildings and sprouts.
The Real Dirt on Manure and Compost
Many organic farmers rely on compost and manure as their main fertility inputs. Compost and manure do not necessarily serve the same purposes on an operation, however, and each poses different levels of food safety risk.
Manure generally contains more plant nutrients and is considered more of a fertilizer than compost. Compost, on the other hand, generally contains lower levels of plant nutrients than manure but higher levels of stable organic matter, which has benefits for soil structure and soil health. Both plant nutrients and stable soil organic matter are essential for a successful organic farm.
Manure
Animal manure has been used as a fertility input on farms since the dawn of agriculture and remains the most important fertility source on organic farms today. Manure comes from a variety of sources, and each source has its own characteristics. Poultry manure is generally higher in plant nutrients, like nitrogen, phosphorous and potassium, than other types of manure but lower in organic matter. The high levels of nutrients in poultry manure can damage crops and must be carefully managed.
Conversely, cattle manure is generally higher in organic matter and lower in plant nutrients, so its use has a lower potential to damage the crop, but higher application rates are required to meet the crop’s nutrient demands. Untreated manure of all types has the potential to pose a food safety risk, and farmers, organic and conventional alike, have traditionally mitigated this risk by applying manure to their fields early in the season before they have planted the crop.
U.S. Department of Agriculture organic regulations have established regulations on appropriate waiting times, and now all organic producers must wait either 90 or 120 days to harvest their crops following the use of untreated manure, depending on whether the crop has contact with the soil (90 days: think cherries or apples; 120 days: think lettuce or carrots).
Compost
Actively managed, aerobic composting is distinct from the unheated backyard compost bins many homeowners incorporate into their gardens. Active composting requires that all feedstock (these are the inputs into a compost pile like manure, food waste and yard debris) reach a certain temperature within the pile for a certain length of time. Temperatures in an actively managed pile must exceed 131 °F, and must continue for a length of time appropriate to the type of compost pile made (either 3 days for static aerated piles or 15 days for turned windrows). These temperatures eliminate human pathogens while allowing beneficial compost and soil organisms to flourish. While the pathogen-reduction aspect of compost lowers its inherent food safety risks, often compost cannot satisfy crop nutrient demands and additional fertilizers are required.
Compost and manure both serve critical functions in organic agriculture. They are not necessarily interchangeable, however, as compost usually does not contain the same concentration of plant nutrients as manure. FDA’s alignment with NOP standards on the use of compost recognizes the reduced food safety risk that composting can provide to public health, and FDA’s decision to defer final decision on its previously proposed 9-month minimum application interval for manure shows the agency’s recognition that manure plays its own unique role in providing organic crops with adequate fertility.