About Certification
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Frequently Asked Questions about "Going Organic"
Can I use non-organic manure on my certified organic farm? If so, are there any restrictions?
The Canadian Organic Standards (COS) ask farmers to feed their soil in
a number of ways. The basis of a farm’s fertility regime should be from
the farm. A good rotation that includes legumes, cover crops, and
supplementation with your own organic compost or manure (ideally from
animals fed crops grown on the farm) are all on-farm sources of
fertility. However, many farms are not able to be completely self
sufficient in their nutrient needs. Farms may not have livestock (or
not produce enough manure for all their crops), space or cropping
considerations may limit the use of nitrogen-fixing cover crops, and
even those farms with their own animals will still likely import some
feed or supplements. So, off-farm amendments are often necessary and
are permitted under the standard.
For manure, section 5.5.1 explains the best choices are on-farm and
organic. If you don’t keep your own organic animals, off-farm organic
manure can be used. This may be challenging to find, as many farms keep
their organic manure for use on their own crops. You should
contact known nearby organic livestock producers to see if they have
extra manure, and document your research for your CB to review (similar
to an organic seed search). If your research has shown that there are
no local sources of organic manure, or that there is not enough organic
manure for your needs, then conventional manure can be used (with a few
restrictions).
Conventional Manure:
You will need to document your search and confirm with your certifier
that your source of manure is acceptable for use. Manure cannot be used
from animals that are fully caged or are unable to turn around
completely (360 degrees); or from animals that are kept permanently in
the dark. This rules out the use of manure from veal calves or from
pigs kept in farrowing crates, but does allow caged poultry.
If you are using conventional manure, you need to record the following:
• Manure source (farmer, location, type of animal).
• Amount acquired and applied.
• Living conditions of the animal (to ensure the standards criteria are met).
An informative note in the standards states that where possible,
organic producers should use manure from farms in transition to organic
or from extensive operations (where animals are able to graze). Some
farmers keep conventional animals on an organic farm (although as per
section 5.1.2, in these circumstances there needs to be an eventual
plan for transition to organic). One advantage to using this manure is
that the farmer will know exactly how the animals were fed and treated,
and should have records to support their claims. However, organic
farmers still need to look for an off-farm source of organic manure
before using conventional animal manure – even if it is from their own
farm.
Less desirable is manure taken from confinement operations or from
animals that have eaten feed which contains genetically modified
organisms (GMOs). Conventional manure can have residual modified DNA if
the animals are fed GMO feed (usually corn or soy). The modified DNA
can be degraded through the digestive process, so levels in manure are
much lower, although may still be present. Another possible source of
GMO contamination is spilled feed in the manure pack. Conventional
manure is also a source of hormone and antibiotic residues, and
depending on feed, the manure may also be high in heavy metals. Both
organic and conventional manures can be a source of human pathogens
that could contaminate vegetables and fruit.
Section 1.4.1 of the Canadian Organic Standard forbids the use of all
materials and products produced from genetic engineering. This includes
seed, feed and inoculants, but is less clear when it comes to manure
from animals fed GMO feed. Most conventional livestock is fed with feed
that has GMO ingredients. Furthermore, pesticides on crops and
medications that have been fed to conventional animals may appear in
manure.
It is worthwhile to consider section III of the Introduction, which states:
Organic practices and this standard cannot assure that organic products
are entirely free of residues of substances prohibited by this standard
and other contaminants, since exposure to such compounds from the
atmosphere, soil, ground water and other sources may be beyond the
control of the operator. The practices permitted by this standard are
designated to assure the least possible residues at the lowest possible
levels.
So, while the use of conventional manures is not an ideal situation in
an organic system, at present there are not enough alternative organic
sources of fertility available for farmers.
Farmers and Certification Bodies (CBs) must work together to assess
their source of manure and determine the best management practices to
reduce the risk of contamination. If the source of conventional manure
indicates that it is likely to be contaminated by materials listed in
section 1.4.1, then your CB can request that the manure not be used, or
that it be composted before use.
Composting:
Research has demonstrated that composting can reduce pathogens and
different contaminants found in conventional manure. Modified DNA in
both plant material and manure can be eliminated or greatly reduced by
composting. Composting must be done properly to ensure that
the pile heats up so that the microorganisms that decompose at high
temperatures are able to do their job. Adequate moisture, a good mix of
carbon and nitrogen based materials (C:N ratios of 25:1-30:1) and
aeration or turning will help compost reach the necessary
temperature. The pile will also have to be mixed adequately to ensure
that all parts of the pile reach temperatures necessary for
decomposition.
In the Permitted Substances List, it specifies that compost must reach
a temperature of 55°C (130°F) for a period of four consecutive days or
more. A thermometer with a long probe will be needed to check the
inside of the pile, or you can dig into the pile with a shorter
thermometer. You will need to record the temperatures and the dates
that the compost was turned while it was actively decomposing.
If you are composting manure but don’t keep temperature and turning
records, there is another option to prove your product has composted.
The PSL states that you can test the compost to ensure that it is low
in human pathogens. The compost would have to have either a fecal
coliform level less than 1000 MPN / g of total solids or no Salmonella
sp. as measured with a detection level < 3 MPN / 4 g total solids,
both calculated on a dry weight basis. These limits are taken from the
current Canadian Council of Ministers of the Environment (CCME)
guidelines for compost quality. At the end of this document, you can
find the contact information for two laboratories able to conduct this
analysis. If you choose to test your compost, you will need to collect
a representative sample from the pile. Using a clean trowel or spoon,
take 5-10 samples from points throughout the pile, mix these well in a
container, and then take a subsample of the mixed compost for analysis.
Testing should usually be done within 2 days of sampling. Contact the
lab to confirm the sample size, sample handling technique, and price
for analysis.
Raw and Aged Manure:
Raw, uncomposted manure is higher in many nutrients than compost;
however, the nutrients are more freely available and care must be taken
to ensure they are not lost to runoff. Under the organic standards, raw
manure must be applied and incorporated a substantial amount of time
before harvest to minimize the risk of contamination by pathogens. For
crops not in contact with the ground (for example, grains, staked
tomatoes, soybeans) the time between application and harvest is 90
days; if in contact with the ground (for example, root crops, unstaked
tomatoes, squash) then 120 days must pass between application and
harvest. The 120 day rule can be challenging to meet if you are
growing a shorter season crop in a cold region, as you can’t apply
manure too early in the spring to frozen or saturated ground.
Liquid dairy or hog manure is difficult to compost; if you plan to use
it, you will need to ensure that the source is acceptable to your
certifier and follow the 90/120 day rule for raw manure application.
For all types of manure, in your farm records you will need to note the
date and rate of manure application and the dates of harvest. These
rules only apply to crops for human consumption and not for livestock
feed.
If you have manure that has decomposed over time (aged manure) but
there are no records or analysis to prove it meets the COS rules for
compost, then it needs to be treated as raw manure. While it is likely
that some degradation of pathogens and other contaminants has occurred
over time, there is no way to confirm this without lab testing, and the
breakdown may take longer than you think.
Off-Farm Compost Products:
You can use commercial compost, or compost produced at other farms if
the compost ingredients meet the rules outlined in the PSL. Ingredients
can include:
• Animal manures conforming with requirements in par. 5.5.1
• Animal products and by-products (including fish)
• Plants and plant by-products (including forestry and yard waste)
• Soils and minerals in conformity with the COS and PSL
Several materials are identified as not allowed, including sewage
sludge, leather by-products, glossy paper, waxed cardboard, paper
containing coloured ink, among others. The supplier of your compost
should be able to provide documentation that confirms the ingredients
for your CB to review. In addition, any off-farm compost has to meet
the criteria set for CCME Category A compost for trace elements and
foreign matter, and for human pathogens (as discussed above).
Regular soil testing will need to be done to ensure that there is no
build up of metals in the soil from continued compost use.
Although you might see compost or fertilizers in a store using the term
“organic”, be cautious! The Canadian Organic Standard only applies to
food and feed; so compost products cannot officially be certified
organic. However, the US Standard (NOP) does allow certification of
inputs, so you may see compost with a USDA Organic logo. Another group
that reviews products for compliance with organic standards is the Organic Materials Review Institute (OMRI).
Seeing either of these certifications is a good indicator that a
product is likely allowed for organic production, but it’s a good idea
to still check with your certifier first. Other products can still be
allowed if the supplier can show that they meet the requirements of the
COS. Pelletized manures and composts are covered under the PSL under
processed manures. These are dehydrated and can be easy to apply,
although do not add much soil organic matter. Best practices must be
used by the manufacturer to eliminate pathogens; either heating during
pelletization/dehydration, or by composting beforehand.
Either compost or manure can add needed nutrients to your organic soil
while improving texture and tilth. A clear understanding of how the
organic standard applies to these products will give you certainty in
the certification process, and help you build fertility on your organic
farm.
Labs who can test compost for Total Coliform and/or Salmonella
Maxxam Analytics
200 Bluewater Rd., Suite 105 Bedford, NS B4B 1G9
Tel: (902) 420-0203
Fax: (902) 420-8612
Toll Free: (800) 565-7227
(Also have branches in Sydney, Dartmouth, St. John’s)
The cost for analysis can range between about $50 (salmonella) to $100
(total coliform); there is a $150 minimum charge per submission.
A&L Canada Laboratories Inc.
2136 JetStream Rd.
London, ON
N5V 3P5
Phone: (519) 457-2575
Fax: (519) 457-2664
alcanadalabs@alcanada.com
The cost for analysis is approximately $50 for both total coliform and
salmonella. Samples will need to be expedited to the lab. They also
have a useful reference document about compost.
Documents and References
Canadian General Standards Board. The Canadian Organic Standard
(CAN/CGSB‑32.310‑2006) and Permitted Substances List
(CAN/CGSB‑32.311‑2006)
www.tpsgc-pwgsc.gc.ca/ongc-cgsb/programme-program/norms-standards/internet/bio-org/index-eng.html
Canadian Council of Ministers of the Environment. 2005. Guidelines for Compost Quality. PN 1340. www.ccme.ca/assets/pdf/compostgdlns_1340_e.pdf
GMOs and compost:
McLean, N., Matheson, S. and Martin, R.C. Does composting degrade
modified DNA? (Poster) Dept. of Plant and Animal Sciences, Nova Scotia
Agricultural College, P.O. Box 550 Truro, NS, Canada B2N 5E3 www.organicagcentre.ca/DOCs/compost_mclean.pdf
Rasmussen, L.D.; Møller, J. and Magid, J. 2004. Composting rapidly
degrades DNA from genetically modified plants. DARCOFenews (2)
Van Acker, R.C., McLean, N. and Martin, R.C. 2007. Development of
quality assurance protocols to prevent GM-contamination of organic
crops. In Cooper, J. et al. [eds.] Handbook of organic food
safety and quality. Woodhead Publishing, Cambridge.
Pathogens and compost:
Mukherjee, A., Speh, D., Dyck, E., and Diez-Gonzalez, F. 2004.
Preharvest Evaluation of Coliforms, Escherichia coli, Salmonella, and
Escherichia coli O157:H7 in Organic and
Conventional Produce Grown by Minnesota Farmers. Journal of Food Protection, Vol. 67, No. 5, 894-900.
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