The Organic Trade Association corrects inaccuracies and helps paint a more complete picture in response to the recent blog post “14 facts the organic industry doesn’t want you to know.”
Dear Tiffany,
Every parent should have the right to make well-informed decisions about what they feed their families. On this point, we couldn’t agree with you more. We also agree that making those decisions has become increasingly confusing for eaters and shoppers everywhere.
We share in your sentiment that our food system is broken. There is limited regulation on how the majority of our food is produced. There is MAJOR consumer confusion around unregulated claims made on product labels with terms like “all natural”, local, cage-free, non-GMO… the list goes on and on. And then, of course, parents have the added challenge of trying to separate fact from fiction. Of having to comb through all of the misinformation that is shared about exactly what is and isn’t good for us, good for the planet, and worth our investment.
To that end, your recent blog post “14 facts the organic industry doesn’t want you to know” contains too many inaccurate and misleading statements about organic for us to sit idly by.
First and foremost, it’s important to know that organic is the most heavily regulated, transparent, and closely monitored food system in the United States. Unlike other eco-labels, the organic label is backed by a set of rigorous federal production and processing standards. These standards have been developed through a transparent process involving the National Organic Program, the National Organic Standards Board (a citizen advisory group), industry representatives and the public, to provide traceability from the farm to table, and to ensure that you and your family can have confidence in the organic products you buy. There is nothing “the organic industry doesn’t want you to know.” More than any other part of the global food system, organic is an open book.
We’ve closely read the 14 points outlined in your piece and have responded to each of them below. The work that you are doing to keep parents informed so that they can make choices about what to feed their families is both important and well-intentioned. Your voice is influential, and as such, we urge you to consider the complete facts, to learn more about the organic certification and verification process, and to correct the misleading information presented in this post.
If you are interested, we would love to connect you with organic farmers, business owners, and founders of major organic brands who can talk to you more about why they choose to do the hard work, why they stand up for the organic standards, and exactly what it means to be a part of this unique sector of U.S. food and farming.
-- On behalf the 7,000+ small and large organic farmers, local and national organic processors, regional and country-wide organic distributors, mom-and-pop organic stores and organic retail chains represented by the Organic Trade Association.
1. Pesticides are allowed in organic production.
THE REAL FACTS: The limited amount of approved pest-control products for organic growers represents the least harmful and most advanced substances available in agriculture. Every single pesticide is approved by the EPA that establishes tolerances for residues on crops—organic pesticides are no different. There are no approved organic pesticides that are not also “tolerance exempt” according to the EPA. Tolerance exemption means that EPA has evaluated the scientific data around human health related to the substance and has determined it to not be harmful. So, yes, there is a guarantee that these products are safer. Additionally, no pest-control product can be used unless it is added to the National List of Allowed and Prohibited Substances. The National List is controlled by the National Organic Standards Board (a citizen federal advisory committee made up of farmers, scientists, environmentalists, handlers, consumers and certifiers). This group wades through public testimony, scientific literature, and written comments to determine if substances are compatible with organic principles as spelled out in the organic law. In order for a substance to be added to the National List, it must be 1) absolutely necessary; 2) safe to humans; and 3) safe to the environment. The allegation that organic pesticides are not tested or overseen or that they have been allowed without concern for consumer health, the environment, and farm workers is completely untrue.
Visit OTA.com for more information on how the organic standards are set, how the National Organic Standards Board functions and details on the National List of Allowed and Prohibited Substances.
For non-technical summaries of recent studies on pesticides in organic, please visit organic-center.org.
2. Some “natural” chemicals used in organic farming are carcinogenic.
THE REAL FACTS: As stated earlier, all substances used in organic production have been vetted and supported by the National Organic Standards Board. One of this group’s criteria for approving any substance is its impact on human health. For instance, the National List bans such toxic natural pesticides as nicotine, strychnine, and arsenates.
3. Organic pesticides aren’t always as effective as synthetic, and may require more application in order to achieve the same protection.
THE REAL FACTS: First off, organic producers must manage crop pests and disease with a preventive approach prior to using any approved pest-control materials. These practices include crop rotation, planting insectary hedgerows to encourage pollinators and pest predators, cultural practices, and monitoring for disease and pests. Only after these practices have failed can an organic producer use an approved pest-control material. As we learned earlier, all of these pest-control materials have been tested for safety and were determined by EPA to be among the safest pesticides available – Tolerance Exempt. The argument that since organic pest control materials are less effective (which confirms the fact that they are, in fact, less toxic) they must be used at higher rates and residues on food will be at higher levels is an unwarranted assumption. Organic pesticides are less effective than their conventional counterparts, because they’re less toxic, but organic producers are also under a regulatory obligation to prevent pests before using any materials.
4. There are 35 non-synthetic, non-organic substances allowed as ingredients in or on processed products labeled as “organic.”
THE REAL FACTS: Even non-synthetic substances are monitored under the organic standards. Like every natural non-organic ingredient allowed in organic processed products, it must be essential (no organic forms available), safe to humans and safe to the environment.
There is a lot of confusion about carrageenan, but carrageenan should not be confused with poligeenan. Poligeenan is a degraded form of carrageenan with low molecular weight, and it is poligeenan, not carrageenan, that is used to induce inflammation in studies. The European Commission Health & Consumer Protection Directorate General, Scientific Committee on Food (SCF) and Joint Food & Agriculture Organization/WHO Expert Committee on Food Additives state that un-degraded carrageenan is non-toxic as a food additive.
It’s important to keep in mind that organic production strives to build a healthy environment with as few inputs as possible. The list is not a static list; every five years, substances on the list are re-evaluated by NOSB to ensure that new information has not emerged that should change their status, or if a natural or organic alternative has become available. Furthermore, compared to the 78 non-agricultural minor ingredients allowed in organic processing, more than 3,000 total substances are included on the “Everything Added to Food in the United States (EAFUS) list—and this is only a partial listing of all food ingredients that may be lawfully added to conventional food.
5. There are 43 synthetic, non-organic substances allowed as ingredients in or on processed products labeled as “organic.”
THE REAL FACTS: The synthetic non-organic substances allowed in organic products are also vetted and approved by NOSB—the same board that oversees substances used in organic crop production. It evaluates each substance to ensure that its form, function, and manufacturing adhere to organic principles and the National List criteria. What is critical to understand is that each of these substances has been determined to be “essential” for organic processing. This is a defined criteria of the National List. Ethylene is allowed to be used for the ripening of tropical fruits and degreening of citrus. This substance is essential to organic handling of these crops to bring tropical products to market for U.S. consumers. Other substances on this part of the National List include chlorine and peracetic acid—critically needed materials for ensuring food safety, giving organic processors adequate tools to ensure the safety of organic food for consumers.
6. Over 45 non-organically produced ingredients are allowed as ingredients in or on processed products labeled “organic” when the ingredient is not commercially available in organic form.
THE REAL FACTS: The process of adding a non-organically produced ingredient to the National List is extensive, time consuming, and almost never successful. This short list of non-organic agricultural ingredients includes things like fruit- and vegetable-based colors, Turkish bay leaves, and seaweed. These are ingredients for which there is inadequate organic supply available, and are only allowed in the 5% of an organic product allowed to be non-organic (more on that later). In addition to the ingredient being listed, a certified operator must continuously demonstrate to their certifier that an organic version is not available. Additionally, NOSB regularly reviews this list. In October 2014 at its most-recent meeting, NOSB voted to remove two non-organic cooking wines (sherry and marsala) because of the availability of organic substitutes. This is a process of continuous improvement, not an attempt to pull the wool over the eyes of consumer in the name of profit and shortcuts. As we will see later, none of these ingredients can be GMO…ever.
7. Only 95% of a food item is required to be organic in order to be labeled “organic.”
THE REAL FACTS: Unfortunately, the author did not actually look at the regulations guiding organic product composition before writing this blog. The assertion that a product can contain a conventional version of the same ingredient is clearly prohibited in the organic regulations at 205.301(f)(7): “All products labeled as ‘100% organic’ or ‘organic’ and all ingredients identified as ‘organic’ in the ingredient statement of any product must not include organic and non-organic forms of the same ingredient.”
Additionally, the 5% of the product that might not be organic must be approved on the National List through NOSB, and it cannot have been grown with sewage sludge, processed using ionizing irradiation, or be GMO. Again, all organic products cannot be produced using GMOs. This clearly spelled out in the organic regulations at 205.105(e): “To be sold or labeled as ‘100% organic,’ ‘organic,’ or ‘made with organic (specified ingredients or food group(s)),’ the product must be produced and handled without the use of Excluded methods.” (Excluded methods is the defined term pertaining to GMOs).
Visit OTA.com for easy-to-understand information on labeling of organic products and view the NOP’s labeling preamble for details.
8. The United States Department of Agriculture (USDA) and the National Organic Program (NOP) do not certify or inspect companies/foods for certification.
THE REAL FACTS: USDA and NOP do not perform the annual onsite inspection mandated for each certified operation. Instead, they’re charged with accrediting the certifying bodies that do this boots-on-the-ground work. Every certified operation must be inspected at least once a year by an accredited certifying agency. Accreditation ensures that certifiers are competent, have conflict of interest procedures in place, and are fully implementing the organic regulations. NOP actually accredits certifiers all over the globe to ensure that the label we see in our stores does, in fact, meet organic requirements. USDA has control and authority over any product labeled as organic in the USA, regardless of where it was grown. NOP also handles complaints from consumers and other parties, manages compliance actions against operations found in violation of the standards, provides trainings to certifiers, regularly provides guidance documents for clarification of regulations, engages in federal rulemaking to ensure organic regulations continue to meet consumer expectations, and collects civil penalties for willful violations of the organic regulations. This system works. In 2013, NOP completed 285 complaint investigations and levied nine civil penalties for $81,500.
If you still think NOP is “simply the managers overseeing that the organic certification is working as it’s supposed to…in the United States,” we encourage you to subscribe to its almost weekly newsletter The Insider so you can be aware of all the updates and communications this wing of our government provides.
Visit OTA.com for more background information on the National Organic Program.
9. The company/brand seeking organic certification pays the accrediting company.
THE REAL FACTS: Sometimes, businesses are required by federal law to be inspected and have oversight, like in the meat industry. Obtaining organic certification is voluntary, but it also requires a high level of regulation and annual onsite inspections. In most inspection and verification programs, whether it is federally mandated inspections of meat plants by USDA inspectors or voluntary organic certification, the inspected party pays the certification body for their services. This arrangement is typical and verification of the safety of our food and the authenticity of organic claims relies on these partnerships. The author implies an implicit level of conflict of interest in the relationship between certified operations and certifiers. However, to imply that payment for services will most likely result in criminal fraud is naïve. Certifiers can only do business if their accreditation is in good standing, and conflict of interest can jeopardize this status.
10. Two of the three major organic certifying companies are for-profit. Only one organization is non-profit.
THE REAL FACTS: Any company providing services that require accreditation is acutely aware of the fact that without their accreditation, they have no business model, whether it’s for-profit or non-profit. Regardless of tax structure, NOP’s oversight of certifiers is consistent and rigorous.
11. The actual certification to become organic, and follow-up inspections of companies certified organic, is often outsourced to a third-party.
THE REAL FACTS: Here’s actually how the certification process works for a large company that processes tomatoes:
- USDA-NOP accredits the certifier (the accredited certifier pays USDA-NOP – mostly for fees associated with the week-long accreditation audit by USDA auditors and direct support to NOP accreditation managers to assist with certification)
- The certifier certifies the company as an organic tomato processing plant (the company pays the certifier for approval of formulas, annual onsite inspections at ALL facilities, and verification of authenticity of ingredients)
- The certifier sends trained staff inspectors or hires trained independent organic inspectors to conduct on-site inspections of all of the company's facilities and audit records to verify compliance with the organic standards.
- The farms that the tomato processing plant purchases organic tomatoes from must all have their own organic certification by a USDA-NOP accredited certifier.
- Your grocery store buys organic tomatoes from the company, and if asked, the company will know exactly which farm supplied the tomatoes. Why? Because organic regulations require that operations be able to trace all products from beginning to end.
12. Organic foods may be cross-contaminated with conventional versions of the same food.
THE REAL FACTS: Again, the author makes suppositions without clear understanding of the organic regulations. All organic handlers must have procedures in place to ensure that organic and conventional don’t get mixed together. This is a federal requirement. Inspections verify these procedures are in place, and required audits of financial and production records ensure that no conventional product is shipped as organic.
13. Some food processors “water down” organic foods.
THE REAL FACTS: So, by now we know that you can’t put an organic almond and a conventional almond together in the same bag (see #12 and #7) without risking your business’ organic certification at a minimum, and potentially facing fines and criminal fraud charges for willful violations. Purposely “watering down” product would result in compliance action and probably civil penalties.
14. Annual sales of organic food totals about $27 billion each year, yet there are only 27 employees in the NOP.
THE REAL FACTS: The organic sector fought hard to increase the NOP budget in the 2014 Farm Bill. NOP is now adding more staff and developing an interactive database to ensure authenticity of organic certificates. But we agree, they still could use more resources to provide the organic industry with education and oversight. NOP’s ability to accredit certifiers and enforce the regulations should continue to grow as organic grows. We need supporters of organic products to contact their representatives and request that they continue to fund NOP. Meanwhile, please note that there are over 100 certifying agents and thousands of inspectors who oversee USDA certification and help ensure that organic operations are following the practices required by national organic standards.
