Search form

Main Menu New

Home > Advocacy > Policy Positions > Addressing Inadvertent Residual Environmental Contaminants in Organic Farming and Handling

Addressing Inadvertent Residual Environmental Contaminants in Organic Farming and Handling

Organic farmers and handlers go to great lengths to produce safe, healthy, and climate-friendly food while keeping harmful contaminants off the land and out of your body. Unfortunately, these same chemicals and compounds are extensively used in conventional agricultural and other industrial settings, contaminating the surrounding environment, air, and waterways. Many contaminants such as heavy metals are also naturally occurring. As a result, the organic sector is faced with the ongoing challenge of dealing with the ubiquitous and unavoidable threat of inadvertent environmental contaminants.

Addressing Unintentional Contaminants in Organic 

On March 4, 2021, the U.S. Food and Drug Administration (FDA) provided the Organic Trade Association with an update on the agency’s work to further reduce toxic elements, such as heavy metals, in foods for babies and young children. This included a letter they released on March 5 to baby and toddler food manufacturers reminding them of their existing responsibility to consider toxic elements when conducting hazard analysis. The agency has declared this issue to be among FDA’s highest priorities and expressed its commitment to working with stakeholders to inform the development of action levels of lead, cadmium, mercury, and arsenic in foods for babies and young children. FDA will be looking at additional sources of data to build their understanding of the issue, focusing on compliance and enforcement activities, and they will be hosting a workshop later this year to bring together stakeholders to share knowledge and discuss potential mitigation strategies. More information about this announcement can be found in FDA’s constituent update

The Organic Trade Association continues to be involved and committed to high-quality standards and taking proactive steps to ensure the organic sector continues to produce the best and healthiest choice. We strongly support the continued development and use of best practices and mitigation strategies and we continue to proactively work with federal agencies to establish meaningful limits and action levels to protect consumer health. 

Details
no
472
yes
200

Blue

Main color: 
#1eb9d2
Hover: 
#4edaf0
Active: 
#078fa5
Title: 
#ffffff
Title Hover: 
#ffffff
Title Active: 
#ffffff

ORGANIC IS THE BEST CHOICE

Contamination by chemicals from the environment is not only a serious threat to human and environmental health but it threatens the organic sector’s ability to meet consumer demand. In response, the Organic Trade Association continues to be committed to high quality standards and taking proactive steps to ensure the organic sector continues to produce the best and healthiest choice.

Organic food and fiber are the best choice because certified organic products have lower levels of pesticide residues, organic farmers and handlers do not use toxic synthetic chemicals or inputs themselves, and they are required to implement strategies to protect organic land and products from contaminants. Furthermore, the organic regulations require that organic producers manage their farms ‘in a manner that does not contribute to contamination of crops, soil, or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances.’ Organic is the most transparent and trust-worthy option, and we are proud to say that foods certified organic by the U.S. Department of Agriculture (USDA) have lower pesticide levels and less impact on the environment.

Organic Trade Association members support the continued development and use of best practices to help mitigate the occurrence of inadvertent residual contaminants in organic products. We have a long history of supporting mandatory testing as a critical monitoring tool, and we are committed to proactively working with federal agencies to establish meaningful limits and action levels to protect consumer health. We also recognize that our work is ongoing, and there is opportunity for continuous improvement in mitigation strategies, testing and detection methods. There is also a need for establishing federal action levels for many environmental contaminants and associated food products.

In partnership with The Organic Center, we are also committed to identifying and investing in research that will help fill gaps in knowledge and reduce barriers to effective solutions. We work proactively to ensure organic products continue to be the gold standard in consumer safety, conducting research with governmental and academic institutions toward illuminating toxins in the food supply. For example, we worked jointly with USDA to identify techniques to reduce heavy metal uptake in organic crops, initiated a collaboration on organic methods for promoting food safety, and currently have a project in partnership with seven universities evaluating needs for protecting organic farmers and consumers from inadvertent pesticide residues.

Every day, millions of consumers choose organic food because it the most transparent and trust-worthy option out there. The Organic Trade Association is prepared to continue to meet that expectation, stay engaged in the process, and push forward to improve our food system. 

473
yes
200

Blue

Main color: 
#1eb9d2
Hover: 
#4edaf0
Active: 
#078fa5
Title: 
#ffffff
Title Hover: 
#ffffff
Title Active: 
#ffffff

ORGANIC STANDARDS: PROHIBITIONS, PREVENTION, AND TESTING

USDA organic regulations specify production and processing requirements (such as conserving natural resources and preventing commingling with non-organic products). They also specify which production inputs are allowed and prohibited. For example, in organic farming, the use of most synthetic pesticides and fertilizers is prohibited, as are growth hormones, antibiotics, sewage sludge and genetic engineering (GMOs). In organic processing, only certified organic ingredients may be used along with a short list of approved non-organic processing ingredients that are safe for humans and the environment. Examples include baking soda, carbon dioxide, citric acid and tocopherols.

Organic operations must also implement strategies that prevent contamination of organic products from prohibited substances from outside conventional sources (e.g. airborne drift, runoff, contaminated water, food contact surfaces.). For example, farmers must protect their organic land and crops from neighboring conventional use of pesticides by having buffer zones and runoff diversions. Processing facilities must implement measure to protect organic products from contact with prohibited substances or commingling with non-organic products.

USDA-accredited certifying agents oversee the compliance of organic operations, and use a variety of tools to not only verify that organic farmers and processors aren’t using prohibited substances, but they are also protecting products from inadvertent residual contamination. These tools include annual and surprise on-site inspections and periodic residue testing.

Residue sampling is an effective certification tool for monitoring compliance, deterring fraud, and protecting organic integrity. Certifiers are required to sample and test at least 5% of operations annually, which ensure that testing is done on a regular and reoccurring basis. Certifiers may sample and test organic products for any type of prohibited substance residue including pesticides, GMOs, antibiotics, heavy metals, and pathogenic organisms. For any positive detection, the certifier must conduct an investigation to determine why the residue is present and respond with adverse actions as appropriate. These investigations help to strengthen an operation’s organic system plans to avoid contact with prohibited substances, and prevent more serious contamination events before they occur.

Organic takes a much more cautionary approach to pesticide residues than any other food or agricultural sector. When residues of prohibited pesticides are detected at or above 5% of the EPA tolerance for the detected pesticide on the sampled product, the product cannot be sold as organic and must be diverted to the conventional market. These thresholds ensure that organic products are held to a much higher standard that conventional foods when it comes to pesticide residues.  

Sub Details
no

Blue

Main color: 
#1eb9d2
Hover: 
#4edaf0
Active: 
#078fa5
Title: 
#ffffff
Title Hover: 
#ffffff
Title Active: 
#ffffff
158
Organic Rice, Arsenic and Other Heavy Metals in Baby Food

Providing consumers with the safest and cleanest foods is the top priority of every organic farmer and processor, and the organic industry takes the issue of arsenic and other heavy metals in baby foods – and in any food – very seriously. 

For years, the Organic Trade Association in collaboration with The Organic Center has worked with the Food and Drug Administration (FDA) in examining arsenic exposure from rice, and bringing forth a science-based assessment to inform the establishments of clear arsenic limits on infant rice cereal. We have consistently supported the regulatory assessment process, the use of testing as a critical monitoring tool, and the establishment of science-based limits and thresholds. In the case of arsenic in rice, we have provided assistance and collaboration through our Organic Rice Working Group. The organic industry has conducted research to mitigate the levels of arsenic present in the food supply, as well as to better understand its health impact. We have shared consumer feedback and agronomic research, and we firmly stated that setting limits is a clear way to provide assurance to consumers that their food supply is safe. We are confident in the safety of organic rice relative to FDA’s action level for infant rice cereal, as well as the limits established for EFSA and Codex limits. FDA’s final guidance on action levels for inorganic arsenic in rice cereals for infants is a reasonable outcome following years of engagement with regulators, farmers, food producers, academics, and technical experts to proactively address the issue of environmental contaminants in organic food.

Learn more about the work of The Organic Center on Decreasing Arsenic Update in Organic Rice System

Toxic Chemicals from Packaging and other Food Contact Sources

Given recent examples of food packaging issues such as bisphenol-A- and fluorocarbons (BPA), “clean packaging” is becoming more of a focal point for organic consumers and an opportunity for all brands large and small to further demonstrate that the well-being of their customers is a top priority. Consumers are also concerned with expanded polystyrene, styrene, plastics, phthalates, heavy metals and propylene glycol, to name a few. Furthermore, some chemicals of concern, such as ortho-phthalates, migrate into organic foods from plastics and rubber used in processing equipment (e.g. conveyor belts and plastic tubing). Testing has revealed no difference in phthalate levels in organic foods compared to conventionally sourced foods.

Organic consumers demand transparency about what they are eating, and many are taking a critical eye to the packaging their food comes in and the presence of industrial chemicals in food products. This is likely not going away. Policy plays an important role in protecting human health, but it can be slow moving and limited in scope. In addition to policy and regulatory action, private sector solutions can be utilized in a timelier fashion to ensure that the organic label continues to meet consumer demand.

As a step to address the presence of toxic chemicals that may migrate into organic products from packaging or other food contact surfaces, the Organic Trade Association is in the initial stage of exploring a private-sector solution initiative to help drive packaging and processing suppliers towards materials and options that are consistent with organic principles. To begin the process, a task force of our member companies will be convened. The task force would help develop the framework, structure and overriding goals of the initiative, and help identify, screen and prioritize a subset of top chemicals of concern for action.

Details cont
no
476
yes
400

Blue

Main color: 
#1eb9d2
Hover: 
#4edaf0
Active: 
#078fa5
Title: 
#ffffff
Title Hover: 
#ffffff
Title Active: 
#ffffff

MEMBER ENGAGEMENT OPPORTUNITIES

Residues Task Force - Active

The mandate of the Residues Task Force is to continue the Organic Trade Association's strong support of periodic residue testing as a critical tool to monitor compliance with the organic regulations, and address challenges relating to unavoidable residual environmental contamination (UREC) and concentration factors. Work on this Task Force is facilitated by Johanna Mirenda, Farm Policy Director.

Join the Task Force

478
no
400

Blue

Main color: 
#1eb9d2
Hover: 
#4edaf0
Active: 
#078fa5
Title: 
#ffffff
Title Hover: 
#ffffff
Title Active: 
#ffffff

Cleaner Packaging Initiative Task Force – Coming Soon

Cleaner Packaging Initiative Task Force – Coming Soon

The mandate of this task force is to help develop the framework, structure and overriding goals of a “Cleaner Packaging and Processing Initiative,” a voluntary program for organic member businesses to strategically work with packaging and processing suppliers towards cleaner packaging and processing options. Work on this Task Force will be facilitated by Gwendolyn Wyard, Vice President, Regulatory Affairs.

Let us know if you are interested in joining        

Learn about our position on Protecting Organic Agriculture from GMO Contamination

Resources and Contact
no
column-1
30px

Resources

OTA comments on Rice  

FDA Response to Questions About Levels of Toxic Elements in Baby Food             FDA Letter to Industry on Chemical Hazards in Food / Update on FDA Efforts to Increase Food Safety


Contact

Gwendolyn Wyard
Vice President of Regulatory and Technical Affairs
(503) 798-3294

Maggie McNeil
Director of Media Relations
(202) 403-8514