Define the rules for the certification of inputs to be used in organic farming and processing facilities.
A constantly growing number of inputs for the use in organic farming and proc-essing facilities are becoming commercially available to be purchased “from the shelf”. Due to the fact that not all input manufacturers act seriously it is some-times difficult for the user to distinguish between an authorised product and a non-authorised one.
The latter ones represent a mayor risk to the organic grower as he might be sub-ject to a de-certification by his certification body.
A seriously and professionally developed input certification system, facilitates the certification procedure of the companies who had used these inputs, by avoiding that the same investigations about contents and production methods of the input will have to be explained several times to different certification bodies and/or competent state authorities.
Normative framework :
13. INSPECTION AND CERTIFICATION OF INPUT
13.1 Approval Systems:
Where Inspection and Certifying Agencies issue lists or in any other way approve products without formal certification, it shall document at least the following measures:
- the application procedure, including the necessary documents to be submitted by the applicant;
- the procedure to be followed in evaluating the product‘s compliance with the programme‘s standards;
- the decision making authority;
- the period for which approval is granted and the requirements for the manufacturer to report changes in composition or other relevant factors;
- a clear statement of the nature and guarantee of the approval.
Criteria for the Evaluation of additional inputs to organic agriculture:
Appendices 1 & 2 refer to products for fertilising of the soil and control of plant pest and diseases in organic agriculture. But there may well be other products which may be useful and appropriate for use in organic agriculture which may not fall under these headings.
The following checklist should be used for amending the permitted substance list for fertilizing the soil conditioning purposes:
- The material is essential for achieving or maintaining soil fertility or to fulfill specific nutrient requirements, for specific soil-conditioning and rotation purposes which cannot be satisfied by the practices
- The ingredients are of plant, animal, microbial or mineral origin which may undergo the following processes:
- physical (mechanical, thermal)enzymatic
- microbial (composting, digestion) and
- Their use does not result in, or contribute to, unacceptable effects on, or contamination of, the environment, including soil organisms
- Their use has no unacceptable effect on the quality and safety of the final product.
The following checklist should be used for amending the permitted substance list for the purpose of plant disease or pest and weed control:
- The material is essential for the control of a harmful organism or a particular disease for which other biological, physical or plant breeding alternatives and/or effective management techniques are not available
- The substances (active compound) should be plant, animal, microbial or mineral origin which may undergo the following processes:
- Their use does not result in, or contribute to, unacceptable effects on, or contamination of, the environment.
- Nature identical products such as pheromones, which are chemically synthesized may be considered if the products are not available in sufficient quantities in their natural farm, provided that the conditions for their use do not directly or indirectly contribute to contamination of the environment or the product.
When an input is to be evaluated it must first be investigated by certification programmes to see whether it fulfills the following six criteria. An input must fulfill all 6 requirements before it can be accepted as suitable for use in organic agriculture.
Inputs should be evaluated regularly and weighed against alternatives. This process of regular evaluation should result in organic production becoming ever more friendly to humans, animals, environment and the ecosystem.
The necessity of each input must be established. This will be investigated in the context in which the product will be used.
Arguments to prove the necessity of an input may be drawn from such criteria as yield, product quality, environmental safety, ecological protection, landscape, human and animal welfare.
The use of an input may be restricted to:
- Specific crops (especially perennial crops)
- Specific regions
- Specific conditions under which the input may be used
2. Nature and Method of Production
The origin of the input should usually be (in order of preference):
- Organic – vegetative, animal, microbial
Non-natural products which are chemically synthesized and identical to natural products may be used.
When there is any choice, renewable inputs are preferred. The next best choice is inputs of mineral origin and the third choice is inputs which are chemically identical to natural products. There may be ecological, technical or economic arguments to take into consideration in the allowance of chemically identical inputs.
Method of Production:
The ingredients of the inputs may undergo the following processes:
- Action of micro-organisms
- Chemical (as an exception and restricted)
The collection of the raw materials comprising the input must not affect the stability of the natural habitat nor affect the maintenance of any species within the collection area.
The input must not be harmful or have a lasting negative impact on the environment. Nor should the input give rise to unacceptable pollution of surface or ground water, air or soil.
All stages during processing, use and breakdown must be evaluated. The following characteristics of the input must be taken into account:
All inputs must be degradable to their mineral form. Inputs with a high acute toxicity to non-target organisms should have a maximum shelf life of five days.
Natural substances used as inputs which are not considered toxic do not need to be degradable within a limited time.
Acute toxicity to non-target organisms:
When inputs have a relatively high acute toxicity for non-target organisms, restrictions for their use is needed. Measures have to be taken to guarantee the survival of these non-target organisms. Maximum amounts allowed for application may be set. When it is not possible to take adequate measures, the use of the input must not be allowed.
Long-term chronic toxicity:
Inputs which accumulate in organisms or systems of organisms and inputs which have, or are suspected of having, mutagenic or carcinogenic properties must not be used. If there are any risks, sufficient measures have to be taken to reduce any risk to an acceptable level and to prevent long lasting negative environmental effects.
Chemically synthesized products and heavy metals:
Inputs should not contain harmful amounts of man made chemicals (xenobiotic products).
Chemically synthesised products may be accepted only if identical to the natural product. Mineral inputs should contain as few heavy metals as possible. Due to the lack of any alternative, and long-standing traditional use in organic agriculture, copper and copper salts are an exception for the time being. The use of copper in any form in organic agriculture must be seen, however, as temporary and use must be restricted with regard to environmental impact.
4. Human Health and Quality
Inputs must not be harmful to human health. All stages during processing, use and degradation must be taken into account. Measures must be taken to reduce any risks and standards set for inputs used in organic production.
Inputs must not have negative effects on the quality of the product, e.g., taste, appearance and quality.
5. Ethical Aspects – Animal Welfare
Inputs must not have a negative influence on the natural behaviour or physical functioning of animals kept at the farm.
6. Socio Economic Aspects
Consumers’ perception: Inputs should not meet resistance or opposition of consumers of organic products. An input might be considered by consumers to be unsafe to the environment or human health, although this has not been scientifically proven. Inputs should not interfere with a general feeling or opinion about what is natural or organic, e.g., genetic engineering.
Generic term for any kind of Organic and mineral fertilizers, micronutrients, growth stimulators, Insecticides, fungicides, bactericides, nematicides (and herbi-cides) on basis of plant extracts, mineral substances, microorganisms and other materials, including additives for animal feed and additives and processing aids for processing of organic food.
Contrary to the certification of organic farms and processing facilities, which is basically to be considered as a process certification, input certification falls pri-marily into the range of product certification: It is assessed whether the chemical, physical or biological composition of specific product meets the requirements of a certain Standard.
Reduction of environmental hazards during the manufacturing process:
Anyhow, some typical aspects of process certification are applied in order to as-sure that the production of inputs for organic farming should be carried out in an environmentally friendly way.
Therefore, organic input manufacturers have to have a system in place to mini-mize water, soil or air contamination. This refers especially to:
- Mining companies (i.e. production of rock phosphate)
- Agrochemical Industries (waste water treatment and air filters if applica-ble)
- Animal husbandry farms
- Commercial composting plants
ADITI is not in the condition to carry out an extensive assessment of labour health aspects in the production plants. Anyhow a minimum of preventive meas-ures must be implemented whenever it applies (such as protection mask, gloves, ear protection, etc.)
- For any kind of input the principles of animal welfare have to be respect-ed. No manure is certified from operations who do use electric shocks or similar methods to force animals. A maximum animal load per m2 is de-fined. The animals should not be kept exclusively on slatted floor.
- No manure is certified from farms were growth hormones are used
- No manure is certified from farms were highly flourished aromatic sub-stances are used as antibiotics or coccidiostatics are used in a preventive way.
- The production of Poultry manure has to comply with the minimum crite-ria described in our ―Policy on Use of Poultry Manure‖.
- Recollection of bat manure in caves which are still hosting bats should not expel the bats. Therefore recollection should be suspended during mating season.
Potentially harmful substances:
- Not only the active substances but also the inert ingredients should not present a risk to human health or the environment.
- The Maximum Residue Levels (MRL) established in NPOP for commercial compost made of domestic waste are applied to any other type of organic fertilizer and also for inputs to be certified according to NOP.
- MRL for any an individual pesticide is 0,1 ppm whereas the sum of all pesticide residues should not pass 0,5 ppm. In case of operations using potentially contaminated raw materials (i.e. rice husks in broiler farms, or poultry farms using insecticides and acaricides on a regular basis) pesti-cide testing has to be performed.
- MRL for any an individual antibiotic is 1 ppm whereas the sum of all pesticide residues should not pass 3 ppm.
- The Maximum Residue Level (MRL) of 90 ppm Cadmium established.
- No GMOs or GMO derivates may be used in input production.
- In order to keep things manageable ADITI restricts its control activities to the previous step in the production chain. Example: No enzymes or citric acid derived from genetically modified bacteria may be used as an active ingredient in the final product, whereas GM en-zymes may be used as a processing aid in the manufacturing process of the input.
- Manure from genetically modified animals is not certifiable.
- If the animals are fed with GM feedstuff their manure has to undergo a minimum 3 month composting process in order to assure that non-digest-ed residues from the GM-feedstuff will be decomposed.
Labelling and advertising:
- The manufacturer has to make sure that no confusion about the certifica-tion status of his products may occur; this implies that on product labels and advertising materials a clear differentiation between certified and non-certified products must be maintained. This is especially important for manufacturers who produce and sell inputs for the organic market but also inputs for conventional farming.
- In case the provisions of a Standard define that a certain input may only be used upon authorisation of the certification body of the farmer/processor this restriction has to be printed in letters of sufficient size directly beside the information about the certification status. The in-formation about these restrictions also has to be included in publicity material.
- Labels and information material have to include warnings about potential health risks of the user and should indicate protective measures how to avoid or minimize such a risk.
The ADITI´s certificate does exclusively state the conformity of a certain input with the standards which are mentioned on the certificate. It does not represent any guarantee for the effectiveness of the input for the indicated purposes. Nev-ertheless in order to protect its reputation as a certifying agent, ADITI will certify only products which have undergone serious testing and research in order to prove their effectiveness.
Humic acids and lignosulfonates are allowed as growth stimulator and chelating agents by NOP because:
- they are natural substances having a proofed beneficial effect
- they can be found in (natural) manure or soil
- no negative effects for people or the environment are known
Anyhow, taking into consideration that some competent authorities sometimes apply a formal approach when taking the decision about an import authorisation, we can not guarantee that each competent authority will share our point of view about the use of Humic Acids in organic farming. The different organic standards restrict the use of micronutrients to cases of proven deficiency. As soil analyses are normally not very helpful to determine micronutrient deficiencies we prefer leaf analysis.
As micro nutrient availability depends mainly on the soil pH you can hardly find a situation in which all micronutrients are not available. Therefore ADITI does not certify multi-micronutrient products which contain elements which are avail-able in completely different pH ranges. We either certify individual microelements or micronutrient mixtures containing Manganese (Mn), Iron (Fe), and Zinc (Zn) for common deficiencies in alkaline soils.
In this case it should say on the label that the product should only be used in the case of proven deficiency for each of these elements.
Biological pesticides can only be certified as long as they contain the living or-ganism or its spores. Highly concentrated fermentation products are not certifi-able (i.e. Avermectin, which is produced by using Streptomyces avermitilis). The same applies to highly concentrated fitohormons.
Inspection and product assessment:
As indicated under 5.1 input certification does not necessarily require a physical yearly inspection. Instead, laboratory analysis becomes a more important issue. According to the type of product ADITI applies a different assessment methodo-logy:
Animal manure or inputs containing animal manure will have to be inspected physically on a yearly basis. A lab analysis will only be required in the case that there does exist the risk of contamination with pesticides, antibiotics, antipara-sitics, etc.
Industrially manufactured products will have to be visited and a sample has to be analysed in the first year. From then on a yearly physical visit will alternate with a yearly lab analysis.
In case of suspicions or irregularities an unannounced inspection may take place at any time.
Standard analysis includes the following parameters:
- Fertilizers: Concentration of soluble NPK
- Pesticides: Qualitative screening of 220 different pesticides
- Manures: Antibiotics, pesticides and/or antiparasitics
- Compost made of household waste or industrial residues: Heavy metals
- Phosphoric rock: Cadmium
Additional analysis may be carried out according to the type of product.
The samples should be taken by a ADITI inspector in a commercial store or in the production plant itself from commercially packed products. Only in an excep-tional case the manufacturing company itself may take and send the samples by itself.
Inspectors have to receive a special training on the issue. If necessary ADITI will hire specialized professionals for that purpose.