Aims :

Specify requirements concerning composting procedures for different kinds of farms and crops.

Background :

NOP gives detailed instructions for composting animal manure, to avoid food contamination with pathogenic micro organisms, especially aggressive E. coli strains.

Normative framework :

§ 205.203

(c) The producer must manage plant and animal materials to maintain or improve soil organic matter content 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. Animal and plant materials include:

(1) Raw animal manure, which must be composted unless it is:

(i) Applied to land used for a crop not intended for human consumption;

(ii) Incorporated into the soil not less than 120 days prior to the harvest of a product whose edible portion has direct contact with the soil surface or soil particles; or

(iii) Incorporated into the soil not less than 90 days prior to the harvest of a pro duct whose edible portion does not have direct contact with the soil surface or soil particles;

(2) Composted plant and animal materials produced though a process that

(i) established an initial C:N ratio of between 25:1 and 40:1; and

(ii) maintained a temperature of between 131° F and 170° F for 3 days using an in-vessel or static aerated pile system; or

(iii) maintained a temperature of between 131°F and 170°F for 15 days using a …..windrow composting system, during which period, the materials must be turned a minimum of five times.

NOP (Comments, page 68):

The microbial composition of compost teas are difficult to ascertain and control and we are concerned that applying compost teas could impose a risk to human health. Regulation of compost teas was not addressed in the proposed rule. The National Organic Program (NOP) will request additional input from the NOSB and the agricultural research community before deciding whether these materials should be prohibited in organic production or whether restrictions on their use are appropriate.

§ 205.103 (b)

…records must…

4) Be sufficient to demonstrate compliance with the Act and the regulations in this part.

Terms :

• Compost (NOP definition): “The product of a managed process through which micro organisms break down plant and animal materials into more available forms suitable for application to the soil. Compost must be produced through a process that combines plant and animal materials with an initial C:N ratio of between 25:1 and 40:1.”

ADITI clarification: Obviously, compost can also be produced only from plant materials. In this case, however, the NOP requirements are not applicable, be-cause this compost is not considered a health risk. Composts made only from animal manure, without plant material, however, are not compliant with NOP!

• 131° F=^~55° C; 170° F =^~ 75° C
• Compost tea (NOP definition): “A compost tea is produced by combining com-posted plant and animal materials with water and a concentrated nutrient source such as molasses. The moisture and nutrient source contribute to a bloom in the microbial population in the compost, which is then applied in liquid form as a crop pest or disease control agent.”

Policy :

Records on composting:

ADITI will require detailed records on composting procedures, including tem-perature readings, whenever there is a real health risk, i.e. when animal manure is applied within 4 months before harvest on crops, where contact between manure and the edible part of the plant is possible. This is the case for most vegetables, strawberries and similar crops. ADITI provides producers a special record form for this purpose.

For crops, where the health risk is low, obviously the farm has to comply with the NOP compost standard, too, but ADITI will not request detailed records. It is suf-ficient, if the farmer can explain, how the required temperature is achieved, and how often the compost is turned.

C:N ratio:

Normally, ADITI will not request a laboratory analysis for the initial C:N ratio of compost material. It is sufficient, if the farmer can demonstrate a reasonable mix-ture of C-rich (like straw, sawdust, and most crop residues) and N-rich (like manure and urine) materials of around 1:1 to 2:1 (volumes).

Compost tea:

Use of compost teas is quite common in organic farming. Especially in Latin America, many farmers use anaerobic or semi-aerobic fermentation products from plant and animal waste, which are applied on crops with sprayers. ADITI will not allow the use of such fertilization techniques under NOP, whenever there is a real health risk (see 5.1). On crops, however, where the health risk is low, like e.g. bananas, ADITI does not want to block such farmer initiatives, while the US National Organic Standard does not clearly prohibit them.

Pastures:

In some regions, animals graze on the same land, where some kind of cultivated, wild or semi-wild crop is harvested (e.g. zero-input fruit orchards, wildcrafting of typical grassland species, etc.). ADITI will handle these situations as follows:

• Products, where there is a possible risk of contact between animal droppings and the harvested product (e.g. apples collected from the ground, Taraxacum or Plantago leaves harvested from pastures): The 4 months period between grazing and harvest has to be respected.
• Products, where there is no or a very low risk of contact between animal drop-pings and the harvested product (e.g. cherries picked from the tree, Agave leaves, wildcrafted elderberries or Taraxacum roots: No restrictions, unless grazing has been so intensive, that density of animal dropping is comparable to a real fresh manure “application”. In this latter case, the 3 months period be-tween grazing and harvest has to be respected.