Brief Preface: This essay examines how the United States Department of Agriculture (USDA) through its regulatory body the National Organic Program (NOP) is threatening the future of organic farming in the USA.
When reading it is important to remember several points. Organic certification is the only true national standard for growing healthy food in this country. Many of the regulations designated and enforced by the NOP date back to the original drafting for organic certification in 2001/2 and are widely accepted as promoting and protecting true organic principles. In our current marketplace other terms such as “regenerative” or “certified regenerative” or “natural” mean absolutely nothing from a standards point of view.
This is why the Real Organic Project certification (discussed below) is an addendum to the NOP organic certification. It is attempting to validate organic certification where appropriate during this current period of wide-scale NOP-endorsed fraud.
I had the opportunity these past several months to revisit my commitment to the National Organic Program. The NOP is the regulatory arm administered by the USDA that oversees permitting for farms that wish to promote themselves as organic. The NOP essentially contracts out organizations both public and private to oversee the process of certifying farms (and other related businesses). Until recently, the fall of 2023 to be precise, the Rhode Island Department of Environmental Management’s Division of Agriculture oversaw this certification process in RI. Many if not all of the certified organic growers in Rhode Island received their certification through this public office. If you were buying Big Train Farm products wholesale you would receive a sticker on your box that said “Certified Organic by RIDEM”.
Rhode Island recently was one of several states to loose its public accreditation to administer organic certification to farmers. According to the head of RI’s Division of Ag the increasing demands of USDA and the lack of funding and support led DEM to finally surrender the process. This precipitated a scramble for organic growers in the state. Farms like Big Train had only a matter of months to reapply through a private certifying agency, a process that usually takes at least several days to prepare and had already been done in the spring of the same year. If we failed to do so we were in danger of losing our USDA organic certification by the New Year. With the alternative private company the cost of applying for certification was going to skyrocket and the additional paperwork looked potentially daunting. For me it was a chance to step back and think about where I stood with organic certification personally, financially, and ideologically.
I’m old enough to remember when the NOP was founded in 2001. I had just finished my first internship on an organic farm in the Finger Lakes region of New York. In those days the organic sector held only the slightest sliver of a fraction in the grocery retail market. While today we have one national standard in those days local, unregulated certifiers accommodated farms that wished to be certified organic. Unlike today where you could potentially be fined up to $10,000 for organic fraud, there were no penalties to speak of for folks who did not follow the standards of their certifying organizations. Although the organic movement had been defining the word intentionally for many years at this time the term “organic” still was not technically defined and as open to potential fraud as familiar, murky terms such as “natural” or “regenerative”.
With the arrival of the NOP on the scene organic certification became truly standardized and national. The public and private certifying organizations I mentioned stepped up to oversee the application and renewal process, and long-time luminaries in the organic movement had influence with the NOP. The standards were not perfect by many accounts but they were strong and included ideas critical to organic farming principles. Regulatory standards included mandatory crop rotations and natural resource management such as on-farm water and biodiversity concerns. Core organic values such as pasture-based livestock production, cover cropping, and soil-grown crops (i.e. no hydroponic production in organics) were embedded in the standards.
Most people focus on the issues orbiting around restricted and prohibited substances in organics such as the various pesticides that are not permitted in organic farming systems. These are of course extremely important issues to consumers and remain the primary purchasing leverage for organic products. Yet these other standards I mentioned are also of critical importance to developing a healthy farming system that can be recognized as “real organic”. It is in fact these more holistic practices such as cover cropping, pasturing, and ecologically minded soil-care that make the final products of our farms healthier, more nutritious, and better for the environment. Our crops are healthier because of the things we do do, such as cover cropping, not because of the things we don’t do, such as spraying poisons on our fields.
Check boxes that speak to these more holistic and less consumer-centric topics are found on every farmer’s organic certification application. They are time-consuming and often costly practices to implement on farms and are one of many reasons that organics can demand higher prices. The USDA has been allowing conventional growers to circumvent many of these application boxes, whole pages really, and allowing farms who would otherwise be deemed noncompliant to receive organic certification. This is fake organic farming and it has real consequences for the market and our communities. Because of two particularly egregious departures from core organic principles a new organic movement in the USA has risen up to bring integrity back to the organic label. As the NOP has allowed the bypassing of organic standards in several arenas, such as permitting hydroponic growing and confined animal feeding operations (CAFOs) to be certified organic, farmers around the country are pushing back.
The Real Organic Project has been offering a addendum to the USDA organic application which certifies that the farm in question is a soil-based farming system (no hydroponics) and/or raises it’s livestock primarily on pasture (no CAFOs). Because the USDA has bent the knee to Big-Ag by allowing hydroponic farms and CAFOs to be certified organic real organic farms are finding their markets debased and themselves priced out while the consumer is totally unaware. This has had a deleterious effect on real organic farms across the country, in particular organic dairy farms, chicken farms, blueberry and cane-fruit farms, and vegetable farms, in particular tomato growers. A salient example for New England has been the pull out of Horizon Organic milk from Vermont and New Hampshire (all contracts were canceled with these real organic farms), the company preferring to buy cheaper milk from fake organic farms out west. If you are a wholesale farmer who deals in these commodities you are being swindled by the NOP, priced out of your market. If you are a consumer you are being deceived. Sadly you simply cannot trust the USDA’s organic label today in regards to these staple agricultural products when shopping in a grocery store.
Big Train Farm has had a relationship with organic certification typical of many small farms. Being such a small operation (BTF is a ten acre farm that primarily serves roughly eight-hundred people through our CSA program) our marketing style is very retail, very face-to-face. We decided to adopt organic certification in 2012 for two reasons. We were doing more wholesale in those years, sending product up to Boston and the north shore through a local distribution center as well as working more closely with local universities and restaurants. With anonymity in those markets organic certification was extremely important in justifying our pricing and assuring these faraway customers of the integrity of our products.
During the pandemic we increased our CSA membership by about thirty percent. This required more than word of mouth advertising so organic certification was important in providing interested customers a reliable standard when deciding to join our CSA membership. Marketing is a fundamentally important benefit to organic certification.
But also important was the fact that I had come up in what was a particular cultural wave of organic farming (I’m not sure what to call this wave, but the period from 2000-present). All the farms I worked for previous to starting my own business were certified and I saw organic (especially in my early years) as a unique and even fringe movement that spoke to my counter-cultural sympathies. Yet as I’ve grown up I feel like Organic has grown up too. Organic is ubiquitous now and has become a successful and respected standard, a household word. The community has expanded as well with new growers and organic-minded organizations popping up like dandelions all around us. I came up in organic farming feeling as though I was part of an intelligent, dedicated, and thriving community and once I was farming on my own I wanted to be counted among the ranks of certified organic farmers all around the world.
Yet in the fall of 2023 I was feeling skeptical. Dealing with the public certification process through RIDEM had always been frustrating. Slow, clunky, often opaque and sometimes arbitrary I was tired of the tedious noncompliance letters and late to arrive certificates. The increased cost of switching to a private certifier had me balking too. My business was established, we knew our customers and at this point most of our business was built on reputation and not on advertising. I felt like I didn’t really need Organic anymore. So what brought me around? It was the Real Organic Project. Being certified by the Real Organic Project for several years now I could see how important it was to stand with these certified growers, some who are not as fortunate as me to have a nearly fully retail business. I felt that pull of community again, a Real movement, something stirring, like I felt in my early days of farm work.
This community is still small with only about 1,000 farms certified Real Organic. I believe it needs growers like myself to stay certified in order to fight and to win. The issues attached to Real Organic go far beyond a national standard of excellence in food production. These issues go to the heart of our troubled economy and suffering environment: anti-trust, indigenous rights, climate change, inequality, algorithm autocracy, rural decimation and so on. This movement is at the heart of systemic change because food production is at the heart of systemic recalcitrance. Frankly I’m proud to be part of it.
So I went to Staples and copied all my paper work for the second time last year. I sent in my application in a heavy envelope with an even heavier check, and gladly participated in half-a-dozen clarifying phone calls with my very charming new certifier.
Organic has done a lot for me. It has been a friend, a buoy, a partner, and a family. Perhaps right now it needs me more than I need it. I am happy to accept that. When my son asks me where I was when the USDA was trying to roll back Organic I’ll be able to tell him… right on the front line.