Hydroponic and Aquaponic Task Force Report

196 Pages·2016·4.79 MB·English

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July 21, 2016

MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD

FROM: Miles V. McEvoy
Deputy Administrator
National Organic Program (NOP)

SUBJECT: Hydroponic and Aquaponic Task Force Report

The Hydroponic and Aquaponic Task Force Report is available for your review.

In September 2015, AMS convened the Hydroponic and Aquaponic Task Force to further
explore the issue. The task force was comprised of sixteen (16) diversely qualified individuals
that represent both the soil-based organic and hydroponic communities. The objective of the task
force was to develop a report for the NOSB that: 1) describes the current state of technologies
and practices used in hydroponics and aquaponics; and 2) to examines how those practices align
or do not align with the Organic Foods Production Act (OFPA) and the USDA organic
regulations.

Please use this report to make a recommendation to AMS. Based on your recommendation,
AMS will take the necessary steps to establish clear standards for these production systems. The
public will be invited to provide comments during your deliberations, as well as when AMS
develops guidance or initiates rulemaking on this issue.

AMS greatly appreciates the time and effort that the Hydroponic and Aquaponic Task Force
members volunteered in writing this report. Members of the task force include:

• Will Allen, Milwaukee, Wisconsin • Eric Sideman, Ph D., Strafford, New
• Colin Archipley, Esondido, California Hampshire
• John Biernbaum, Ph.D., East Lansing, • Pierre Sleiman, Encinitas, California
Michigan • Stacy Tollefson, Ph.D., Tucson, Arizona
• Angela Caporelli, Frankfort, Kentucky • Jose Edgardo Torres, Sahuarita, Arizona
• Dave Chapman, East Thetford, Vermont • Jessica Vaughan, Freedom, California
• Marianne Cufone J.D., New Orleans, • Jeffry Evard, Plainfield, Indiana
Louisiana • Sam Welsch, Lincoln, Nebraska
• Amy Lamendella, Santa Cruz, California • Theresa Lam, East Brunswick, New
• Charlie Shultz, San Marcos, Texas Jersey
National Organic Standards Board (NOSB)
Hydroponic and Aquaponic Task Force Report

July 21, 2016

Table of Contents

1. 2010 NOSB Recommendation Subcommittee Report
2. Hydroponic and Aquaponic Subcommittee Report
3. Alternative Labeling Subcommittee Report

NOTE: This report was written by the National Organic Standards Board, Hydroponic and Aquaponic Task
Force. This report has not been reviewed for approval by the U.S. Department of Agriculture (USDA), and, hence,
the contents of this report do not represent the views and policies of the USDA, nor of other agencies in the
Executive Branch of the Federal government, nor does mention of trade names of commercial products constitute
a recommendation for use. Additionally, the information provided as part of this report, including photos,
diagrams, videos, presentations, written content or otherwise belongs to the report authors. Outside of reading
the report, none of the information provided should be used by others without permission from the individual who
contributed the content.
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1. 2010 Recommendation
Subcommittee Report

Subcommittee Members
John Biernbaum, MSU and MOFFA
Dave Chapman, Greenhouse Organic Farmer
Theresa Lam, NOFA-NJ
Amy Lamendella, CCOF
Eric Sideman, MOFGA
Sam Welsch , OneCert
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Summary of 2010 Subcommittee Report

In 2010 the National Organic Standards Board passed a recommendation onto the National
Organic Program called Production Standards for Terrestrial Plants in Containers and
Enclosures. This recommendation was the culmination of more than a decade of work by the
NOSB, and was the final recommendation of the Board on this topic. Six years later, the NOP
felt that there were a few points relating to hydroponic production that were left ambiguous,
and so created the Hydroponic and Aquaponic Task Force. The Task force formed three
Subcommittees: one was to describe "organic hydroponic" production and discuss the ways in
which it aligns with OFPA and the USDA organic regulations, one was to discuss alternative
labeling, and we ("the 2010 Recommendation Subcommittee”) accepted the task of providing
clarification and further support for the position taken in the 2010 NOSB recommendation and
consider the alignment of soilless production systems with organic law and regulation.

The Federal Register Notice announcing the formation of this task force had simple objectives:
"There are two main objectives of the task force: (i) To describe current hydroponic and
aquaponic production methods used in organic production, and (ii) to assess whether these
practices align with OFPA and the USDA organic regulations. The task force will prepare a report
advising the NOSB on proposed standards or guidelines for hydroponic and aquaponic methods
in organic agriculture. The report may be used to inform the NOSB on recommendations
concerning hydroponic and aquaponic systems and for possible guidance or rulemaking by the
NOP."

Observing that the framework of organic farming is based on its foundation of sound
management of soil biology and ecology, it became clear to the NOSB that systems of crop
production that eliminate soil from the system, such as hydroponics, cannot be considered as
acceptable organic farming practices. The 2010 Subcommittee of the Task force came to the
same conclusion. Similar to the NOSB in 2010, we based our conclusion on historical founding
principles of the organic farming movement, regulatory text in the Organic Foods Production
act, Regulatory Text of the USDA National Organic Program, good soil management practices,
and international organic standards.

The organic farming movement began in the early part of the twentieth century, pioneered by
farmers and academics who were responding to obvious problems with "modern" agriculture
(where little organic matter is added to the soil) such as depletion of soil fertility and structure,
decline of livestock health caused by low feed quality, soil erosion, etc. The basic premise of
organic farming was that agricultural soil needs continuous restoration by means of adding
manure and/or compost, managing cover crops and crop residue, and adding natural rock
powders. The earliest organic certification programs based their standards on this premise.
OFPA and the NOP regulatory text did an excellent job of representing this heart of the early
certification programs by using the word "must" or "shall" (rather than "may") in the sections
regulating soil management.
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Organic farming practices are centered on the basic principle of feeding the soil rather than the
crop. This simple slogan rests on the idea that the successful management of soil is all about
taking care of the organic fractions; the living organisms, the recently dead and decomposing
organisms, the slow to decay organic matter, and the very stable organic matter often referred
to as humus. The key to an organic farming system is to build and maintain these interactions.
It is through the interaction of the organic matter fractions with the mineral fractions that a
productive and sustainable soil system is developed and maintained. In an organic farming
system the bulk of the crop's nutrients comes from complex organic molecules being fed into
these organic fractions, and some portion of the material and mineral fraction being converted
to nutrient forms available for plant uptake. Some of the organic material becomes part of the
organic fraction of the soil, building the soil. Section 6513 (b)(1) of OFPA states, "...foster soil
fertility, primarily through the management of the organic content of the soil...". Our
interpretation of this OFPA section is that direct crop feeding with available fertilizers is to be
used only as a supplement when necessary.

The 2010 Task Force Subcommittee recognize that there are some parts of an organic system
that do not directly link to the soil, for example production of transplants. Furthermore, there
are some commodities produced that include a less than obvious link to soil, such as sprouts,
crops grown in containers, etc. In this report, we discuss these and explain the link to the soil,
and explain why some of these may not be applicable to the premise that organic production
takes place in the soil. We discuss the continuum between “grown in the ground” and “grown
in a nutrient solution” and how to draw the line between a system that feeds the soil, and a
system that does not meet organic principles because it is based on simply feeding the crop.

The basic standard of all of the countries in Europe is that hydroponic production is prohibited.
We believe, that although some international standards allow crops to be grown in containers
of biologically active media mimicking a soil system, and also restrict the amount of crop
nutrients coming from direct feeding, there is no international organic standard that allows the
bulk of the crop nutrients to come from direct crop feeding.

Conclusions

The NOSB in their 2010 recommendation made it clear that they support the historical premise
that organic production should take place in soil. Our subcommittee of the
Hydroponic/Aquaponic Task Force agrees, and has worked to clarify any ambiguities that we
and/or the NOP recognized.

The crux of our conclusion is to clarify the distinction between organic fertility management
and conventional fertility management. In organic management, the source of the bulk of the
crop nutrients are from the biological activity decomposing complex organic molecules
(compost, manures, seed meals, etc.) and the mineral fractions in the soil. In contrast, in non
organic production the bulk of the plant nutrients are supplied in available forms. It is the
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management of the soil that is at the heart of organic production. In contrast, in a non organic
system it is the management of the fertilizers.

The NOSB will ultimately have to recommend its clear intention for the role of soil. This will be a
very important recommendation for the future of organic certification. No matter what one
thinks about which path is best, we can all accept that many in the organic community are
opposed to the inclusion of hydroponic as organic1. Failure to address that concern will inevitably
undermine public and farmer support for the USDA Organic label.
Container Growing, (including hydroponic production)

Based on the work of this subcommittee, there appear to be the following choices to satisfy both
the language of OFPA and the intent of the 2010 recommendation:

● Limit organic certification to what is grown in the ground, with the exceptions of
transplants, ornamental, and herbs (The common standard used in most European
organic certification). This would be the single path that is in clear alignment with the
language of OFPA. The majority of the subcommittee supports this option.

● If certification includes crops grown in containers, it will require additional standards to
cover the practices that are not covered by existing regulations. The critical question is
how to ensure that container grown plants get most of their fertility from the natural
processes of the soil or compost based media in the containers. This could require a
limitation on the percentage of nutrition that could be gained from additional fertilizers
after planting, and the amount of fertility obtained from liquid feeding. We suggest a
limitation of no more than 50% of the required fertility being added after planting, and
no more than 20% to be added as a liquid fertilizer after planting. For perennials these
limitations should be on an annual basis. A similar limitation suggested by IFOAM EU is
intended for field crops as well as greenhouse crops. Another suggestion is to follow the
recommendation of Dr. Martine Dorais of Laval University and the Agassiz Research and
Development Centre to grow in 100 to 180 liters of soil per m2. At this volume she has
demonstrated that no liquid fertilizing is necessary, and fertility can be provided by the
biological activity of the growing medium in the beds. We recommend defining the
growing area to include the paths between rows. This choice deviates from a strict
interpretation of the language of OFPA, but is closer to the intention.
Enclosures

1 A clear demonstration of the depth of this opposition was the Moratorium letter presented to Secretary Vilsack
in April of 2016. This letter called for an immediate moratorium on all new hydroponic certification until final
standards in accord with the 2010 recommendation could be completed. It was signed by 65 organic leaders, 15
former NOSB members, and 40 organizations whose total membership exceeds 2.2 million people. (Appendix H)
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● Greenhouses need to be more specifically defined as having transparent roofs and walls
to permit the passage of sunlight. Controlled indoor environments without transparent
roofs and walls can be used for transplant production but not for organic crops.
● Electric lighting may be used as a supplement to the sun, but not as a replacement for
the sun when producing organic crops. Transplants can be produced with only electric
lighting.

Growing Media

● Regulations relative to container growing media for transplants and organic crops need
to be refined and evolved to require compost based media. This will require expanded
definitions and guidelines relative to the production and acceptable characteristics of
compost. The primary goal is to align with the expectations regarding containers as
outlined above. At a bare minimum, a substrate used in pots or containers should have a
minimum of 20% compost.
Rotation of Crops

Regarding rotation of crops in greenhouses, there seem to be two choices:

● Require rotations for all annual crops. This may be accomplished by rotating the crops, or
by rotating the soil in the beds on a schedule of once every number of years. Then the
rotated soil should be removed and be renewed by cover cropping or composting before
returning to the greenhouse.
● Accept that greenhouse crops are grown in a specialized environment, and may require
that issues such as soil biodiversity and health can be treated in a similar way to a
perennial crop, with liberal use of compost, mulch, and interplanting.
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Table of Contents

Summary of 2010 Subcommittee Report.................................................................................... 2
Conclusions ............................................................................................................................... 3
Container Growing, (including hydroponic production) ............................................................ 4
Enclosures ............................................................................................................................. 4
Growing Media ....................................................................................................................... 5
Rotation of Crops ................................................................................................................... 5
Table of Contents ....................................................................................................................... 6
Introduction ................................................................................................................................ 9
Section 1. Regulatory Issues: How OFPA and NOP Regulatory Text Address Soil ..................13
Background ...........................................................................................................................13
Before OFPA: ....................................................................................................................13
OFPA, the USDA organic regulations, and the NOSB: .......................................................14
Organic Foods Production Act and National Organic Program Regulatory Text ....................16
OFPA Section §6513(b)(1) .................................................................................................16
National Organic Program Regulatory Text Sections 205.202, 203, and 205.........................17
§205.202 Land requirements. ..........................................................................................17
§ 205.203 Soil fertility and crop nutrient management practice standard. ...........................17
§205.205 Crop rotation practice standard. .......................................................................17
Hydroponics Task Force Regulatory Considerations .............................................................18
Exceptions That Need to be Addressed in Future Regulation (Applicability of OFPA and
USDA organic regulations to various types of soil-less production systems) .........................19
Soil requirements are not applicable to four types of soil-less production: sprouts,
mushrooms, wild aquatic plants, and annual seedlings. .....................................................20
Some soil-less growing systems are not in alignment with USDA organic regulations
because their fertility does not come from soil. ...................................................................21
Some container grown systems that use a combination of soil/compost as the source of
fertility may be close enough to soil-grown that they could be certified with some
amendments to USDA organic regulations. ........................................................................22
Consistent with OFPA and USDA organic regulations ...........................................................23
§6501. Purposes ................................................................................................................23
§6506. General requirements .............................................................................................24
§6512. Other production and handling practices ................................................................24
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§6513. Organic plan ...........................................................................................................24
Section 2. Soil as the Foundation .............................................................................................26
The Science of Growing in the Ground ..................................................................................26
Role of Soil in Organic Agriculture .........................................................................................30
Soil Physical Properties .....................................................................................................31
Soil Chemical Properties ....................................................................................................32
Soil Biological Properties ...................................................................................................32
“Organic” Soil .....................................................................................................................32
Regarding Organic Hydroponics ........................................................................................33
Section 3. Containers and Growing Media ................................................................................35
The Challenge of the 2010 Recommendation ........................................................................35
Assessment of Alignment with OFPA and USDA Organic Regulations ..................................36
Photos of each type ...............................................................................................................37
Type A Production System .................................................................................................38
Type B Production System .................................................................................................40
Type C Production System ................................................................................................42
Type D Production System ................................................................................................43
Type E Container production systems ................................................................................44
Criteria Used for Characterizing Systems ..............................................................................46
1. Source of Fertility ...........................................................................................................46
2. Growing Media / Compost ..............................................................................................46
3. Biological Activity of Growing Media ...............................................................................46
4. Consumer Awareness of Growing Method .....................................................................47
5. Annual Seedling Transplants or Finished Crops .............................................................48
6. Container Size ...............................................................................................................48
7. Adherence to All Applicable Aspects of the USDA Organic Regulation ..........................48
Section 4. International Standards ...........................................................................................49
The Canadian Standards .......................................................................................................49
The EU Standards .................................................................................................................52
The Four Scandinavian Countries .........................................................................................55
Section 5. 2010 Recommendations Not Directly Related to Hydroponics .................................56
Eight Point Summary .............................................................................................................57
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Eight Point Details .................................................................................................................58
1. Enclosures .....................................................................................................................58
2. Lighting ..........................................................................................................................59
3. Natural Resources .........................................................................................................61
4. Containers .....................................................................................................................62
5. Container Growing Media...............................................................................................64
6. Land Use and Soil management ....................................................................................66
7. Rotation .........................................................................................................................67
8. Compost ........................................................................................................................69
Section 6. Definitions ...............................................................................................................73
Section 7. Appendices ..............................................................................................................75
Appendix A: EGTOP Report on Greenhouse Production .......................................................75
Appendix B: IFOAM EU Position Paper on Organic Greenhouse Production.........................77
Appendix C: Canadian Soil Fertility and Crop Nutrient Management and Greenhouse
Standards ..............................................................................................................................81
Appendix D: Soil Association Greenhouse Standards ...........................................................86
Appendix E: Language for the EU rule on growing in the ground ...........................................91
Appendix F: Bioland Standards on Soils and Substrates and Growing of Seedlings,
Transplants, Sprouts and Potted Herbs in Greenhouses (Bioland - the leading association for
organic farming in Germany) .................................................................................................93
Appendix G: 1980 USDA Report on Organic Agriculture ......................................................95
Appendix H: Moratorium Letter .............................................................................................98
Appendix I: USDA Regulations of the use of Chilean Nitrate in Organic Agriculture ............ 110
Appendix J: Letter from Michael Sligh.................................................................................. 111