[Terrapreta] USDA organic certification standards

[David Yarrow]

  ----- Original Message ----- 
  From: Douglas Clayton 
  Sent: Sunday, March 25, 2007 6:49 PM
  Subject: USDA organic certification standards

  David,

  Ran across this last night:
  §205.203 Soil fertility and crop nutrient management practice standard.
  1. Standards require organic producers to select tools (e.g., tillers, plows) and practices that maintain
  improve soil quality and minimize soil erosion.
  2. Producers are required to utilize crop rotations, cover crops and plant and animal materials
  maintain or improve soil organic matter content in a manner that does not contribute to contamination
  of crops, soil, or water by plant nutrients, pathogens, heavy metals, or residues of prohibited substances.
  3. Prohibits the use of raw manure unless it is incorporated into the soil more than 120 days prior
  harvest for crops for human consumption whose edible portion is in direct contact with the soil
  particles; or 90 days prior to harvest for crops whose edible portion does not contact soil or soil
  4. Defines compost as material that has an initial C:N ratio of between 25:1 and 40:1. Requires
  to reach specific temperature parameters for specific time periods. If produced according to requirements,
  compost can be applied at any time.
  5. Allows use of uncomposted plant materials.
  6. Allows mined substances of low solubility.
  7. Allows the use of fertility inputs on the National List. Prohibits the use of synthetic fertilizers
  National List.
  8. Prohibits the burning of crop residues, except to prevent disease or to stimulate seed germination.
  9. Ash from the burning of plant or animal material is allowed, but manure ash is prohibited.
  10. Micronutrient trace minerals may be used when soil deficiency is documented by testing.
  Micronutrients must not be used as defoliants, herbicides, or desiccants. Nitrate and chloride
  prohibited.

  Douglas Clayton
  50 Bullard Road
  Jaffrey, NH 03452
  H. 603-532-7321
  W. 603-532-1120
  Fax. 603-532-4581 
so then, by an initial reading of the USDA NOP statute, pyrolysis charcoal is not defined within the language of the law.  so charcoal may not be automatically approved for use by certified organic farms.

we ran into a similar issue in inquiring about the NOP status of sea minerals, since they are not a "mined substance of low solubility."  sea minerals are mined minerals of high (total) solunbility.  fortunately, no one challenged sea minerals on the basis of solubility, and we are recommending only low levels of application, so the sea minerals are accepted as a natural mined mineral that is non-synthetic.

gaining approval for pyrolysis charcoal under the USDA NOP may involve some careful crafting of language.  

for one, the charcoal must be from organic wastes, where "organic" must be clearly worded for precise definition   what sorts oif organic materials are acceptable; which are not?  certainly not highly synthetic paper and cardboard, or sewerage.

for two, the definition must specify the process used to create the charcoal.  we should be careful to use lanfuage that includes high tech, controlled combustion and emission steel tanks, without excluding more traditional methods to create charcoal in earthen kilns, heaps and smouldering piles.

for three, the definition should specify "low temperature" pyrolysis, since this preserves the microscopic pore structure of the biological-created carbon-based molecules.  in contrast, high temperatue pyrolysis destroys and "melts" this micro-pore organic structure, degrading its value as a soil condiioner favorable to micro-organisms, plus soil aeration, water retention and nutrient conservation.

just a few preliminary thoughts.

David Yarrow
"If yer not forest, yer against us."
Turtle EyeLand Sanctuary
44 Gilligan Road, East Greenbush, NY 12061
518-330-2587
dyarrow at nycap.rr.com
www.championtrees.org
www.OnondagaLakePeaceFestival.org
www.citizenre.com/dyarrow/
www.SeaAgri.com
 
"Happiness can be found even in the darkest of times, 
if one only remembers to turn on the light."  
-Albus Dumbledore
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