[Terrapreta] USDA organic certification standards
Sean K. Barry
sean.barry at juno.com
Tue Mar 27 14:05:43 CDT 2007
Hi Ron,
Ask this environmental scientist if there already exists in soil large amounts of carcinogenic materials? Coal is a carcinogen. Emission from coal fired power plants include mercury, uranium, thorium, radon, SOx, NOx, and particulate soot (which is PAH); all proven carcinogens. Is it possible the risks of those emissions are greater than Acetic acid from wood. Ask if forest fires cause increases in cancer near them, because they sure do increase the amount of charcoal on top of soil under them? Ask also, if ingesting the carcinogens (i.e. eating dirt) or drinking contaminated water is the only way the contamination can effect human or animal health? Ask if he knows what polycyclic aromatic hydrocarbons are soluble in water? Ask if he knows what the source of the PAH is that contaminates the soil in his city? Ask if he knows the specific chemical composition of the PAH which pollute ground water near him?
Saying CARCINOGENS = SHOWSTOPPER! without the research to back it up is like yelling "Fire" in a theatre. I doubt a million Amazonian ancient people suffered from cancer instead of starvation.
Regards,
SKB
----- Original Message -----
From: Ron Larson<mailto:rongretlarson at comcast.net>
To: Tom Miles<mailto:tmiles at trmiles.com> ; 'Sean K. Barry'<mailto:sean.barry at juno.com> ; 'David Yarrow'<mailto:dyarrow at nycap.rr.com> ; terrapreta at bioenergylists.org<mailto:terrapreta at bioenergylists.org>
Sent: Tuesday, March 27, 2007 12:10 PM
Subject: Re: [Terrapreta] USDA organic certification standards
Tom etal:
I have recently communicated with a well known environmental scientist who is working in the area of improving degraded soils - trying to get his involvement in terra preta activities. He wrote back today on a topic which is closely related to your issue below of organic certification, saying in part:
We have read much about biochar. Do you have data
on its PAH content and its mobility in ground water? I live in a city that
has PAH contamination of ground water, so I know how harmful it can be.
Wikipedia says about PAH (emphasis added): "Polycyclic aromatic hydrocarbons, also known as PAH, are chemical compounds that consist of fused aromatic rings and that do not contain heteroatoms and that do not carry substituents. Many of them are known or suspected carcinogens. They are formed by incomplete combustion of carbon-containing fuels such as wood, coal, diesel, fat, or tobacco.
I have started trying to learn more. However, some of the pyrolysis experts on our list may be able to speed up getting an answer to this important question. Clearly this could be a showstopper. We don't want to be accused of placing carcinogens into the soil. Perhaps if the amounts are there but of small amount, it will also be important on their mobility and any propensity for aggregating in some commercial product.
Anyone able to suggest a line of investigation on rrelationships between PAH and biochar?
Ron
----- Original Message -----
From: Tom Miles<mailto:tmiles at trmiles.com>
To: 'Sean K. Barry'<mailto:sean.barry at juno.com> ; 'David Yarrow'<mailto:dyarrow at nycap.rr.com> ; terrapreta at bioenergylists.org<mailto:terrapreta at bioenergylists.org>
Sent: Monday, March 26, 2007 8:24 PM
Subject: Re: [Terrapreta] USDA organic certification standards
If there is a special value of charcoal for the organic farmer then we need to start the process to make sure that the door is not closed to charcoal in this high value market. Organic farmers may be more disposed to using charcoal than others.
In the last week I have been thinking about the application of charcoal as I have driven from the Canadian border to San Francisco. This covers a strip of agriculture about 30 miles (50 km)wide and 1000 miles (1500 km) long. I am reminded of the crops and soils as I travel. And I try to identify the most suitable values charcoal has to offer to a Western farmer in this region. Cation exchange capacity may be one. Water holding may be less important. Richard's use of charcoal for rehabilitation of depleted soil. Or, special purposes like providing a media for inoculation or root development may be useful. We need to find those values that are important to the growers or we will not see terra preta in use.
Tom
From: Sean K. Barry [mailto:sean.barry at juno.com]
Sent: Monday, March 26, 2007 7:08 PM
To: 'David Yarrow'; terrapreta at bioenergylists.org; Tom Miles
Subject: Re: [Terrapreta] USDA organic certification standards
Hi Tom,
Sand maybe (to help with drainage)? Gypsum (calcium sulfate dihydrate), clay, vermiculite, and perlite are all minerals with low solubility and help soil hold water. Gypsum releases nutrients and improves soil structure. Vermiculite has high cation exchange capacity. I believe charcoal is insoluble.
SKB
----- Original Message -----
From: Tom Miles<mailto:tmiles at trmiles.com>
To: 'David Yarrow'<mailto:dyarrow at nycap.rr.com> ; terrapreta at bioenergylists.org<mailto:terrapreta at bioenergylists.org>
Sent: Monday, March 26, 2007 8:31 PM
Subject: Re: [Terrapreta] USDA organic certification standards
What's the intent of (6)? Does it allow coal with low volatile matter?
Tom Miles
From: terrapreta-bounces at bioenergylists.org<mailto:terrapreta-bounces at bioenergylists.org> [mailto:terrapreta-bounces at bioenergylists.org] On Behalf Of David Yarrow
Sent: Monday, March 26, 2007 12:57 PM
To: terrapreta at bioenergylists.org<mailto:terrapreta at bioenergylists.org>
Subject: Re: [Terrapreta] USDA organic certification standards
----- Original Message -----
From: Douglas Clayton<mailto:dnclayton at wildblue.net>
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<mailto:dyarrow at nycap.rr.com>
www.championtrees.org<http://www.championtrees.org/>
www.OnondagaLakePeaceFestival.org<http://www.onondagalakepeacefestival.org/>
www.citizenre.com/dyarrow/<http://www.citizenre.com/dyarrow/>
www.SeaAgri.com<http://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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