Organic Food – USDA Rules and Regulations

Whether it’s a plant or an animal, we eat what our food eats. USDA organic food rules and regulations are more interesting than you may think.

What’s the difference between an organic bell pepper, chicken, or glass of milk and its conventional agriculture counterpart? The main differences are the land it is grown or raised on, what does or does not go in or on it, and how it is labeled.

In the U.S., the USDA National Organic Program (NOP) regulates organic agricultural products (food crops, livestock, and non-food crops). A previous post, Organic Food – USDA National Organic Program, provided an overview of the NOP including certification requirements, the roles of certifying agents and the National Organic Standards Board, and the ramifications of violating the NOP.

In this post, we’ll look at requirements for growing and handling organic crops and livestock and learn about substances that may and may not be used in and on organic food. A separate post will examine USDA Organic categories and labeling.

Prior to slogging through organic food regulations, I thought of organic mostly in terms of whole fruits and vegetables and packaged items like peanut butter. As it turns out, a large chunk of the regulations applies to livestock animals such as cows, chickens, and pigs, and animal products like meat, eggs, and milk.

Allowed and Prohibited Substances, Methods, and Ingredients

NOP regulations stipulate the following substances, methods, and ingredients may not be used to produce or handle organic products, except as noted on the National List (which we’ll discuss later):

Synthetic substances are prohibited except as allowed on the National List.
Non-synthetic substances are allowed except as prohibited on the National List.
Non-agricultural substances are prohibited except as allowed on the National List.
Non-organic agricultural substances are prohibited except as allowed on the National List.
Excluded Methods are prohibited, except vaccines as allowed on the National List.
Ionizing radiation is prohibited.
Sewage sludge is prohibited.

Interestingly, one must delve into section 205.2 Terms Defined of the regulations to learn that genetically modified organisms (GMOs) are prohibited under Excluded Methods.

Organic Production Requirements

Organic production pertains to farms and ranches that grow crops and raise livestock.

The intent of organic production is to improve and maintain the quality of the land, water, and air, avoid using synthetic substances and provide livestock animals with food and habitat conducive to their health and wellbeing.

Soil and Seeds

The condition of the land used to grow food for people and livestock is an essential element in organic farming. For at least 3 years immediately before harvest, no prohibited substance may be applied to land used to grow organic crops. In addition, buffer zones are required to prevent unintended application of prohibited substances from adjoining land that isn’t under organic management.

Instead of applying synthetic fertilizers, soil fertility and health are sustained by selecting plants appropriate to the area, rotating crops, planting cover crops (to provide soil nutrients like nitrogen), applying plant materials, and spreading animal manure (usually composted).

Organic seeds, seedlings, and planting stock are required, with a few exceptions.

Pest, Weed, and Disease Management

Healthy soil contributes to minimizing pests, weeds, and disease. Pests are controlled by planting a variety of crops together (less food for specific pests), introducing pest predators, and using lures and traps. Mulching, mowing, weeding, and livestock grazing keeps weeds down. Applying non-synthetic biological, botanical, and mineral inputs suppress the spread of disease.

When the preferred prevention and control practices are insufficient, an allowed substance from the National List may be used, provided that it is documented in the organic system plan each certified operation is required to submit annually.

Livestock Origin, Feed and Health Care

In order to sell livestock as organic, it must be under continuous organic management from the last 1/3 of gestation or hatching, except organic management must begin on the 2nd day of life for poultry, and dairy animals must be under organic management for 1 year prior to production of milk or milk products.

Feed for livestock follows the same requirements as food crops. Certain practices are prohibited such as:

Administering drugs or hormones to promote growth.
Feed supplements above those needed for animal nutrition and health.
Feed containing plastic pellets, urea, manure, slaughter by-products, or antibiotics.

Ruminants (cows, goats, and sheep) are required to have access to pasture grazing for not less than 120 days a year and must receive at least 30% of their dry food from grazing.

Yards, feeding pads, and feedlots may be used temporarily and under certain circumstances like bad weather, for milking or shearing, to treat illness, and to sort for shipping. Ruminants that are grain finished, meaning they are fed grain instead of pasture just prior to slaughter, may not spend more than 120 days or 1/5 of their lives in a feedlot.

Livestock health care focuses on providing nutritious food, maintaining sanitary conditions, allowing for exercise and freedom of movement, providing access to shelter, fresh air, and clean water, and administering vaccines and non-synthetic medications allowed on the National List. Medical treatment may not be withheld from an animal to maintain its organic status, however, livestock treated with prohibited substances may not be sold as organic.

Organic Handling Requirements

A handling operation receives, processes, packages, stores, and distributes organic products. Key requirements include:

Mechanical and biological methods are to be used to process and preserve organic food, such as cooking, roasting, slaughtering, freezing, and canning to name a few.
Pests are controlled using methods similar to those used by producers.
Organic products must be kept separate from products not produced organically, including storage containers and packaging materials.

National List of Allowed and Prohibited Substances

The National List of Allowed and Prohibited Substances, known as the National List, is a list of synthetic substances that are allowed and non-synthetic substances that are prohibited from use to produce, process, or handle organic agricultural products. The National Organic Standards Board recommends additions and deletions to the National List for approval by the Secretary of Agriculture.

Criteria used to evaluate substances and ingredients include:

A substance cannot be produced from a natural source and there are no organic substitutes.
Substance’s manufacture, use, and disposal do not have adverse effects on the environment and are compatible with organic handling.
Nutritional quality of food is maintained and substance itself or its breakdown products do not have adverse effects on human health.
Substance’s primary use is not as a preservative or to recreate or improve flavors, colors, or textures, or nutritive value lost during processing.
A substance is listed as generally recognized as safe (GRAS) and contains no residues of heavy metals or other contaminants in excess of tolerances set by the FDA.
A substance is essential for the handling of organically produced agricultural products.

Substances on the National List are divided into several categories specific to crops and livestock. The National List details the circumstances under which an allowed substance may be used, the frequency of application, and any limitations, say to a specific crop or animal. A few examples are noted below.

Synthetic Substances Allowed for Crops – include copper sulfate, hydrogen peroxide, boric acid, elemental sulfur, and sodium silicate.
Non-synthetic Substances Prohibited for Crops – include substances that occur naturally but shouldn’t be used on food like arsenic and strychnine.
Synthetic Substances Allowed for Livestock – include biologic vaccines and chlorine for disinfecting equipment and facilities.
Non-agricultural (non-organic) substances allowed in or on processed products (not allowed for 100% organic products) – include calcium carbonate, agar-agar, ascorbic acid, xanthan gum, and potassium chloride.
Non-organically produced agricultural products allowed as ingredients (not allowed for 100% organic products) – include celery powder, pigments from fruits and vegetables, gelatin, cornstarch, and fortified cooking wines.

Summary

Hopefully, after reading this post you feel more informed about how organic food is grown and what substances may and may not be used in and on it. In the next post, we will learn about USDA Organic categories and what the USDA Organic label means.

Resources

Author: Linda Poppenheimer

Linda researches and writes about environmental topics to share information and to spark conversation. Her mission is to live more lightly on Earth and to persuade everyone else to do the same. View all posts by Linda Poppenheimer