COMMENT
of the Organic Trade Association
on the
National Organic Standards Board draft:
“Greenhouse Standards”
July 31, 2001
Submitted by
Tom Hutcheson, Policy Coordinator
Organic Trade Association
P.O. Box 547, Greenfield, MA 01302
Almost all of these proposed changes to the NOSB draft greenhouse recommendation were thankfully submitted as a draft by Emily Brown Rosen of the Organic Materials Review Institute and are shown in underlined text, with deleted text shown in strikeout format. The intent of these changes is to incorporate fully the original 1995 NOSB recommendation, some additional material supported by the OTA’s American Organic Standards, and also refer correctly to the applicable parts of the Final Rule. These references will incorporate requirements for record keeping, farm plan, as well as applicable crop standards. These standards are not meant to cover non-soil based systems, and we believe that NOSB needs to separately address these types of cropping systems.
Add a definition of greenhouse: enclosed structure used to grow organic crops , seedlings, or planting stock used in organic production.
NOSB recommendation on Greenhouses, with proposed changes
205.209 Greenhouse Production Systems
(a) The producer operating a Greenhouse operations must meet all applicable requirements of the Rule, including subpart C (205.200-205.206) except that:
(1) The producer operating a greenhouse with crops grown in containers is exempt from requirements of 205.202, 205.203(a-b), and 202.205, provided the production environment prevents contact between organically produced crops and prohibited substances as listed in §205.105 throughout the entire growing cycle.
(2) The producer operating a greenhouse with an in-ground, permanent soil system must comply with all applicable provisions within these regulations, including the three year prohibition on the application of prohibited substances, and the inclusion of sound soil building and crop rotation strategies.
(b) The producer operating a greenhouse with a bench system must establish and maintain a production environment which prevents contact between organically produced crops and prohibited substances throughout the entire growing cycle.
(c) The use of potting mixtures containing prohibited materials is not allowed.
(b) (d) Producers may use artificial light sources.
(c) (e) Crop pest weed and disease control must comply with requirements of 205.206, except that;
(1) Plants shall not be in direct contact with wood treated with prohibited materials that are used for greenhouse structures or frames of raised beds.
If a producer is growing both organic and non-organic greenhouse crops using a bench system, it is recommended that those crops be grown in separate greenhouse structures.
(d) Organic and non-organic crops can be grown within the same structure if the following conditions are met:
(1) If synthetic prohibited pesticides are applied to the non-organic crops, an impermeable wall shall separate organic and non-organic production sites; and the ventilation system must ensure that prohibited materials do not drift to the organic production area.
(2) Irrigation systems, through which synthetic fertilizers or other prohibited materials have been injected or introduced shall not be used for organic production.
(3) Soil mixing machines and other equipment used for non-organic crop production must be thoroughly cleaned prior to use in organic production.*
(4) (i) Adequate physical facilities, as determined by the certifying agent, shall separate organic and non-organic crops and production materials, in storage, production or holding areas. for shipping.
(5 ) (j) Organic and non-organic crops and production areas as on farms which contain both organic and non-organic crops must be conspicuously labeled.
*Rationale: In both the greenhouse and mushroom standards there is a prohibition against using equipment that has been used for prohibited materials. There is no equivalent prohibition for crop production that would prohibit the use of, say a sprayer, that had been used for prohibited materials. All that is required, under both the AOS and the Rule, is adequate cleaning to prevent contamination. The proposed prohibition places an unfair burden on producers of these specialty crops who are in split production, or who have transitioned to organic. They would have to replace all of the affected equipment--and when buying that equipment, organic mushroom and greenhouse producers couldn't buy any used equipment unless they could prove that it had never been used for delivery of a prohibited material. Compliance with cleanout requirements can be verified through current recordkeeping, inspection, and certification protocols.
