COMMENT
of the Organic Trade Association
on the
National Organic Standards Board draft:
“Mushroom 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 mushroom 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, and also refer correctly to the applicable parts of the Final Rule. OTA suggests expanding the definitions to more completely consider other different types of fungal products that may be organically produced.
Add the following Definitions:
Culture: a microorganism, tissue, or organ growing on or in a media
Media: the substance in which an organism, tissue, or organ exists
Fungi: the fruiting body of an edible fungus
Substrate: the portion of media metabolized by an organism
NOSB Recommendation on Mushroom Practice Fungi Practice Standards
205.208 Fungi practice standard
(a) Facility or site requirements
Any site from which harvested crops are intended to be sold, labeled, or represented as "organic," must:
(i) If an outdoor site; have had no prohibited substances, as listed in § 205.105, applied to it for a period of 3 years immediately preceding harvest of the crop; and
(ii) If an indoor facility, must demonstrate to certification agent that no prohibited substances, as listed in § 205.105 will compromise the organic integrity of the fungi production system.
(b) The producer must maintain a production environment that prevents contact between organically produced mushrooms fungi and prohibited substances as listed in § 205.105 throughout the entire growing cycle, harvesting and post harvesting process.
(i) Pest, disease, and weed control methods must be according to 205.206 The producer must not use lumber treated with aresenate or prohibited materials for new installations or replacement purposes in contact with the growth substratemedia.
(ii) Nonsynthetic or synthetic sanitizers and disinfectants included in §205.601,205.603 or 205.605 and labeled for such purpose may be applied to crops or growing substrate media, or crop facilities.
(cb) The producer must use organically produced spawn, Except, that nonorganically produced spawn that that have has not been treated with a prohibited substance and have has not been raised on GMO substrate may be used when organically produced spawn are is not commercially available.
(c) Uncomposted media
(i) Agricultural materials other than manure, such as including grain and or straw that are used in production uncomposted media substrate must be organically produced. Sawdust, logs or other materials derived from wood used as a growth substrate medium must originate from trees that have been grown in areas free of prohibited materials for at least three years, and must not have been treated with a prohibited substance after tree harvest.
(ii) Producers may include nonsynthetic, nonagricultural materials in substrate media used to produce mushrooms fungi.
(d) Composted media
(i) Manure and any nonorganic agricultural material used as a growth substrate medium must be composted. Compost used as a growth substratemedium must be produced in accordance with compost guidelines presented in 205.203 (c) (2) before it is inoculated.
(ii) Producers may include non-synthetic, non-agricultural materials and any synthetic substances on 205.601(c) (compost feedstocks) in substrate media used to produce fungi.
(e) Organic and non-organic fungi can be grown indoors within the same structure if the following conditions are met:
(1) If prohibited materials which could migrate 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) Equipment used for non-organic fungi production must be thoroughly cleaned prior to use in organic production.*
(4) Adequate physical facilities, as determined by the certifying agent, shall separate organic and non-organic fungi and production materials, in storage, production or holding areas.
(5 ) Organic and non-organic fungi and production areas 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.
