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OTA submits comments on raw manure as fertilizer

The U.S. Food and Drug Administration (FDA) released a Federal Register notice requesting scientific data, information, and comments that would help the agency develop a risk assessment for produce grown in fields or other growing areas amended with untreated biological soil amendments of animal origin, including raw manure. The risk assessment will evaluate and, if feasible, quantify the risk of illness associated with consuming produce grown in fields amended with untreated manure. Along with the notice, FDA has available a related Q & A interview with Samir Assar, Director of FDA’s Division of Produce Safety. 

The Organic Trade Association (OTA) and The Organic Center partnered with UC Davis to conduct a survey of organic produce farms to characterize the use of untreated manure and compost in organic production. This survey received over 600 responses from organic farmers across the country, and the data from the survey was submitted by OTA in our comments to FDA. The survey shows that raw manure remains a critical tool in organic farmers’ fertility management, and that excessively long waiting times following the use of raw manure will impact organic farmers’ ability to rotate crops. OTA has weighed in to FDA with this data, stressing the need for any wait period included in the final rule to be based on current science and not duplicate or conflict with existing organic regulations.

Read OTA's Comments Submitted to FDA