NATIONAL ORGANIC PROGRAM PROPOSED RULE

USDA estimates retail sales of organic foods in 1999 at approximately $6 billion. The number of organic farmers is increasing about 12% per year and now stands at about 12,200 nationwide, most of them small-scale producers. There are currently 36 private organizations and 13 state agencies that certify organic farms. On March 13, the USDA issued its second National Organic Program (NOP) proposed rule. This draft considered 275,603 comments from the public that followed the first proposed rule issued in December 1997. Those comments ‘nearly universally' opposed the use of genetic engineering, sewage sludge, and irradiation, and the new rule prohibits these technologies in the production or organic foods. Many other changes were made to the rule in response to public comments, including a reduction in fees that will initially be charged to certifying agents such as NOFA-VT. In my opinion the USDA deserves credit for addressing the public's concerns and for formulating a much-improved rule. Comments on the new rule must be received by USDA by June 12, 2000. A final rule is expected to be issued by the end of the year. Then, there will be a phase-in period of at least 18 months so that certifying agencies can be approved and farmers and processors adjust to the new standards. Information on the proposed organic rule can be accessed on the web at http://www.ams.usda.gov/nop/ or by calling (202)205-7806.

The NOP is intended to ensure that organically labeled products meet consistent national standards. Any farm, wild crop harvesting, or handling operation that wants to sell an agricultural product as organically produced will be affected by the proposed national organic standards. Handling operations include processors, manufacturers, and repackers of organic products. Operations that sell less than $5,000 a year in organic products are exempted from certification and preparing an organic system plan, but they must operate in compliance with these regulations and may label products as organic. A civil penalty of up to $10,000 can be levied on any person who knowingly sells or labels as organic a product that is not produced and handled in accordance with the NOP.

The proposed organic crop production standards say that land would have no prohibited substances applied to it for at least 3 years before the harvest of an organic crop. Crop rotation would be implemented. Soil fertility and crop nutrients would be managed through tillage and cultivation practices, supplemented with animal and crop waste materials and allowed synthetic
materials. Preference would be given to the use of organic seeds and other planting stock, but a farmer could use non-organic seeds and planting stock under certain specified conditions. Crop pests, weeds, and diseases would be controlled primarily through management practices including physical,  mechanical and biological controls. When these practices are not sufficient, a biological, botanical, or ‘allowed' synthetic substance may be used.

Under the NOP, farm and processing operations that grow and process organic foods must be certified by USDA-accredited certifying agents.  Labeling requirements are based on the percentage of organic ingredients in a product. Products made entirely with certified organic ingredients may say ‘100% organic', products containing at least 95% certified organic ingredients may be labeled ‘organic', products containing 50 to 95% certified organic ingredients may say ‘made with organic ingredients', and products made with less than 50% certified organic ingredients cannot be labeled organic, but can identify which ingredients are organic in the ingredient statement. Only products containing 95% to 100% organic ingredients can use the USDA Organic seal. Products that contain 50 to 95% organic ingredients can only be labeled ‘made with organic' if their non-organic ingredients are not made using any prohibited practices, such as genetic engineering, sludge or irradiation.

I see a few areas of possible concern in the proposed rule to organic growers. One is the manure and compost management requirements, which are much more stringent than currently required by NOFA-VT. Under the proposed rule, to be applied to soil used to grow organic crops, manure must either be composted or applied at least 90, and in some cases 120, days prior to harvest. The proposed rule also requires that compost and composting facilities meet the Natural Resources Conservation Service (NRCS) practice standard Code 317.

PHYTOPHTHORA MANAGEMENT (adapted from Colorado and Connecticut extension)

Losses to Phytophthora were severe on several vegetable farms in Vermont last year. This disease may be called fruit rot or crown and root rot in cucurbits, blight in pepper, buckeye rot in tomato and fruit rot in eggplant. The soil-borne fungus is favored by high humidity and temperature, standing water and soil compaction. The pathogen can survive in infested debris, soil and seed. Disease management involves crop rotation, clean seed and transplants, proper seedbed preparation, careful cultivation and irrigation, and fungicides where appropriate.

Fruit rot begins with a watersoaked or depressed spot, often on the underside of the fruit where there is soil contact. White, yeast-like growth is often seen in the spot. This growth is not thick. The rot progresses rapidly through the fruit until it is completely rotted and collapses. This disease can also be post-harvest. Crown and root rot begins as a sudden, permanent wilt of infected plants without a change in color. The roots and stem near the soil line turn brown and become soft and watersoaked. Soon the stems collapse. The plants may easily be pulled from the soil because the roots have rotted completely. Plants often die within a few days.

Prevention is key to management of Phytopthora. Rotate away from cucurbits, tomatoes, peppers and eggplant for at least 3 years. For these crops, it is critical to select fields where Phytophthora has not occurred in the past. Plant susceptible crops only on well-drained sites and do not over-irrigate. Be on the lookout for irrigation leaks that cause puddles and wet spots where the disease may get started. If a field has a wet spot, consider planting that area to a cover crop instead of a susceptible crop. Where compaction is a problem, subsoiling may be helpful to improve drainage. Use dome-shaped raised beds for non-vining crops. Thoroughly clean equipment when moving between fields, as equipment is the most important way the fungus is brought into a field. Adding compost to the soil can help control this disease. See current recommendations for chemical control measures.

FARMING FOR A LIVING - PART III

(From Jim and Moie Kimball Crawford of New Morning Farm, Hustontown, PA)

We'd like to put in our two cents worth on the continuing discussion of  "farming for a living."  Many of the contradictory things already said nevertheless ring totally true to me. This life is much too hard, yes, and  yet every hardship has ample compensation, for us, anyway.  As absurdly low as our income is, how many intangible plusses there are to this life: living in beautiful surroundings, eating the world's best food, having more control over our working lives than most anyone else, having a sense of purpose and of the intrinsic value of our products, never being bored, always learning, etc. (just to add a few to Paul and Sandy Arnold's list).

On the other hand, too many of us paint too rosy a picture. We may be happy, but are we sustainable economically? We need the experience, the honesty (or the accounting expertise) to realize and admit that most of us are not making a living on our farm production. If you say you're making it, and especially if you're offering yourself as a model to others, here are a few hard questions:Are you surviving on the underpaid labor of others? Are you including off-farm income that shouldn't be considered? Are you excluding return on investment from farm income? (You should be, because if your assets are small and debt is high, then interest is a big expense in calculating your income (this is our case). Conversely, if your assets are large and debt is small then you could be making the same income from cashing out and buying mutual funds. In this case, your income depends on your assets and not your farm production.Your income statement can't fairly be compared to the first example. Comparing incomes in these two examples is meaningless without eliminating this variable.)  Are you paying all your expenses from gross farm income or is the trust fund or someone else covering some of them? Are you ignoring the actual (not IRS) depreciation of your assets? Are you saving for retirement and/or paying down your debt fast enough? Are you buying health insurance?

Without considering all of these questions, and more, we can't claim to be making it on farm income. So I'm not "pissing and moaning." I love what I do and won't stop until I have to. But grim reality is that we're not at all sure that we're economically viable and sustainable over the long term.The economic returns are so small and the pressures so great that the number of us capable and/or willing to continue may soon shrink to zero. We personally don't mind (too much) working 60-80 hours per week for six or eight thousand dollars per year (really!). We have been, for 30 years. But could we survive, and could we retire on this?  (We're surviving and will retire on other income.) And then can we find clear-eyed, hard-nosed (albeit idealistic) people in the next generation who will be willing to take over and carry on for the long term?  If not, then this isn't sustainable agriculture, as wonderful as it may be.