Many consumers and organic farmers, if challenged to describe the production principals of organic agriculture, might list practices that build soil fertility, maintain ecological balance, promote biodiversity, reduce dependence on off-farm inputs, and allow farm animals to display their natural instinctive behaviors. But in the topsy turvy world of “food safety,” every one of those organic principals is being seriously challenged at regulatory levels. Because those principals are so fundamental to the way we farm at Full Belly, you will have to forgive us if we seem to return to this subject over and over.
Paul wrote in this column last week about the proposed FDA Produce Rule. Since then I have read the FDA’s proposed “guidance” for egg producers that provide hens with access to the outdoors (in other words “pastured poultry.”) In that document, there are absurd suggestions, like providing overhead cover to the outdoor pasture so that wild birds can’t swoop in and infect the hens (or be infected) with Salmonella. In addition, this rule admonishes that “Disposable or reusable clothing should be provided for visitors, including maintenance and pest control personnel, as they come onto the farm.” The FDA clothing recommendations include “bouffant caps” to cover hair!
We may tell you more about the egg rule later, but in the weeks since the FDA’s Produce Rule was released, I spent some time thinking about the proposal in that rule to regulate the use of compost on the farm. I’ve talked with our compost supplier and with other compost manufacturers. I’ve spoken with other farmers and also reviewed the Organic Trade Association’s draft response to the new regulation of compost.
Compost is a subject that organic farmers love to talk about! When I give tours of Full Belly Farm I often stop at the compost pile and encourage people to smell and touch the finished compost. A few days ago, in a conversation with Tom Willey (www.tdwilleyfarms.com), an organic farmer in Madera, he made the following statement: “If you have appropriately tested pathogen-free compost, its use should be recommended by FDA as a food safety measure. That’s what the science says.” If he could possibly be right about this, why would the FDA be so concerned about compost that they appear to view it as a dangerous substance? The FDA thinks that there should be a 45-day waiting period between applications of compost and harvest of crops. But organic farmers think that the FDA should be RECOMMENDING compost as an approach to human pathogen suppression. These views are opposite and incompatible.
The reason that organic farmers are so excited about compost isn’t because of its fertilizing benefits as much as because of it’s soil building benefits. At Full Belly Farm, we use compost on every field before planting because it suppresses plant diseases; it converts nutrients to more stable forms that don’t leach out of the soil into ground water; and it increases the soil microbial complexity, thus ensuring that nutrient cycles (which rely on soil microbes) will be fully activated. Compost also improves the water holding capacity of soil so that farmers have to irrigate less. The manufacture of compost from green wastes is seen by many cities as the only way that they are going to be able to reduce the waste stream that they send to the landfill.
A recent literature review of the “Ecology of E.coli O157:H7 and Salmonella enterica in the Primary Vegetable Production Chain” (E. Franz and A. H. C. van Bruggen) gives a great deal of support to Tom Willey’s statement. The article concludes that soils high in microbial diversity, high in organic matter and low in easily available nutrients like nitrogen (i.e. soils treated with compost) have “the potential to decrease pathogen persistence.” (And they’re talking about the notorious E. coli O157.) The authors recommend more research, but they better get a move on. The FDA seems to be making up its mind!
I want to repeat Tom Willey as the last word in this note, because he said it so well: “If you have appropriately tested pathogen-free compost, its use should be recommended by FDA as a food safety measure. That’s what the science says.”
— Judith Redmond
