• Grace Gershuny

Soil health--not elite labels for niche markets-- can save the planet

Updated: Jul 28


A new organization called the Vermont Healthy Soils Coalition (VHSC) is fast becoming an important vehicle for my local activism. A focused but diverse interest group, VHSC states its intention to “shift the paradigm of how people interface with the land. We operate under the premise that we can restore land water cycles by covering Vermont's bare soil; nurturing photosynthesis, biodiversity and the biology underground.” This wonderful purpose fits right in with the urgent message that I have been bringing to everyone I meet, consistent with the theme of “organic farming for the planet.”

Nurturing soil health has always been a cornerstone of organic agriculture (notwithstanding the fact that not all organic products are grown in soil—a debate that I am thoroughly sick of having). Lately some new terms have been promoted to identify goals that would go “beyond organic,” such as “resilient” or “regenerative” agriculture. These are both important concepts that speak to the need to adapt to the shocks of a changing climate, and to repair the damage done by the 99% of US farmland still managed under the agrichemical-industrial model.

What has me a bit perplexed and frustrated at times is why some folks feel it necessary to promote a new marketing label, as is being done by respected entities likethe Rodale Institute, and even the Savory Institute. These label claims often represent an implicit (and sometimes explicit) claim

that the organic label, along with the standards behind it, no longer reflects the goals and values of resilience or regeneration, and the belief that so-called “industrial organic” production actually degrades soil.

As a principal author of the National Organic Program standards I am proud of having ensured that every section of the production standards requires that the farmer "maintain or improve" soil and water quality, biodiversity, and other "natural resources of the operation." In fact, organic farming that only meets the minimum NOP requirements has been shown to improve soil carbon sequestration (compared to comparable crops grown under conventional regimes) in addition to eliminating the need for highly greenhouse gas intensive synthetic nitrate fertilizer.

The marketplace and consumers “voting with their forks” has succeeded in turning a fringe movement into an economic force to be reckoned with, now accounting for something on the order of 5% of all US food sales—but it took upwards of 40 years to get here. If the organic label can’t solve all the problems of our food system, neither can those social, economic, and environmental ills be effectively addressed by marketing products under any "enhanced" label claim. The biggest culprit, as I see it, boils down to a long-term deliberate policy by agribusiness and its henchmen in Congress to force farmers off the land, keep farm prices as low as possible, encourage consolidation in the food system, and perpetuate a system of cruel labor exploitation rooted in the “original sin” of slavery on which our current economic system was founded.

A lot of confusion is generated by the belief that “USDA organic” has now been taken over by corporate agribusiness and watered down to meaninglessness. This belief creates anger by presuming that farmers who do a better job than what USDA says is required are somehow losing out by being associated with this degraded label claim. They assert that only a new label claim, representing “higher” organic standards, can accomplish what the organic label claim has failed to do—that is, transform the corporate dominated, exploitive, unhealthy food system to one that fulfills what I sometimes refer to as the “true organic vision.”

The aphorism I like to use to make this point is that “you can’t dismantle capitalism with a marketing plan.”

The myth of higher standards - How the activists still get it wrong

One of the big misconceptions that stymies efforts to counter such confusion is what I call “the myth of higher standards.” It is one of the central ideas that helped me understand and challenge the thinking that has generated so much anger and opposition towards the USDA organic program. The message is counterintuitive because so much of what we are told in all aspects of our life is that we must uphold the highest possible standards. Anyone who appears to advocate “lower standards” faces ridicule and accusations of “selling out.” What follows is a slightly edited version, excerpted from Organic Revolutionary, of my explanation of this misconception:

The assumption that our standards must be as high as possible has become very like the tale of the emperor’s new clothes in organic circles. Everyone agrees that rigor is essential – the stricter the better -- and to be adequately discriminating we must have clear bright lines to separate good from bad. Subjectivity and flexibility are dangerous, and open up the possibility of loopholes through which the unscrupulous will pass with impunity. While grey areas persist, it is only because we have too little information, and our goal should be to collect enough data to eliminate them. On the flip side, anyone who admits to being willing to accept “lower” standards is accused of advocating mediocrity, or worse, collaborating with agribusinesses who wish to take over the organic label and render it meaningless.

Yet, in fact, the push for higher standards has actually made it easier for the large, professional business organizations than for small owner-operators. They are simply better equipped to deal with the increasingly finicky and paperwork-heavy demands of organic certification. So the demand for higher organic standards has helped create the very situation that organic activists feared the most: intensified bureaucratization of organic certification, increased barriers to access to the organic market by small producers, and near elimination of the possibility that organic production systems might become any more than a small niche in American agriculture....

Standards that reflect the process of how something is produced (e.g., no sweatshops) and those that address the quality of a product (e.g., grades of lumber) are radically different. This distinction is rarely understood, but its implications are enormous. Evaluating organic standards in terms of product quality standards misses the point. Organic products are [generally] not distinguishable from similar conventional ones, whether through sensory evaluation or laboratory analysis. Will higher standards, by which the consumer usually means product quality standards, ensure that organic products are better, safer, or healthier than conventionally produced ones? Will they allow consumers to differentiate between “superior” and “ordinary” organic products? Is there any way of objectively measuring whether an organic product meets the highest organic standards? The answer to each of these questions is an emphatic “no.”

Another crucial distinction must be made between market regulation and health and safety standards. Standards whose purpose is to regulate markets, such as meat grading standards, differ significantly from those established to protect public health and safety, such as meat packing plant sanitation standards. This difference is critical for sorting out the confusion surrounding organic standards. Most people -- especially environmental activists – are accustomed to thinking of regulations of any kind as serving to protect public health and safety, and that industries want the weakest possible standards to minimize their costs. But standards whose purpose is to regulate markets are generally developed at the behest of the industry being regulated, and serve to protect the industry more than to protect the public.

The purpose of the National Organic Program, as defined by the OFPA (the organic law), is market regulation. While it does help protect the public from misrepresented products, it is not there for the purpose of protecting public health and safety, but rather to protect the industry being regulated from “substandard” goods entering the market and competing with established producers. Besides driving prices down, “lower grade” serve to endanger public confidence in the product. Much as we may believe that organically produced products are better for our health and the environment, this is not the purpose of the USDA’s organic standards.

Uniformity and standardization spring from industry’s requirements for inputs and products that are predictable and interchangeable. This has given us the possibility of mass production and the wonders of cheap consumer goods. Many critics of institutionalizing organic standards argue convincingly that these demands are anathema to organic systems. Complexity, diversity, local adaptation, and evolution do not lend themselves to the cookie cutter concept of standardization. Food from Florida should not be interchangeable with food from Wisconsin, and the appropriate methods for the organic production of artichokes in California do not resemble those for goat cheese in Maine.

However, when we look at standardization from the viewpoint of a process as opposed to a product, we can see that uniform rules do not require uniform methods to comply with the rules. Organic certification represents one of the earliest efforts to standardize a process-based label claim. Because organic systems are dynamic and evolve over time they are fuzzy, context specific, and hard to nail down definitively. In real life, organic standards can and should reflect the reality of organic methods and the philosophical concepts on which they are based.

Performance standards, which establish goals for specific outcomes to be achieved by the operation being regulated, can allow for the kind of innovative problem-solving that is a hallmark of organic farmers, and that can quickly be stifled by the need to satisfy prescriptive practice standards. In an organic system, measurable improvements in the health of any factor, such as soil quality or livestock health, can be considered a performance standard. Agroecosystem health can thus be seen as a barometer for the success of the management system, as well as an outcome or goal to be pursued.

While there is little disagreement about these basic concepts, there is also little agreement about where lines should be drawn in practice. For example, organic principles dictate that practices which enhance biological diversity must be a key requirement. However, given the realities of farming and the existing industrial food system, clear lines of acceptable versus unacceptable are hard to identify. Not only is it nearly impossible to decide how much biodiversity is enough, it is very hard to objectively measure how much biological diversity is present in a given farm or field.

Although organic standards are about the process, products can give us information about the process. Product quality may indicate something about how the process is working, but can never absolutely determine whether it passes or fails. An apple can be measured to see if it makes the grade, but worms in the apples can only serve to indicate the level of health in the orchard agroecosystem.

A process is also not static; it is a collection of activities and not a discrete material thing. Although the process cannot itself be measured, its functioning can be monitored at different times by selecting appropriate products – such as the apple example - or outcomes that can be measured. These products or outcomes are called indicators, and changes in indicators over time can be used to figure out if the process is working as intended or needs some adjustment. This creates a positive feedback loop, which ultimately provides a farmer with helpful tools for improving the overall success of the operation.

An organic process involves many kinds of products, only one of which will eventually be sold with a label that reads, “organically produced.” If the ultimate goal of organic methods is agroecosystem health, the quality of the product that is sold is but one indicator of the health of that system. [emphasis in original] This is why the first [NOP] proposed rule was intended to orient all production standards towards the SOFAH [the definition we crafted for a ‘system of organic farming and handling’], with its overarching criterion of agroecosystem health.

People often believe that we need highly prescriptive practice standards, such as those used in food safety rules, in regulating a production process. However, this form of regulation works against both creativity and ecological balance[i]. For instance, one important organic precept is that of integrating crops with livestock, both to encourage greater biodiversity and to recycle nutrients within the farm system. However, if a produce grower can only market meat or eggs as organic by following a strict requirement for 100% organic livestock feed, she may forego raising her own livestock and buy in manure or compost from conventional livestock or food processing operations. Does this farm adhere to higher standards than one that includes animals who are fed some portion of local (mostly nonorganic) food waste?

The insistence on higher organic standards may also come into conflict with the principle of regional food self-reliance. Livestock operations are often the most ecologically sound form of agriculture on hilly, thin upland soils, which may also harbor endemic sheep parasites that resist the most scrupulous preventive health care. Is it really better to prohibit synthetic worming agents for organic sheep production if it means that organic lamb cannot be reliably produced in certain regions? Most tree fruit grown in humid climates is highly susceptible to diseases that are mainly cosmetic problems, such as sooty spot on apples. Is it consistent with organic principles to make it extremely difficult to raise high-quality organic apples in the humid East, where apples are otherwise well adapted?

Ultimately, the integrity of the system is upheld by attention to enforcement, not by setting the standards bar ever higher.[emphasis added] Given the imprecision and judgment calls inherent in measuring agroecosystem health, though, at what point would it become clear that the system does not qualify as organic? The answer depends largely on whether a minor infraction is willfully repeated, without effort to correct it. In practice, loss of organic certification is rarely if ever a result of too many minor infractions, but rather evidence of deliberate violation of the most critical rules. Legally, organic certification is considered to be a license granted by the USDA; before the government can take away a license granted to any citizen, a lengthy process with multiple appeal opportunities must be followed.

Consistent standards are a necessary step in the development of a broader organic market, but this is only one step towards the more radical agenda of the organic movement – to transform the way food is produced and distributed in this country. Standards for changing behavior should be attainable by the majority who, by definition, will just be “pretty good.” One goal of our education system, for example, is to make sure that every child is able to complete high school and to achieve basic competencies. As my friend Katherine DiMatteo has said, “Do we want organic farmers to only be those who get the A’s?”

[i] Organic advocates have more recently come to recognize the problematic nature of highly prescriptive practice standards for food safety, with promulgation of new regulations implementing the Food Safety Modernization Act.

Regenerating our society

The marketplace has served a valuable function, if only to awaken the public to the realization that there is something very wrong with the agri-industrial food system as it is now. Those who throw brickbats at USDA organic and seek to promote another marketplace label as superior or more authentic have already done serious damage to the public’s confidence in organic products, bolstered the charge of organic as niche products for the elite market, and sowed confusion and division within the organic community. This does nothing to advance the spread of resilient or regenerative agriculture among beleaguered conventional farmers, desperate for a way out of the toxic treadmill. But it does provide ammunition to the agribusiness-as-usual apologists who take every opportunity to discredit and delegitimize the organic movement.

Ultimately, the solutions to saving the planet and human civilization have to be political and cultural, not just focused on the marketplace. It has been refreshing to join forces with a group of people in the Vermont Healthy Soils Coalition who are committed to working towards regenerating the “soil carbon sponge” in a positive and inclusive way. Advocating for a shared vision of healthy soil, clean water, and flourishing farms and communities through diverse strategies, without needing to disparage anyone’s contributions, is the most persuasive approach to changing destructive land management practices for the benefit or soil, people, and planet.


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