Formal Recommendation From: National Organic Standards Board (NOSB) To: The National Organic Program (NOP) Date: November 2, 2017 Subject: Aeroponics NOSB Chair: Tom Chapman The NOSB hereby recommends to the NOP the following: Rulemaking Action: X Statement of the Recommendation: The NOSB Recommends that aeroponic production be prohibited from organic certification. Rationale Supporting Recommendation: The NOSB recommends prohibiting aeroponic production systems from organic certification because they do not meet the requirements of OFPA or the Organic Rule. While many in the organic community supported various types of hydroponic production where terrestrial plants had their roots either in water or an inert substrate, and the plants are reliant on continuous application of fertility inputs for their nutrients, there was little to no support for aeroponic systems where terrestrial plants are suspended in the air and misted with nutrient rich water. NOSB Vote: Motion to prohibit aeroponic production systems from organic certification. Motion by: Emily Oakley Seconded by: Harriet Behar Yes: 14 No: 0 Abstain: 1 Absent: 0 Recuse: 0 Outcome: Motion passed Formal Recommendation From: National Organic Standards Board (NOSB) To: the National Organic Program (NOP) Date: November 2, 2017 Subject: Aquaponics NOSB Chair: Tom Chapman The NOSB hereby recommends to the NOP the following: Rulemaking Action: None Statement of the Recommendation: None. The motion to prohibit aquaponics failed, and no recommendation was made. NOSB Vote: Motion to prohibit aquaponic production systems from organic certification. Motion by: Harriet Behar Seconded by: Jesse Buie Yes: 7 No: 8 Abstain: 0 Absent: 0 Recuse: 0 Outcome: Motion failed Formal Recommendation From: National Organic Standards Board (NOSB) To: the National Organic Program (NOP) Date: November 2, 2017 Subject: Container Growing NOSB Chair: Tom Chapman The NOSB hereby recommends to the NOP the following: Rulemaking Action: None Statement of the Recommendation: None. The motion to limit organic certification of crops grown in containers to containers/crop systems that meet the requirements as outlined below, failed. NOSB Vote: Motion that for container production to be certified organic, a limit of 20% of the plants’ nitrogen requirement can be supplied by liquid feeding, and a limit of 50% of the plants’ nitrogen requirement can be added to the container after the crop has been planted. For perennials, the nitrogen feeding limit is calculated on an annual basis. Transplants, ornamentals, herbs, sprouts, fodder, and aquatic plants are exempted from these requirements. Motion by: Francis Thicke Seconded by: Steve Ela Yes: 7 No: 8 Abstain: 0 Absent: 0 Recuse: 0 Outcome: Motion failed Formal Recommendation From: National Organic Standards Board (NOSB) To: the National Organic Program (NOP) Date: November 2, 2017 Subject: Hydroponic production systems NOSB Chair: Tom Chapman The NOSB hereby recommends to the NOP the following: Rulemaking Action: None Statement of the Recommendation: None. The motion to prohibit the organic certification of crops grown by hydroponic production, as defined below, failed. NOSB Vote: Motion: That any container production system that does not meet the standard of a limit of 20% of the plants’ nitrogen requirement being supplied by liquid feeding, and a limit of 50% of the plants’ nitrogen requirement being added to the container after the crop has been planted is defined as hydroponic and should not be allowed to be certified organic. For perennials, the nitrogen feeding limit is calculated on an annual basis. Transplants, ornamentals, herbs, sprouts, fodder, and aquatic plants are exempted from these requirements. Motion by: Jesse Buie Seconded by: Dave Mortensen Yes: 7 No: 8 Abstain: 0 Absent: 0 Recuse: 0 Outcome: Motion Failed National Organic Standards Board Crops Subcommittee Proposal Hydroponics and Container-Growing Recommendations August 29, 2017 Introduction Over the past year the Crops Subcommittee has prepared—and received many public comments on—two discussion documents and a proposal covering the range of growing systems in which nutrient delivery to plants is water based, including aeroponics, hydroponics, aquaponics, and plants grown in containers. We have learned that the public is divided on these issues, as are members of the NOSB. Some think that organic certification should require plants be grown in soil that is connected to the earth’s surface. Others think that organic certification should allow the growing of plants in pure nutrient solution, without the presence of any soil or compost. Others favor positions somewhere in between. Accredited organic certification agencies have been permitted to certify hydroponic operations as organic by the National Organic Program (NOP), with some agencies certifying hydroponic operations and some choosing not to. The lack of consistency among certifying agencies and lack of standards for water-based nutrient-delivery growing systems has led to the need for the National Organic Standards Board to review this issue in a holistic way and recommend a path forward to the National Organic Program. The purpose of this proposal is to delineate the range of growing systems, from soil to soilless, and make recommendations on a middle ground within that range, which we hope the NOSB and the organic community can support. To do that, we first summarize pertinent past discussions and legal considerations. Background The 1995 NOSB recommendation Standards for Greenhouses contains the statement: Hydroponic production in soilless media to be labeled organically produced shall be allowed if all provisions of the OFPA have been met. This was before there was an NOP rule so the NOSB only had OFPA to guide them. Also, that statement indicated that an analysis had not been made of whether or not hydroponics met the provisions of OFPA. The brief dialogue at the 1995 meeting indicates that while some board members were supportive of hydroponics, others had concerns about soilless production: Kahn concluded his report by reading the hydroponics recommendation that would allow organic labeling for products from soilless media if all other National Program requirements are satisfied. Baker expressed his concerns about the philosophical problems associated with soilless production. Kahn noted that the recommendation only allows for the possibility of an organic hydroponics industry developing. Kahn recognized that hydroponics is a practice that is dependent on synthetic inputs and wants to open up dialogue with its proponents. Crossley moved and Weakley seconded a motion to accept lines 101-105 as a Board Final Recommendation. Friedman first offered a friendly amendment that was accepted to strike "other applicable" from the document. Vote: Unanimous aye.1 A revised proposed rule for the National Organic Program was published in March 2000 revising the initial 1 NOSB Meeting Minutes - April 24-28, 1995. Orlando, Florida. proposed rule published in December 1997. In the supplemental information, the following was stated: (13) We have amended the term, “system of organic farming and handling,” to “system of organic production and handling” and retained the original definition in this proposal. The original definition was crafted to be consistent with the requirements of the Act. We have changed “farming” to “production” to provide a more encompassing term, which may come to include such diverse activities as hydroponics, green house production, and harvesting of aquatic animals. The purpose of the original definition was to describe practices and substances consistent with systems of organic farming and organic handling as required by the Act and to provide an explicit reference point for determining which practices and substances are most consistent with these systems. Several commenters suggested that the definition include the concepts, “agroecosystem health,” “ecological harmony,” and “biological diversity.” Commenters also suggested including definitions for “organic agriculture,” “organic farming,” and “transition to organic.” This definition is intended to clarify regulatory provisions in this proposal and is not intended as a broad philosophical statement. The terms “organic agriculture,” “organic farming,” and “transition to organic,” are not used in this proposal and, therefore, are not defined2 The final rule for the National Organic Program was published in December 2000 (65 FR 80547). In the supplemental information, the following was stated: The proposed rule treated mined substances of high solubility as a single category of soil amendment and allowed their use where warranted by soil and crop tissue testing. Many commenters objected to the general allowance for this category of substances and were particularly disappointed that the NOSB annotations on two such materials, sodium (Chilean) nitrate and potassium chloride, were not included. Commenters cited the potential detrimental effects of these highly soluble and saline substances on soil quality and stated that several international organic certification programs severely prescribe or prohibit their use. One certifying agent recommended that natural substances of high solubility and salinity be handled comparably to similar synthetic materials such as liquid fish products and humic acids that appear on the National List, complete with their original NOSB annotations. At its June 2000 meeting, the NOSB recommended that the NOP delete general references to mined