Conventional Produce Is Not Dirty, But The Marketing Tactics Of Big Organic Are

Spinach - a crop that is getting a bum rap (picture by Victor M. Vicente Selvas)

(This post originally appeared on Forbes on 3/13/17)

For each of the last twenty years, an organization called the Environmental Working Group has issued what it calls a “Dirty Dozen List.” It names crops it claims to have high pesticide residues and recommends that consumers purchase organic versions of these crops. They base their list on a seriously distorted interpretation of a taxpayer-funded testing program called the PDP (Pesticide Data Program, USDA). What the PDP actually documents is that our food supply is extremely safe. EWG has repeatedly been called out for promoting this science-free list and for the counter-productive effect it is having on produce consumption by Americans. Yet, EWG persists in employing this strategy as a means of fund raising. Presumably it also serves the interests of their corporate funders in the organic food industry (see list below).  Note that these are very large, processed food players with only one produce company in the list.

The real "dirty dozen"

In its latest campaign, EWG is singling out a few crops for added demonization – notably spinach. They highlight certain specific chemicals that were detected in spinach samples by the USDA in 2015. I have looked in detail at this same, publicly available data. It turns out that 7% of the 2015 spinach samples were organic. The very same chemicals that EWG choses to talk about were found on those organic samples. As with virtually all of the residues found on all crops, the quantities that the USDA analytical chemists found were at very low levels - well below any possible level for health concern. Still, it is ironic that the same flawed logic that EWG uses to scare consumers away from perfectly safe conventional spinach says that they should also avoid the organic alternative.

Bagged Baby Spinach (CCO Public Domain)

Experts agree that one of the best things we can do for our health is to consume a lot of fruits and vegetables (here is one example of why that makes sense). Sadly, all too few Americans do that. Spinach is one of the more popular vegetables that can help move consumers in the right direction, particularly since it has become available as a convenient fresh, pre-washed option. Discouraging consumption of any kind of spinach is a notably irresponsible thing to do, particularly through disinformation. An industry group that represents both conventional and organic produce companies (and many are both) offers an on-line calculator using the USDA’s data and legitimate toxicological information. With this tool consumers can visualize just how safe products like spinach actually are. For instance, a child could safely eat up to 310 servings of spinach a day without negative effects from the trace chemicals on that crop.

Aphids on spinach (Image by demintedmint)

As I wrote last week, organic and conventional produce are actually quite similar when it comes to the presence of low levels of pesticide residues. Because EWG singled out spinach in its recent fund raising email campaign I thought it would be worthwhile to get into the details for that crop.

For instance, EWG focuses on the synthetic pyrethroid insecticide, permethrin, which it calls a “Neurotoxic bug killer.” That sounds scary, but pyrethroids all have the same mode of action as the natural product called pyrethrin derived from Chrysanthemums (pyrethrin is used on organic crops).  As a class the pyrethroids are only slightly toxic to mammals and are considered safe enough to be in many household, garden and pet products sold to consumers.  One of the synthetic versions, Permethrin, is among the most used crop protection agents on spinach to prevent damage from caterpillar pests and infestations with aphids. These are not things we would like to find in our salads!

The USDA detected an average of 0.8 parts per million of permethrin on the 2015 conventional spinach samples. That is only 4.2% of the conservative tolerance set by the EPA, meaning it isn’t even close to something to worry about. On the organic samples from the same season, the USDA detected an average of 0.9 parts per million permethrin– essentially the same level as with conventional.

EWG also calls out the fact that traces of DDT and its metabolites were found in some spinach samples. These are unfortunate, long-term soil contaminants still slowly decomposing decades after that old product was banned. Their presence is certainly not related to whether the current spinach crop is grown conventionally or under the organic rules. Fortunately, the levels are tiny – seven parts per billion for the conventional and 11 parts per billion for the organic. These are only 1-2% of the level that the EPA considers to be of concern.

Permethrin and DDT are the products detected on spinach that the EWG chose to talk about. There were residues of 30 other synthetic pesticides on the organic spinach in 2015. The USDA does not test for at least two dozen other organic-approved pesticides that are used on spinach (biocontrol agents, mineral compounds, natural product chemicals). None of this means that organic spinach is “dirty.” Conventional spinach isn’t “dirty” either. What is “dirty” is the tactic is telling consumers they need to buy organic because of residue concerns without acknowledging that the organic products have similar, low-level residues.

In my opinion the "Dirty Dozen" should refer to the eleven big-organic companies that support the EWG and the EWG itself.

You are welcome to comment here and/or to email me at savage.sd@gmail.com

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Do You Really Need To Worry About Pesticide Residues On Your Food?

Some of the healthy fruits and vegetable we can enjoy (Image from Wikimedia)

Many Americans have concerns about pesticide residues on food – particularly for fruits and vegetables. In contrast with that oft-communicated perception, the safety of our food supply is well documented. One reason for this disconnect is that there are activist groups (non-governmental organizations) that consistently promote the idea that consumers should buy organic versions of certain crops in order to avoid pesticides. A recent study documented how that sort of message induces some lower income Americans to simply avoid fruits and vegetables all together. The truth is that our food supply is extremely safe because farmers are careful to use pesticides in ways that don’t lead to residue problems at the consumer level and because of rigorous regulation followed by farmers over the last several decades.

The common perception of organic as a safer option in this regard is also at odds with reality. The United States Department of Agriculture (USDA), which oversees organic certification, clearly states on its National Organic Program website: “Our regulations do not address food safety or nutrition.” Organic farmers can and do use pesticides from an approved list, but that list is not based on safety criteria. Organic growers are limited to natural chemicals and to a limited list of synthetic materials. As with any crop protection material, the EPA has the responsibility to evaluate and regulate their safe use. That oversight is why consumers can confidently enjoy both conventional and organic foods.

In this post I will describe the testing, regulatory and training systems that are in place in the US to protect consumers from risks associated with pesticide residues. I will also describe the intense monitoring system that demonstrates year-after-year that this system is working.

All farmers face challenges from a variety of pests and although they use a number of methods to manage those threats, pesticides are a critical part of that “toolbox.” The broad category “pesticide” includes certain chemicals that occur in nature as well as various synthetic chemicals. There are also pesticide products based on living biological agents. The responsibility for pesticide regulation is with the Environmental Protection Agency or EPA. It determines how pesticides can be used safely, based on their particular intrinsic properties, and by restrictions on how and when they can be used.

EPA Risk Assessments

Before any new pesticidal product can be sold in the United States, an extensive list of toxicological tests must be performed and reported to the EPA. The company that makes or which will sell the product is responsible for the cost of this testing, but most of the work is performed in contract labs that are closely audited by EPA. The tests evaluate many different facets of potential toxicity for human and environmental health, both in terms of short-term effects (acute toxicity via consumption, by skin exposure, by inhalation exposure…) and long-term effects on development, organ health, reproduction, and potential carcinogenicity. In addition, a great deal of data has to be generated to show what happens to the chemical over time on the food, and in the environment in terms of its persistence, movement, and breakdown into innocuous ingredients. It costs on the order of $286,000,000 and can take more than 10 years to generate all of this required data. EPA then uses these data to conduct an extensive “risk assessment.” Based on that assessment, EPA develops “label requirements” specifying how, on which plants, when, and how much of the pesticide can be used. These risk assessments cover issues of worker safety, environmental impact and also what sort of residues might be left by the time the crop is harvested, and any potential risk to human health.

Some safe, delicious apples ready for harvest in western Washington this summer

Pesticide Tolerances (or MRLs)

With regard to pesticide residues at harvest, EPA designs the label requirements to make sure that any residues still present when the food gets to the consumer are below what is called a “tolerance.” (Outside the US this is called an MRL or maximum residue limit). The tolerance is set to insure that there is a substantial margin of safety (typically 100-fold) between the allowed residue and any level to establish reasonable certainty of no harm to humans. EPA then sets limits on how much of the pesticide can be applied and how close to when the crop is going to be harvested so that the tolerance is unlikely to be exceeded when farmers use the product.

These tolerances are very conservative limits and represent such small amounts that they can be difficult to envision. For instance, a tolerance might be five (5) parts per million. That can be visualized as to two drops of water in a five (5) gallon carboy. Some tolerances are set as low as one part per billion (e.g. one drop in 528 carboys). In summary, tolerances are extremely small levels of pesticide residue, set as a conservative standard for human safety, and customized to the specific properties of the each chemical.

Training

In order to be allowed to apply pesticides, farmers have to be trained and certified about how to comply with the chemical-specific label requirements. They have to maintain that training through on-going classes.

Is the System Working?

Every year, as part of a USDA effort called the Pesticide Data Program (PDP), thousands of food samples are randomly gathered from normal food channels and consumer markets. The samples are taken to labs where each sample is screened for the presence of hundreds of different chemical residues. The data that the USDA generates is transparently published both in raw and summarized form. Year after year, what the data show is that the system is working! The vast majority of samples have either no detectable residues or residues that are below the assigned tolerances – mostly far below. The fact that a small residue can be detected does not mean it is of concern. Modern analytical chemists have the ability to detect chemicals at very low levels. The reason that the numbers below tolerance are still published is not that they are of concern, but rather as transparent documentation that these products should be of little concern to consumers and regulators.  Several governmental agencies evaluate this information each year and confirm that consumers can confidently enjoy their food supply without concern about pesticide residues. The results were just released for 2015 and again document how well the system is working.  The FDA also has a residue testing program from which it concludes, "Results in these reports continue to demonstrate that levels of pesticide residues in the U.S. food supply are well below established safety standards."  California does its own residue testing and concludes, "California tests show low or no pesticide levels in many fruits and vegetables." Similar residue testing is conducted in Canada and the EU with equally encouraging results.  With this overwhelming body of evidence, how can the fear of residues persist?

What About the “Dirty Dozen List?”

Unfortunately, each year there is an organization called the Environmental Working Group (EWG) that takes the USDA PDP data and grossly misuses it to create a “Dirty Dozen List.” Instead of looking at how detections relate to carefully developed tolerances, EWG essentially treats all detections as significant – an approach that has been completely rejected by independent experts in the field of toxicology. EWG then recommends that certain crops be sought out as organic. Similarly misguided recommendations to purchase organic are published Consumer Reports. This makes no sense, since organic is not a safety certification. In fact, organic crops often have the same sort of low-level, detectable residues of pesticides as conventional (example data from the US and Canada). This point is conveniently ignored by these organizations.

In conclusion, we have a system in the US that both enables farmers to control pests and which protects consumers so that they can enjoy healthy foods without worrying about pesticide residues.

You are welcome to comment here and/or to email me at sdsavage@gmail.com

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A Closer Look At Organic Pesticides In California

I've posted an article on Forbes taking a general look at the role of organic-approved classes of pesticides in California.  The take-home points are that pesticide actives that are approved for use in organic made up 55% of the total crop use in 2013 and that those are used by both organic and conventional growers.  I also take a look at the relative toxicity (simple acute ingestion toxicity) and there is a similar range for the organic and synthetic options.  None of this is surprising because what determines whether a pesticide can be "organic" is whether it is "natural", and that is not a safety-based criterion.  The safe use of all pesticides is the responsibility of the EPA and similar regulators around the world.

In this post I'd like to delve in more detail into what these widely used organic pesticides are and why they are used by all sorts of growers.

Major Categories of Organic-Approved Pesticides

In the first graph in this post I've divided the organic-approved materials into Mineral-based, Oil-Based, Natural Products and Live Biologicals.  I'll talk about each category below.

Mineral-Based Pesticides

The mineral-based pesticides that are approved for organic include sulfur, lime-sulfur, and various forms of copper. Together these materials comprise 34% of the pounds used but only 12% of the area treated. That is because these are relatively high use-rate materials (~2 to 25 pounds/acre).

Sulfur has been used as a pesticide since ancient times. While it is essentially non-toxic by ingestion, as someone who has worked long hours in treated vineyards, I can tell you that it is quite irritating to the eyes and skin. Sulfur controls powdery mildew fungi and suppresses spider mites, but has to be reapplied every 7-10 days. It works by sublimation (direct transition from solid to gas) so it is ineffective if it is cold and can burn the crop if it is very hot. It is converted into reactive sulfur compounds in the humid boundary layer of a leaf or berry.  Conventional growers have alternatives that need only be applied at ounces/acre every 14-21 days, but continue to use some sulfur in their programs as a way to manage resistance to the newer materials (see chart below for the trend in sulfur use on premium California grapes).

Conventional grape growers today use about 1/3 as much sulfur because they have other options

The next big mineral-based material is lime sulfur.  It is used for some dormant season sprays, so its “moderately toxic” status (EPA Class II) is not an issue for crop residues.  The remaining organic mineral pesticides are the copper-based fungicides which were discovered in the late 1800s and actually saved the European grape industry when a downy mildew pathogen was introduced from the New World. Some of the copper products are Class II in terms of oral toxicity, can be persistent, and are toxic to aquatic invertebrates, but with appropriate care for where they are used, they are considered safe . Again, conventional growers have lower rate, longer interval, more effective options, but use some copper for resistance management. Coppers are also one of the few options for the control of certain bacterial diseases and for algae control in rice fields.

Petroleum Oil-based Products

An interesting organic-approved category is a collection of oils derived from petroleum (mineral oil, paraffinic oils, petroleum distillates…). These too are relatively old products used at high rates, but they are effective on mites, aphids, whiteflies, scale insects and also powdery mildews. These are also EPA Category IV – “essentially non-toxic” to mammals by ingestion.  Again, they are also used by conventional growers along with other more modern options.

JMS Stylet Oil is a major organic brand in this category

Natural Products

Spinosyn-A - some seriously fancy chemistry (image via Klever)

About 2% of the acre-treatments on California crops were with various “natural products” which are chemicals that are made by plants or from fermentations of various microbes (thus qualifying them for organic). Nature is indeed a remarkable chemist, but that is not a guarantee of safety. Some of the most toxic chemicals known are from nature. The safe use of these materials is based on the same, elaborate risk assessment that agencies like the EPA conducts for all pesticides. The most widely used natural product is the plant hormone gibberellin (540,000 acre treatments). The next biggest product (309,000 acres) is Spinosadwhich was introduced by Dow Agrosciences. It comes from fermentation of an actinomycete. It’s a remarkably complex chemical, but very low in mammalian toxicity (Category IV) and quite effective against all sorts of caterpillars and hard to control insects like leaf miners. Unlike the mineral or oil-based pesticides, it can move inside of the treated plant to protect newly emerging leaves.  Lately it has become available to homeowners as “Captain Jack’s Dead Bug Brew” which is a sort of silly name, but definitely something I use in my garden.

The number 6 natural product (22,500 acres treated) is a relatively recently developed, plant-based natural product that comes from a plant called Epazote or American Wormseed. The small, California company that commercialized it was purchased by Bayer Chemical Company. They have since introduced a product in Europe which is made of a mixture of the same four terpene chemicals that occur in the plant extract. That sort of product often generates much debate in the organic community about whether it is still natural, but the chemicals are the same. In any case this product is effective against various insects including thrips which are difficult to control. That is why it will be increasingly used by both organic and conventional growers.

Thrips cause these feeding scars you often see on snap peas or snow peas

The smallest category of organic-approved products are the biological control agents. The most used and famous of these are various strains of the bacterium Bacillus thuringiensis, or “Bt.” These bacteria make a protein that is selectively toxic only in the guts of certain insects (e.g some work only on caterpillars, some only on beetles and some only on mosquitoes). Together, 10 Bt-based products were applied to 320,000 acres. Some crops have been genetically engineered to express these same Bt proteins, but those would not qualify for organic. Sweet corn has been modified this way, but the sweet corn growers have been asked by their retail store customers not to use the "GMO" varieties. Instead they must make at least six more sprays a season than they would need to if they could use a Bt variety. That is a shame.

The "natural" pesticides that are approved for organic also have an important role in conventional agriculture.  They are not qualitatively less toxic than synthetics, but then virtually all the pesticides used today are only moderately toxic at most and most commonly non-toxic in the classic sense. These and the modern synthetic pesticides play an important role in the efficient use of the land, water, fuel and labor that it takes to produce food. 

You are welcome to comment here and/or to email me at savage.sd@gmail.com

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My Comments To The USDA On Agricultural Coexistence

Today I submitted a comment on the official USDA regulatory forum on the question of coexistence in agriculture.  Here is a link for background from a workshop on this topic held in North Carolina this March.  Here is a link of you want to comment (>4500 people have so far and the comment period is open until May 11, 2015).

The point I hoped to make was that coexistence between different kinds of farming is something people have known how to do for a very long time, but it requires a certain level of reasonableness and cooperative spirit.  That is rarely a problem when you are talking about real farmers and if there are rational standards for "adventitious presence."  The issues to do with coexistence today arise from downstream players making unreasonable demands and by those which are not, by their own statements, interested in coexistence.  The USDA seems to be trying hard to make this an open dialog, but there are aspects of this debate that need to be recognized for what they are.

Text Of The Comment I Submitted 4/28/15

While the coexistence of diverse commodity and identity preserved crops is a long-standing, successful feature of American agriculture, some aspects of the current coexistence discussion warrant careful consideration.  Particularly for row crops, the definition of acceptable “adventitious presence” is critical in any identity preservation effort.  That threshold drives the costs of isolation and segregation protocols as well as the level of risk for the producer.  The threshold of adventitious presence should logically be driven by objective issues of functionality in the intended use and/or by levels that are practical in the real world.  That sort of system has long enabled coexistence in farming.

The current problems for co-existence arise in what many participants in the North Carolina workshop described as "sensitive markets."  Principally this means products intended for "non-GMO" and/or organic markets.  Unfortunately, a significant proportion of those markets have been established at the consumer end through fear-based marketing and advocacy.  For these IP segments there is no "reasonable level of adventitious presence," because the categories were never based on any reason-based functionality or safety criterion.  Perhaps "fear-based marketing" sounds like a harsh term, but if you look at examples of promotional campaigns generated by very large, for-profit, organic and non-GMO food companies, it’s hard to come up with a friendlier sounding descriptor:

1. This recent video produced by Organic Only, a consortium of organic marketers including may of the largest ones:

https://www.youtube.com/watch?v=ypF15z3euwM

2. Several productions from the large, non-GMO promoting fast food chain, Chipotle:

http://farmedanddangerous.com

https://www.youtube.com/watch?v=lUtnas5ScSE

3. This humorous, but not fair 2005 production from the Organic Trade Association: 

https://www.youtube.com/watch?v=hVrIyEu6h_E

Coexistence requires, by definition, some level of fair play and mutual respect from the parties involved.  The corn and soybean growing neighbors who are trying to make a living in commodity and IP markets may have that sort of working relationship, but the demands coming down to them from "sensitive markets" are often driven by rather successful, fear-for-profit business models.   These downstream drivers are certainly not on the "coexistence" page at all – in fact exactly the opposite.  Some explicitly state that their goal is the elimination of biotech crops via the agency of GMO or non-GMO labeling and its effects on markets.  As is usually the case, the farmers have virtually no leverage in these exchanges.  With this enormous gulf in terms of power and intention, the prospects for rational co-existence are not encouraging.

There are certainly players in the organic and gmo-free segments that could be reasonable participants in a coexistence discussion, but their voices do not represent or apparently influence other important players.  It would be irresponsible to fail to explicitly acknowledge this “elephant in the room.”

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Why Organic Can't Fulfill Our Food Supply Ideals

Almost any farmer or consumer could agree on the following ideals for our agricultural system:

"Farming in ways that are best for us, best for the environment, and best for providing an adequate food supply."

I believe that these are the goals and ideals of organic customers and organic farmers, and I share them. If organic could deliver on these “triple best” goals, I would be among its strongest supporters, but I don't believe that it can.  The organic rules are based on the assumption that “natural” is always best.  That assumption originated in a pre-scientific era, and it does not hold up to what we have learned over the last century.  The "natural" definition is great for marketing purposes, but often not the optimal criterion to guide farming practices. 

The Original Contribution of the Organic Movement

The important contribution of organic early in the last century was its focus on improving soil health/quality.  The pioneers of the organic movement worked out certain farming methods using “natural fertilizers” to mitigate the nutrient-depleting and soil-degrading effects of the plow-intensive farming of the late 19^th and early 20^th century.  The organic focus on natural also meant that it eschewed some of the early pesticides, which were later found to be problematic for health and the environment.  For a period of time, organic may have been, in fact, the best farming option for us and for the environment.

A pretty picture, but for soil erosion and soil health this kind of farming was highly undesirable

Since then we have learned more and more about environmental systems, genetics, microbiology and human health.  Based on that, increasingly rigorous regulatory processes were put in place and farming practices have changed dramatically.  Sometimes organic growers were in the lead in making those changes.  But increasingly, the “natural” constraints of organic are making it difficult or even impossible for organic farmers to implement what we now know to be best for us, best for the environment, or best for the food supply.  I'd like to describe six specific examples of those limitations.

1. Nitrogen Fertilization

One of the greatest challenges of farming is providing a growing crop with the necessary mineral nutrients when it needs them. When nutrients are free in the soil and not being actively absorbed by the growing crop, they have the potential to move into ground water, or to wash off into surface water.  If they do, they can become health issues and/or foster algal blooms that cause “dead zones” in bodies of water.  Excess nitrogen in soils can lead to the generation of the potent greenhouse gas, nitrous oxide. There are specific conditions under which natural fertilizers like manures or compost can reduce these problems, but there are also conditions under which the uncontrolled, nutrient release pattern from natural fertilizers can be quite problematic. Depending on how and when they are delivered, “synthetic” fertilizers can be deployed in ways that do a better job of providing the crop’s need without as much risk of these forms of pollution. For example, drip irrigation systems are very efficient ways to deliver fertilizers but cannot be used for most forms of organic fertilizers. Triple-best farming requires the ability to use both natural and synthetic fertilizers in the right settings and with the right delivery methods. There is even the possibility of making synthetic nitrogen using renewable energy.  

2. Low Risk Pesticide Use

What makes a pesticide safe for us or for the environment is not related to whether it is “natural."  Some of the most toxic chemicals known are produced in nature. The reason that the American consumer can have confidence in the safety of crop pesticide use is that the EPA demands a great deal of data for its multi-dimensional risk assessment for any chemical, natural or not, that is going to be used for pest control.  These tests involve multiple dimensions of human toxicity as well as assessments of environmental fate and environmental impact. Some, but not all “natural products” meet those standards.  Some, but not all, synthetic products meet those standards.  The details of how synthetic or natural pesticides can be used are then dictated in “label requirements” specific to the properties of that chemical (e.g. how long before the crop is harvested, what worker protection standards are needed, what considerations are needed relative to sensitive environmental settings…).  It is this regulatory process, not naturalness, which ensures environmental safety and residue levels that are safe even by very conservative standards.  In many cases the "synthetic" options are the very best choice among the approved options. 
(Note: the graph of California use data shown earlier has been removed.  Sulfur classified in that figure as Category II is actually Category IV for oral acute toxicity, Category III for dermal toxicity)

3. Fully Integrated Pest Control

Baby Spinach Growing In Coastal California

Organic farmers have been early adopters of many pest control options other than classical, chemical pesticides (genetic resistance, biological controls, crop rotations, natural pest enemies, and pheromone-confusion…), but at least since the 1970s, this has also been a growing component in “conventional agriculture” called Integrated Pest Management(IPM).  In many crop systems, modern synthetic pesticides are one important component in these mixed approaches.  For example, there is a problem in the current, California spinach crop, which has around 50% organic production.  There is a disease of that crop called downy mildew and it is transmitted from season to season via survival in the seed.  Through conventional breeding, it has been possible to develop spinach that is resistant to that fungus.  The conventional growers also use a relatively benign synthetic fungicide as a seed treatment against the disease - thus they are using an integrated program of genetics and a fungicide.  For the organic production, the seed treatment is not allowed.  Without the multiple control strategy, the fungus has rapidly mutated to get around the genetic resistance, and six good sources of resistance have been lost within a few years.  Each time, the newly virulent strains have emerged first in the organic fields. This gap in the IPM program is now putting the entire California spinach industry at risk.  There are similarly precarious situations in other crops.

4. Biorationals

It takes a lot of money to do the testing needed to commercially develop and insure the safety of any new agricultural pesticide - more than $200MM.  That level of spending is appropriate to meet our modern safety standards, but it means that the commercial development of any new synthetic pesticide can only be justified for a very large market within the agricultural realm.  For problems that only affect a small part of the food supply, it is not possible to justify the investment in a new option.  Fortunately, the EPA has a special, lower cost registration process for low toxicity chemicals that already occur within the food supply. 

The sprouts of potatoes are actually rather toxic, so don't eat them

A good example of this is a new product for preventing sprouting in stored potatoes.  The compound 3-decen-2-one already occurs in at low levels in potatoes as well as in mushrooms, tuna fish, yogurt and soy.  An identical, synthetic version of the chemical can now be used with stored potatoes and it is a better, safer option than the old sprout inhibitor, CIPC.  Because of a purist interpretation of the organic rules, the new sprout inhibitor cannot be used for organic potatoes.  Instead they are treated repeatedly with clove oil – a more costly and less effective option with no other “triple best” advantages.

5. Soil Building

Starting in 1960, farmers have been working out farming systems that do not require physical tillage of the soil.  When these are combined with the use of cover crops and GPS guided equipment use, it is possible to raise the important row crops (wheat, barley, canola, soybeans, corn, cotton…) in no-till or minimum-tillage systems that improve soil health and quality.  It is also an important “best” system to prevent soil erosion, reduce water pollution risk, and sequester carbon to mitigate climate risk. 

No-till Soybeans Following Corn

This system is much more like the way soils are built in natural prairie habitats and is not dependent on outside inputs of organic matter as is the case in the typical organic systems.  In order for these new options to be pursued efficiently on a large scale, herbicides are necessary as are controls for certain pests which are favored in a non-tillage system.  Organic growers don’t have many of the practical tools to manage these issues, and so they are ironically unable to fully or cost-effectively pursue these best, reduced tillage protocols.

6. Genetic Improvements

Genetic modification of crop plants has always been an important means of making farming better able to meet our food supply goals.  In recent history it has become possible to make more precise genetic modifications using the tools of genetic engineering – tools which were in fact drawn from nature. For example,  restriction endonuclease enzymes occur naturally and cut DNA at specific target sites, and the Ti plasmid of Agrobacterium which inserts DNA into chromosomes of plants.  In the last few years, even more precise and efficient tools for genetic modification have been discovered within a group of ancient microbes we call the Archaea (e.g. the CRISPR-Cas9system). 

Diagram of the CRISPR system via Wikipedia

As deployed within the unprecedented and rigorous regulatory framework for "GMO Crops", these tools have become an important means through which triple-best crop improvements can be made.  In her book “Tomorrow’s Table,” UC Davis molecular biologist Pamela Ronald has made an articulate argument for why these tools should be embraced for organic farming. But such suggestions are not even considered by the fierce defenders of the organic rules.  Even when genetic engineering is used to transfer something like a gene from wild potatoes into commercially relevant potatoes, the resulting triple-best crop will not be available to organic farmers (as in the case of the new, Innate 2 potato from Simplot)

European experiment showing healthy potatoes on the left that have the wild potato gene vs susceptible potatoes on the right without that gene

 A Missed Opportunity to Embrace Best Practices by Organic

There was a window of opportunity in 1990 when the organic rules could have been updated to use science-based criteria rather than the restrictive obligation of natural.  In that year, the US Congress tasked the USDA with formulating a national organic standard, and that research-oriented agency was inclined to bring modern knowledge into their rule-making process.  Such an approach was vigorously opposed by key elements of the existing organic advocacy community.  When the national standard emerged in final form in 2000,  at had only enshrined the "natural requirement" which continues to limit the ability of farmers to pursue many triple-best strategies such as those I’ve described above. 

Unfortunately, some of those who market organic products, and some who advocate for organic, continue to make unsupportable claims that organic is best for us and for the environment.  Many consumers accept these claims and believe that they are doing the right thing by paying the premium prices for organic items.  If we really had a food supply that was only safe and responsible for those able and willing to pay higher prices, that would represent a huge failing of public policy.  Fortunately, that is not the case.  Consumers and farmers with high ideals for the food supply can support farming in the ever-innovative mainstream system as it continues to find ways to farm that are best for us, best for the environment.

You are welcome to comment here and/or to write me at savage.sd@gmail.com

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