Compost: Organic Systems and Requirements

1. Compost: Organic Systems and Requirements Rutgers University On-Farm and Manure Composting School December 13, 2010 3:15 pm - 4:00 pm Presented by: Erich V. Bremer Supervisor, Organic Certification Program

2. Topics Discussed: 1. General information on the NJDA Organic Certification Program (slides 3-5) 2. Explanation of which regulations govern organics in the US and the guidance documents concerning manure and composting. (slides 6-8) 6. Time disclaimer (slide 9) 3. Description of compost's place in organics and the rule sections that govern manure and compost use. (slides 10-15) 4. Description of difficulties with the Rule as written and the National Organic Standards Board's involvement. (slides 16-18) 5. National Organic Program Guidance on Compost and Vermicompost (slides 19-23) 7. The "Bottom Line" - What NJDA considers when reviewing manure and compost use on organic operations (slides 25-28)

3. Contact Information for the NJDA Organic Certification Program Organic Certification Program New Jersey Department of Agriculture Division of Marketing and Development PO Box 330 (mail) 369 S. Warren Street (physical) Trenton, NJ 08625 (609) 984-2225 (voice) (609) 984-2508(fax) erich.bremer@ag.state.nj.us

4. NJDA Organic Certification Program The New Jersey Department of Agriculture is Accredited by the USDA to perform Organic Certifications for Crop, Livestock, Wild Crafting, and Organic Handling Operations as of April 12, 2007.

5. Organic Operations in NJ: The New Jersey Department of Agriculture is not the only ACA (accredited certification agent) working in NJ. For more information on National Organic Program (NOP) certification activities here in NJ, the on-line listing provided by the USDA can be searched: (just sort by fields) http://apps.ams.usda.gov/nop/

6. Organic certifications are based upon the USDA’s national organic regulations – officially titled: 7CFR Part 205, the National Organic Program; Final Rule We often abbreviate and just say "the Rule" Can be found online at www.ams.usda.gov/nop

7. Additional documents, aside from the Rule, are important when considering manure and composting for organic systems. The NOP has published guidance documents on: Compost and Vermicompost in Organic Crop Production (Doc # NOP 5021) The Use of Processed Animal Manures (Doc # NOP 5006) Allowance of Green Waste in Organic Production Systems (Doc # NOP 5016) (you can Google "NOP" and the number, and retrieve a link to each document)

8. For today's presentation we will focus mainly on the Rule, §205.203, and guidance document # NOP 5021: Compost and Vermicompost in Organic Crop Production

9. TIME DISCLAIMER! It is important to realize that regulations, such as the Rule, and interpretations of those regulations are constantly revised / adjusted. This presentation is being put together in the winter of 2010, and contains the most current information on the topics covered. Regulations, interpretations, and guidance documents can and will change over time, so it will be important to realize some of the documents discussed, and indeed some of the requirements, may change over time.

10. Compost, a.k.a decomposed plant and animal material, is an important tool for organic producers (farmers). The word "organic" in "organic agriculture" can be considered as describing the carbon sequestering that occurs through the careful management of soils in organic agriculture systems.

11. The Rule has specific requirements for the management and application of plant and animal materials. The Soil fertility and crop nutrient practice standard is found at §205.203 of the Rule. Part (a) requires growers to use tillage and cultivation practices that maintain or improve the physical, chemical, and biological condition of the soil.

12. Part (b) lets growers know that organic producers must use management techniques - such as crop rotations, cover cropping, and the application of "plant and animal materials" to manage crop nutrients and soil fertility. Part (c) then defines the appropriate plant and animal materials that can be utilized, and places restrictions on certain forms.

13. §205.203 Soil fertility and crop nutrient management practice standard. (a) The producer must select and implement tillage and cultivation practices that maintain or improve the physical, chemical, and biological condition of soil and minimize soil erosion. (b) The producer must manage crop nutrients and soil fertility through rotations, cover crops, and the application of plant and animal materials.

14. §205.203 Soil fertility and crop nutrient management practice standard cont' (c) The producer must manage plant and animal materials to maintain or improve soil organic matter content in a manner that does not contribute to contamination of crops, soil, or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances. Animal and plant materials include: (emphasis added by NJDA. This is what will be in mind during reviews of composts) (1) Raw animal manure, which must be composted unless it is: (i) Applied to land used for a crop not intended for human consumption; (ii) Incorporated into the soil not less than 120 days prior to the harvest of a product whose edible portion has direct contact with the soil surface or soil particles; or (iii) Incorporated into the soil not less than 90 days prior to the harvest of a product whose edible portion does not have direct contact with the soil surface or soil particles;

15. §205.203 Soil fertility and crop nutrient management practice standard, cont': (2) Composted plant and animal materials produced though a process that: (i) Established an initial C:N ratio of between 25:1 and 40:1; and (ii) Maintained a temperature of between 131 °F and 170 °F for 3 days using an in-vessel or static aerated pile system; or (iii) Maintained a temperature of between 131 °F and 170 °F for 15 days using a windrow composting system, during which period, the materials must be turned a minimum of five times. (3) Uncomposted plant materials.

16. As written, the Rule requirements are quite restrictive. Until recent clarifications, if compost contained manure or other animal materials as feed stocks (to include mushroom soils), documentation that the C:N ratios, time, temperature, and turning requirements were met were needed to determine compliance. If compost did not meet the requirements, the "days to harvest" restrictions had to be followed (120 days for most vegetables). Growers using windrow systems on their farms were required to compost for fifteen days at temperature, with at least five turnings, to use their compost without days to harvest restrictions.

17. Negative comments from the public and interested parties ensued. The NOP advisory board, called the National Organic Standards Board (NOSB), convened two task forces that delivered comprehensive reports to the NOP on compost (2002) and compost tea (2004). The NOSB then made a final recommendation on compost, compost tea, processed manure, and vermicompost in November of 2006.

18. The NOP incorporated many of the NOSB recommendations to create a guidance on compost and vermicompost published in September of 2010. This guidance has some significant differences from the original Rule requirements. The document is still in the "draft" phase, and the public can provide comment to the NOP (end date is December 13, 2010). After reviewing comment, the NOP will release a final version that will become part of the new program handbook published by the NOP.

19. NOP 5021; Draft Guidance; Compost and Vermicompost in Organic Crop Production 1. Purpose This guidance provides clarification on allowed practices for composition, production, and use of compost and vermicompost in organic crop production. 2. Scope This guidance applies to all certified and exempt organic producers, accredited organic certification agents (ACAs), and input suppliers. 3. Background Section 205.203(c) of the soil fertility and crop nutrient management practice standard sets forth the requirements for management and application of plant and animal materials. This section of the National Organic Program (NOP) regulations provides specific requirements for the use of compost and raw manure, but does not describe the full range of methods that may be used for compost production. The National Organic Standards Board (NOSB) convened two task forces that delivered comprehensive reports to the NOSB on compost (2002) and compost tea (2004). The NOSB then made a final recommendation on compost, compost tea, processed manure, and vermicompost in November, 2006. A key provision of the NOP regulations regarding addition of organic matter is found at §205.203, which states: “The producer must manage plant and animal materials to maintain or improve soil organic matter content in a manner that does not contribute to contamination of crops, soil, or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances.”

20. NOP 5021; Draft Guidance; Compost and Vermicompost in Organic Crop Production, (Cont') Section 205.203 further states that animal and plant materials include three types of materials: raw manure, composted plant and animal materials, and uncomposted plant materials. Raw manure is restricted in use, and compost containing animal materials must be produced under certain conditions. The designated types of systems do not include common methods of composting such as in piles (rather than windrows) or include any reference to vermicompost. The NOP concurs with the NOSB that the examples provided in §205.203(c)(1-3) is not a finite list of acceptable plant and animal materials for use in organic production. Site-specific variation in feedstock materials, management practices, and production requirements dictate that organic producers exercise flexibility in managing plant and animal materials on their operations. In July 2007, the NOP issued NOP 5006 - Processed Animal Manures. NOP 5006 clarifies the criteria for production of processed manure products that may be used without restriction in organic production. While the use of processed animal manures in organic production was clarified in the NOP 5006 – Processed Animal Manures, the use of vermicompost has not been addressed. Vermicompost is an alternative method to meeting the NOP compost requirements. Vermicomposts are organic matter of plant and/or animal origin, consisting mainly of finely-divided earthworm castings, produced non- thermophilically with bio-oxidation and stabilization of the organic material, due to interactions between aerobic microorganisms and earthworms, as the material passes through the earthworm gut.

21. NOP 5021; Draft Guidance; Compost and Vermicompost in Organic Crop Production, (Cont') Feed stocks for vermicompost materials include organic matter of plant or animal origin, preferably thoroughly macerated and mixed before processing. Pathogenic organisms are eliminated in 7-60 days, depending on the technology used. Vermicomposting systems depend upon regular additions of thin layers of organic matter at 1-3 day intervals to maintain aerobicity and avoid temperature increases above 35 degrees C (95 degrees F) which will kill the earthworms. Methods of vermicomposting include outdoor windrows (6-12 months), angled wedge systems (2-4 months), indoor container systems (2-4 months) and continuous flow reactors (30-60 days). Earthworms fragment the organic wastes into finely-divided materials with a low C:N ratio and high microbial activity. Nitrogen is mostly found in the nitrate form, and potassium and phosphorus are in soluble forms. For most organic wastes, no traces of the raw materials are visible. Processing is maintained at 70-90% moisture content with temperatures maintained in the range of 18-30 degrees C (65-86 degrees F) for good productivity.

22. NOP 5021; Draft Guidance; Compost and Vermicompost in Organic Crop Production, (Cont') 4. Policy Compost is allowed in accordance with §205.203(c)(2). An example of another acceptable composting method is when: a. Compost is made from allowed feedstock materials (either nonsynthetic substances not prohibited at §205.602, or synthetics approved for use as plant or soil amendments), and b. The compost pile is mixed or managed to ensure that all of the feedstock heats to the minimum of 131oF (55o C) for a minimum of three days. The monitoring of the above parameters must be documented in the Organic System Plan in accordance with §205.203(c) and submitted by the producer and verified during the site visit. An example of acceptable vermicomposting is when: a. It is made from allowed feedstock materials (either nonsynthetic substances not prohibited at §205.602, or synthetics approved for use as plant or soil amendments); b. Aerobicity is maintained by regular additions of thin layers of organic matter at 1-3 day intervals; c. Moisture is maintained at 70-90%; and d. The duration of vermicomposting is at 6-12 months for outdoor windrows, 2-4 months for indoor container systems, 2-4 months for angled wedge systems, or 30- 60 days for continuous flow reactors.

23. NOP 5021; Draft Guidance; Compost and Vermicompost in Organic Crop Production, (Cont') 5. Procedure Compost and vermicompost productions practices should be described in the organic system plan (OSP). Compost production practices should include the type and source of all feedstock materials, temperature monitoring logs by date, and practices used to achieve uniform elevated temperatures. Vermicompost production practices should include the type and source of all feedstock materials, and practices used to achieve aerobicity and maintain adequate moisture. The ACA may allow the use of compost if they review the OSP and records and are assured that these parameters are met. Certifiers reviewing compost inputs produced by commercial operators should similarly review the production methods and source materials. Additional methods for documenting compliance may include measuring temperature, time, moisture content, chemical composition, biological activity, and particle size. These measurements may include testing feedstock materials and compost for one or more characteristics including initial and final carbon to nitrogen ratios, stability (using ammonia/nitrate ratio, O2 demand, CO2 respiration rate or other standard tests), pathogenic organisms or contaminants.

24. The document continues on to cite the reference materials the NOP used to create the guidance. The guidance does NOT specifically address compost teas; however, the NOSB recommendation for compost teas is included in the reference section of the guidance. The guidance provides for additional methods to be used to create compliant compost, and places additional discretion into the control of the Accredited Certification Agent.

25. The Bottom Line: We will now discuss the requirements for various composts and manure for use in organic systems as interpreted by the NJDA Organic Certification Program. For these examples we will assume the compost is to be used in organic production areas growing crops for human consumption. For manure and compost amendments onto organic production areas NOT growing crops for human consumption, producers must still ensure there are no prohibited materials applied (must still track and report feed stocks and sources), must still describe the composting system in the organic farm plan, but will not have to meet the days to harvest restrictions.

26. The Bottom Line: (What the NJDA program will consider when reviewing composts) 1. Composts with vegetative matter only: Do not have to meet time and temperature requirements in the Rule. Should still adhere to C:N ratios and be managed to ensure composting is effective at reducing weed seeds and pathogenic organisms. Composting procedures must be described in the organic farm plan - to include any and all feed stocks and materials added, and their source. Feed stocks and materials added will be scrutinized. 2. Composts with vegetative matter and livestock manure: Must adhere to C:N ratios, must document the three day minimum at temperature (minimum of 1310F). Composting procedures must be described in the organic farm plan, to include information on duration, temperatures, and a description of the procedures used to ensure there are "practices used to achieve uniform elevated temperatures".

27. The Bottom Line: 3. Compost with "animal products" other than manure: *Other than manure includes offal, hides, feathers, bones, etc. Must meet the full requirements in §205.203(c) and must document compliancy (in detail) within the organic farm plan, to include listing of any and all feed stocks and their source, C:N ratios, approx. % of feed stock in the pile/system, temperature and turning records. Due to pathogen concerns, depending on the system and feed stock sources used, additional information may be needed to determine compliance, such as testing (pathogenic organisms, contaminates, stability, particle size, or other methods provided for in the NOP Guidance). 4. For compost teas and vermicompost, the NJDA will use the NOSB recommendations to evaluate. 5. For processed animal manure, NOP 5006 guidance will be consulted.

28. Organic farmers will detail their composting procedures within the Organic Farm Plan form, section 3B. Commercial compost producers will be sent a Commercial Compost Production form that must be completed for review. The NJDA Organic Certification Program does not have a separate, public "materials review" program. NJDA will only evaluate materials their certified organic clients wish to use. There is no charge to the client for a materials review. The NJDA can not be cited in advertisements or publications as an authority who has approved a specific material.

29. Any Questions??