You are quite right about the "loophole" that allows vermicomposting to be
a way of aging manure. This section does indeed allow any kind of raw
organic wastes to be used *on the farm.* The problem comes in when, say, a
fish waste composting operation wants to sell their product to organic
farmers, but it has not been composted according to NRCS practice
standards. I personally don't think that the concept of "practice
standards" is compatible with an organic approach either.
At 08:57 AM 3/29/00 -0500, Frank Teuton wrote:
>>Date: Tue, 28 Mar 2000 19:40:22 -0500
>>From: Grace Gershuny <graceg@ConnRiver.net>
>>Subject: Re: Organic or not?
>>As far as I know, you can use any dairy manure for compost, although some
>>programs are more restrictive about compost feedstock from non-organic
>>sources. The effluent from a digester might still be considered "raw
>>manure" for the purposes of certification, but I'm not sure how this is
>>being handled by certifiers.
>>As a general note, the current proposed rule would allow only compost made
>>according to NRCS practice standards, which only apply to on-farm
>>composting. Someone has already pointed out that this would make
>>vermicomposting unacceptable, but it also doesn't allow for use of compost
>>made by food processing operations or various commercial compost
>>operations, unless they start calling themselves farms.
>I am not so sure about this, as the note to the rule suggested otherwise:
>"(2) Nonorganic Plant and Animal Waste Materials. The first proposal
>permitted the use of any uncomposted plant or animal wastes. It also allowed
>use of composted plant or animal wastes obtained from nonorganic sources,
>such as commercial compost products. Several consumer and environmental
>groups objected to permitting the use of plant or animal wastes from
>nonorganic sources. Such materials, they argued, could potentially contain
>residues of prohibited substances that could compromise the integrity of the
>organic farm system. However, off-farm plant and animal wastes from food
>processing, municipal yard waste facilities, and other sources are used
>extensively in existing organic operations and are generally permitted by
>organic certification programs. Bone meal, fish meal, and seaweed meal are
>also commonly used as organic farm inputs. Commercial fertilizer products
>that contain mixtures of such plant and animal by-products are commonly
>permitted for use in existing organic certification programs, subject to
>certifying agent review. Using such organic wastes is consistent with a
>system of organic production and handling, which calls for recycling organic
>wastes to return nutrients to the land. We believe that concerns about
>potential contaminants in plant and animal waste materials can be addressed
>by the requirement in this proposal that these materials be managed in a
>manner that prevents such contamination. For example, cotton gin trash that
>had been treated with a prohibited substance could only be used if the
>organic system plan specified composting the material before adding it to
>the soil. Composting has been shown to effectively biodegrade synthetic
>organic compounds, and the organic system plan could also call for the
>compost or soil to be monitored regularly for specific residues."
>For my nickel the NRCS 317 standard is too hot, too fast and short on
>detail, at least the version that was up at the website:
>My concern with the hot composting is that you can get the sterilization
>effect followed by pathogen regrowth, for example with manure and animal
>mortalities, and someone pushing the envelope with little guidance might
>very well do just that.
>Forgive me, but I have little confidence in 21 day dead animal
>compost.....not to mention manure. The NRCS 317 standard suggests operating
>temps between 130 and 170 degrees F. Temps above 155 or so will get you
>cooked material. In the words of USDA microbiologist Pat Millner,
>" If compost were to be 'cooked' , nutrients wouldn't be stabilized enough
>and microbial diversity would be decreased to the point that any subsequent
>pathogens that contacted the treated material might re-colonize it. In the
>absence of well stabilized compost with a competitive microflora this might
>result in a product with a pathogen content nearly as great as the untreated
>Farrell discusses this whole temperature and recontamination problem in his
>article, "Fecal Pathogen Control During Composting", which is page 282 in
>The Science and Engineering of Composting, Hoitink and Keener, eds, 1993,
>Renaissance Publications, ISBN 0-936645-15-6. Indeed, the whole thrust of
>many articles in this text indicate that high temperature composting (>140
>degrees F or 60 degrees C ) is a bane and a curse and a bother. It is also
>something very rarely found in nature, I might add.
>And, hot compost made in this way would have little in the way of disease
>suppressive properties, as I understand it. Additionally, chemical
>contaminants like chlordane are less likely to be broken down in a short
>thermophilic composting process.
>The time frame given is not so realistic, I think. Jim McNelly, a veteran
>composter and Vice President of the US Composting Council, sees 105 days as
>the best you can do:
>>Personally, I believe that the optimum rate of composting is a geometric
>>pattern of seven days in the initial "hot" phase, fourteen days in an
>>active composting period, twenty-eight days in a mesophilic initial curing
>>phase, and then a final fifty-six days of curing. 7+14+28+56 = 105 days.
>(----recent email to the Composting Council List)
>Compare this to the 21-60 day time frame suggested in NRCS 317.....
>Luckily, one has some loopholes....for example uncomposted plant and animal
>wastes can be used, and manure if it is 'aged and well-decomposed' need not
>be jumped through the hoop of NRCS 317....and should it happen that you age
>it and decompose it through the good offices of worms, well I suppose that
>shouldn't raise any eyebrows.
>(One of the virtues of vermicomposting is that the worms establish a
>competitive microflora that does not support pathogen regrowth, a process
>known as vermi-stabilization. In fact, worm composting alone has
>demonstrated full pathogen control in biosolids composting in one Florida
>So, since this is the first of supposedly many 'practice standards' the USDA
>wants to impose on capital-O Organics, and it seems inadequate in so many
>ways, maybe the writing is on the wall that whoever is behind all this
>either is unable or unwilling to find the sort of broad umbrella approach
>with suitable limits that might be acceptable and useful to the entire
>organic community. Give them an inch, you know, and away goes the yardstick!
>Someone tell me again, why is this an improvement on OCIA and other private
>and/or state certification agencies, making their own marketing reputations?
>The cure looks worse than the disease, from where I sit.
>Frank Teuton----resisting the urge to say "These aren't the 'droids you're
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