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

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)

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

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.

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/

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

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)

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

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.

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.

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.

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.

§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.

§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;

§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.

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.

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.

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.

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.”

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.

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.

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.

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.

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.

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.

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".

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.

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.

Any Questions??