Subject: [compost_tea] Re: compost tea additives and NOSB

From: "Steve Diver" <[email-masked]>
Date: Mon, 19 Apr 2004 15:15:08 -0000

A lot of people in farming have been **shocked** at

the narrow view of compost, vermicompost, processed

manures and compost teas in the NOP.

The compost practice standards were lifted from a

EPA Biosolids rule known as "processes to further

reduce pathogens", PFRP's, to meet time and temperature

requirements to kill human pathogens in sewage sludge

and APPLIED organic farmers as a regulatory practice!!

In response to protests from organic farmers, the

NOSB formed the Compost Task Force to updgrade

practice standards for compost in NOP 205.203(2).

Here is the report.  It looks like May 2002, and

since it has not been enacted, that tells you how

slow the process is to change NOP, a federal law.

Compost Task Force Final Report

http://www.ams.usda.gov/nosb/finalrecommendations/

may02/composttaskforce.pdf

In fact, NOP rules are so stifling on compost, processed

manures, and compost teas that Oregon Tilth and Oregon

State University sponsored a national summit on human

pathogens from livestock manures to bring people together

and discuss the situation and make recommendations and

suggestions to upgrade these uses... in June 2003...

recognizing there is a disconnect between every day

organic farming and "regulatory text" that codifies

farming practices.

See:

Human Pathogens from Livestock Manures: Proceedings

of a National Summit

http://www.tilth.org/site/Publications/pathogen_summit.pdf

The NOSB Compost Tea Task Force was formed to upgrade

compost tea practice standards.

It notes that compost substrate to make compost teas can

be NOP compliant compost OR compost that follows guidelines

set forth by the the NOSB Compost Task Force.

Under (1) the current climate at USDA which is focused on

pathogens in animal manures and potential contamination of

edible crops and food supply and (2) scientific studies that

show multiple-week survival of pathogens applied to vegetable

crops, and (3) studies that show sweet teas can grow pathogens

-- whether you agree with the brewing protocals or not -- the

CTTF came up with the recommendations that you see.

Keep in mind that zero published studies on modern ACT's

and pathogen survival are available in the literature, today.

There is a lab in TN that is providing an E. coli test for

composters for $15.

Steve Diver

--- In [email-masked], "ericgoodenough" <sfo@g...> wrote:

> NOSB CTTF defines compost tea additives as "Materials other than

> water and compost added at the start of the compost tea making

> process to increase microbial biomasss/populations."

> Now, if I read this correctly, then kelp, rock powders, fish,

> humates, molasses, sugar, juice, oat flour, crab shell, ......THESE

> ARE ALL ADDITIVES INTENDED TO INCREASE MICROBIAL BIOMASS!

> Therefore, if you use these things you will be subject to

pre-testing

> to verify that your tea does not contain pathogens.  Two tests are

> required and the average result is used to "prove" your process is

> clean.  IF YOU CHANGE YOUR RECIPE (or your brew time, or your air

> input, or your start temp, or your water supply) YOU WILL NEED TO

> ORDER UP ANOTHER SET OF TESTS.

> Of course, if you choose to abide by the 90/120 day pre-harvest

> interval restrictions (in other words if you apply CT no sooner

than

> 90 pre-harvest for produce not in direct contact with the soil and

> 120 days for produce in contact with the soil), then of course you

> are all set.  I'm not sure which interval (90 or 120?) I will be

> forced to use for my apples, but if I am limited to using a foliar

> ACT before May 15 (120 interval) or June 15 (90 day  interval) it

> doesn't matter!  THE BOTTOM LINE IS I'VE JUST LOST A TOOL I COULD

USE

> TO OUT-COMPETE APPLE SCAB, SOOTY BLOTCH, FLYSPECK, FIREBLIGHT,

BLACK

> KNOT, ETC. ETC.!  (UNLESS, OF COURSE, I BREW MY TEA WITH ONLY

COMPOST

> AND WATER!)

> Is anyone enlivening their compost with oat flour?  My bet is that

> this practice will cause concern because your compost is no

> longer "finished" according to standards and/or the material will

be

> considered a "compost tea additive."

> I've been making vermi- and thermal composts for tea brewing

without

> the use of manure feedstocks so I could avoid the pre-harvest

> interval headaches.  The CTTF is recommending that CT should be

made

> with "compliant compost or vermicompost, using the NOSB guidelines

> set forth on April 18, 2002"  CAN ANYONE POINT ME TO THE GUIDELINES

> FOR VERMICOMPOST?  DOES IT NEED TO GO THROUGH THE THREE-DAY HEATING

> PROCESS?  OH, BY THE WAY, IF YOU'VE BEEN MAKING YOUR VERMI- OR

> THERMAL COMPOST WITHOUT MANURE TO AVOID THE PRE-HARVEST INTERVAL

THE

> CTTF IS NOW RECOMMENDING THAT EVEN COMPOST MADE FROM 100% PLANT

> FEEDSTOCK MATERIALS IS TO BE CONSIDERED THE SAME AS OTHER COMPOSTS

> (WHEN MAKING COMPOST TEA) BECAUSE "NON-MANURE COMPOST FEEDSTOCKS

MAY

> HARBOR HIGH LEVELS OF FECAL BACTERIA."

> Folks, if these receommendations are accepted, I believe Compost

Tea

> will become an excellent tool for the corporate organic growers who

> can afford the cost associated with testing and re-testing and

> recordkeeping.  It may be that, again, the big guys get to reap the

> rewards of the long fight to creat organic standards while the rest

> of us local growers interested in food integrity and security move

> on.  Organic ain't what it used to be.  I know these are just

> recommendations but I am inching closer to the ledge.  Can somebody

> talk me down?

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---

From: "ericgoodenough" <[email-masked]>
Date: Mon, 19 Apr 2004 12:20:36 -0000

Therefore, if you use these things you will be subject to pre-testing

interval restrictions (in other words if you apply CT no sooner than

doesn't matter!  THE BOTTOM LINE IS I'VE JUST LOST A TOOL I COULD USE

TO OUT-COMPETE APPLE SCAB, SOOTY BLOTCH, FLYSPECK, FIREBLIGHT, BLACK

KNOT, ETC. ETC.!  (UNLESS, OF COURSE, I BREW MY TEA WITH ONLY COMPOST

AND WATER!)

longer "finished" according to standards and/or the material will be

I've been making vermi- and thermal composts for tea brewing without

interval headaches.  The CTTF is recommending that CT should be made

THERMAL COMPOST WITHOUT MANURE TO AVOID THE PRE-HARVEST INTERVAL THE

(WHEN MAKING COMPOST TEA) BECAUSE "NON-MANURE COMPOST FEEDSTOCKS MAY

Folks, if these receommendations are accepted, I believe Compost Tea

talk me down?

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