Subject: Compost Tea and Organics

From: Chuck Benbrook <[email-masked]>
Date: Wed, 13 Nov 2002 07:23:29 -0800

I have learned much from the ongoing dialogue re compost and compost
tea safety and thank the technical experts for taking the time to walk the
non-microbiologists among us through the issues/science.  I agree there is
much more to learn re how to assure compost safety and that the U.S., for
certain, has underinvested in this promising technology.

        Still, the unresolved scientific and food safety issues surrounding
compost, and especially compost tea, pose a major challenge for not just the
sustainable ag/organic community, but also for FDA/USDA and practising soil
microbiologists.  I appreciate the passion and knowledge Elaine brings to
this issue, and her patience and clarity in many recent posts, but her views
are not universally shared among the relatively small group of scientists
charged with the responsibility of advising the NOP/USDA re how to move
forward with the regulation of compost tea applications under the NOP.  I
have had a chance to discuss the recent work of the compost tea task force
with some of its members and am concerned by the degree to which the work of
the task force has come under attack, from a variety of quarters.

        We all know that some of the most strident enemies of organic
agriculture have latched onto compost safety as an Achilles Heel of organic
farming and that they will misrepresent the views of scientists, government
agencies, the local bartender to make their point and raise concerns.  Of
course they will also fully exploit any disagreements within the organic
community, a process now under way.

        The NOP/USDA, and the compost task force, have to be cautious and
deliberate in moving ahead, and indeed their recent report and decisions
could be regarded as consistent with the precautionary principle.  There
must be a very firm foundation if/when NOP/USDA endorses/permits
applications of compost tea under circumstances that might, even very
occassionally, result in a heightened risk of E. coli contamination.  Anyone
who believes that technology and processes now exist, or can readily be
developed, that would assure food safety following applications of compost
tea should take their case, and data, to the task force and other technical
advisory bodies. But as we muddle toward concensus, the conclusions of these
bodies must be accepted, even when some among us feel they are wrong.
Constructive responses in the face of misguided technical advisory body
conclusions is to assure that the committees in the future are composed of
open-minded people lacking conflicts of interest; are given the background
and data needed to understand the issues they have been asked to review; and
to package/present data and information before the committees in clear and
compelling ways.

        The way the organic community deals with potential compost food
safety challenges will be among the decisive issues shaping consumer
attitudes and interest in seeking out organic food.  I hope everyone with
scientific/technical skills and experience on these issues will find a way
to work cooperatively and together to assure that the pursuit of the disease
control and agronomic benefits of compost is carried out with a degree of
patience, caution, and humility, recognizing that there is much we do not
know and many lessons yet to be learned about the practical control and
application of these technologies in the real world.

        Chuck Benbrook

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From: Douglas Hinds <[email-masked]>
Date: Wed, 13 Nov 2002 12:43:30 -0600

Hello Chuck & other saneters following this thread,

In relation to Chuck's post of Wednesday, November 13, 2002:

I will be brief. I agree with everything he said, yet suggest a
different solution.

While the concerns he mentioned are real, this particular issue
(food safety in relation to organic food grown using compost teas)
can and should be resolved by putting a fully operative HACCP system
in place. (HACCP = Hazard Analysis via Critical Control Points).

The presence of a HACCP system should resolve the issue and be taken
into account by those responsible for the NOSB & NOP.

Incidentally, I learned about HACCP from materials sent to me by
Charles Benbrook in 1989, when he was head of the Board on
Agriculture of the National Research Council. The book: "An
Evaluation of the Role of Microbiological Criteria for Foods And
Food Ingredients" (National Academy Press) was one of those sent
(others were related to animal health and disease, as well as food
products of an animal origin). HACCP systems for fruit and
vegetables do exist however.

Designing a functional HACCP for this issue could begin right here.

Does anyone else agree?

Douglas

CB> ... there is much more to learn re how to assure compost safety
CB> and ... the U.S., for certain, has underinvested in this
CB> promising technology.

CB> ... the unresolved scientific and food safety issues surrounding
CB> compost, and especially compost tea, pose a major challenge for
CB> not just the sustainable ag/organic community, but also for
CB> FDA/USDA and practising soil microbiologists. ...I have had a
CB> chance to discuss the recent work of the compost tea task force
CB> with some of its members and am concerned by the degree to which
CB> the work of the task force has come under attack, from a variety
CB> of quarters.

CB> We all know that some of the most strident enemies of organic
CB> agriculture have latched onto compost safety as an Achilles Heel
CB> of organic farming and that they will misrepresent the views of
CB> scientists, government agencies, the local bartender to make
CB> their point and raise concerns. Of course they will also fully
CB> exploit any disagreements within the organic community, a
CB> process now under way.

CB> The NOP/USDA, and the compost task force, have to be cautious
CB> and deliberate in moving ahead, and indeed their recent report
CB> and decisions could be regarded as consistent with the
CB> precautionary principle. There must be a very firm foundation
CB> if/when NOP/USDA endorses/permits applications of compost tea
CB> under circumstances that might, even very occassionally, result
CB> in a heightened risk of E. coli contamination.

CB> Anyone who believes that technology and processes now exist, or
CB> can readily be developed, that would assure food safety
CB> following applications of compost tea should take their case,
CB> and data, to the task force and other technical advisory bodies.

CB> But as we muddle toward concensus, the conclusions of these
CB> bodies must be accepted, even when some among us feel they are
CB> wrong.

CB> Constructive responses in the face of misguided technical
CB> advisory body conclusions is to assure that the committees in
CB> the future are composed of open-minded people lacking conflicts
CB> of interest; are given the background and data needed to
CB> understand the issues they have been asked to review; and to
CB> package/present data and information before the committees in
CB> clear and compelling ways.

CB> The way the organic community deals with potential compost food
CB> safety challenges will be among the decisive issues shaping
CB> consumer attitudes and interest in seeking out organic food. I
CB> hope everyone with scientific/technical skills and experience on
CB> these issues will find a way to work cooperatively and together
CB> to assure that the pursuit of the disease control and agronomic
CB> benefits of compost is carried out with a degree of patience,
CB> caution, and humility, recognizing that there is much we do not
CB> know and many lessons yet to be learned about the practical
CB> control and application of these technologies in the real world.

CB>         Chuck Benbrook

.

---

From: "[email-masked]" <[email-masked]>
Date: Thu, 14 Nov 2002 11:55:29 +0100

Douglas,

For once I may disagree with you. I am not too fond of HACCP since the way it acts, it
makes impossible all kind of traditional ways of foodmaking and just favours large
industries. Besides, I do not see a real need. Does the overview by Dr. Ingham not give
sufficient overview of when there is a risk? Her analysis seems to be "haccp" enough to
me.

regards
wytze

On 13 Nov 2002 at 12:43, Douglas Hinds wrote:

Does anyone else agree?

Douglas

CB>         Chuck Benbrook

.

---

From: Frank Teuton <[email-masked]>
Date: Mon, 18 Nov 2002 20:14:20 -0500

Dear Dr Benbrook:

I appreciate the tone of your post.

The problem as I see it, is that a task force on compost issues, including
compost tea, was brought together that did not include any of the advocates,
advisors, or practitioners of compost tea making, specifically Dr Ingham and
some of the firms she works with.

I don't pretend to understand the politics of who is in and who is out in
creating these groups, but I do know that when you exclude a group of
stakeholders from a process such as this, then issue a finding which
undermines their work directly, the result is not likely to be a satisfied
and happy bunch of campers.

Any future body formed about the issues of compost tea should certainly
include Dr Ingham or someone who can represent a similar viewpoint.
Furthermore, the group should at least attempt to perform a literature
review, and conduct a sampling of the various commercially produced
products, for both positive and negative aspects.

It should not be difficult to access the underlying research such a group
relies on for its recommendations. Every effort should be made to be open,
to receive and respond to comments, and to clearly state assumptions,
research needs, opinions of various task force members, and the basis of
recommendations and conclusions.

It should also attempt to put these things into clear and simple language so
that farmers and other growers as well as consumers understand what is
known, what is assumed, and what else needs to be done.

Clearly, no one out there has a total, thoroughgoing understanding of all
the details of microbial action in water, soil solution, phyllosphere,
rhizosphere and solid state environments such as drier soils and composting
and vermicomposting environments. Our best researchers, of which Elaine
Ingham is certainly one, admit that we are barely scratching the surface in
terms of knowing who all the actors are, and knowing exactly what each does.

But, as Russel Bulluck used to like to close his posts:

"The soil population is so complex that it manifestly cannot
be dealt with as a whole with any detail by any one person,
and at the same time it plays so important a part in the soil
economy that it must be studied. "
--Sir E. John Russell
The Micro-organisms of the Soil, 1923

Indeed in one of his pithier posts on a closely related topic, Russ lays out
the reality for us:

"Here's the good news and the bad news. . . The good news is that pathogenic
strains of enteric bacteria (such as the dreaded E. coli O157:H7) produce
toxins that require a large energy output, and as such, these organisms are
not normally good competitors in the soil environment (being used to the gut
of cows, the bugs in the soil no longer have a constant and rich nutrient
supply or constant and pleasant 37 degrees C temp). The bad news is that
some
enteric bacteria will likely be found in soil! We don't live in a sterile
environment, but luckily, most of the bacteria in soil (and our food for
that
matter) are not harmful.

Let me say this. . . the food that we eat (be it vegetable, mineral or
animal)
has bacteria on it or in it. That's right, our food has bacteria in it. . .
millions of bacteria. Our skin has bacteria on it, as well as fungi, mites,
some nematodes (likely as not), and other bugs that literally make your skin
crawl (does everyone feel a little itchy now?). Most bacteria and fungi are
not that bad. If they were bad, we'd not be here! "

http://www.sare.org/htdocs/hypermail/html-home/43-html/0129.html

I personally want organic food to be food grown in a living soil, with a
full and active foodweb. That means, yes indeed, there will be millions of
bacteria on it, of a large diversity, and fungi, and other stuff. That
living food is what we all evolved on; it is what we have eaten for
countless millennia.

People who want or need sterile food should either not buy organic food (or
conventional food, either, for that matter) or they should cook the heck out
of everything.

I think the big bugaboo on compost tea down at the NOSB is fear of 0157. I
think every time 0157 is raised as an issue, it should be pointed out that
the big breeders of this pathogen are the CAFOs, especially grainfed cattle
feedlots. It is true that such operations are sufficiently widespread that
0157 could be on everyone's farm, and that suitable precautions should be
taken; see for example:

http://www.cog.ca/efgsummer2000.htm#ecoli

But it is also true that if we really wanted to greatly reduce 0157 in the
environment, we would stop the practice of grainfeeding ruminants. All the
costs associated with this practice are now being borne by the larger
society, including consumers, and organic farmers who are largely not to
blame for it.

However, I think in this context it is quite interesting to expand Elaine's
suggestion, that a compost made from manure containing E. coli would
contain, after it matured to the point of  elimination of this pathogen, the
necessary antagonists to protect crops growing near a CAFO or near fields
where inadequately treated CAFO manures are spread from 0157 infection.

"Addition of beneficial bacteria and fungi to an apple's surface might speed
the process of removing pathogens through competition and consumption.  That
would be some interesting research.  So, maybe applying good compost tea
would result in safer fruit, and less likelihood of contamination."---Elaine
Ingham, letter to SANET, 18 November 2002

Of course, that would require that we had really good tests for 0157 that
could be applied to teas. Such tests seem to be coming online:

http://www.montana.edu/wwwpb/univ/ecoli.html

So, if the Compost Tea Task Force [I'm assuming that's what it will be
called] wants to get more respect, it needs to be open, inclusive, and
demonstrate strong scholarship as well as outreach and education abilities.
Surely the positive potential represented by compost teas deserves a more
thorough hearing, and the issues of quality control further inquiry?

Dr Benbrook, I note at Dr Brinton's site:

http://www.woodsend.org/articles.html?a_uid=1

"For a paper by Charles Benbrook regarding the necessity of this
committee-process, click here Commentary "

I am unable to get the site to open. Can you provide us with your paper
elsewhere, and did you really mean that *this* committee-process was
necessary, or that *a* committee-process was necessary?

Isn't a more inclusive committee-process likely to advance matters better?

Thanks in advance for any further light you can give on this,

Frank Teuton

----- Original Message -----
From: "Chuck Benbrook" <[email-masked]>
To: <[email-masked]>
Sent: Wednesday, November 13, 2002 10:23 AM
Subject: [SANET-MG] Compost Tea and Organics

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