Subject: NOSB minutes on Compost Tea

From: Frank Teuton <[email-masked]>
Date: Fri, 8 Nov 2002 18:21:57 -0500

Excerpts from:

http://www.ams.usda.gov/nosb/OctoberNOSBTranscript101902.pdf

MR. BANDELE: Okay, as far as the other 22
agenda items are concerned, next is the compost tea. I 23
think Barbara mentioned this morning how there are 24
certain things that just keep coming back because 1
people want the right answer, -- that's true. 2
(Laughter) 3
MR. BANDELE: I don't want to go into a long 4
discussion about the reasons why the committee strongly 5
feels that we need to really not give up on this 6
compost tea issue. The decision, as I understand it, 7
was not based on scientific data -- at least scientific 8
data that many of us have seen. So what I'll propose 9
tomorrow as an action item is to reactivate the compost 10
task force with the specific charge to look at the 11
compost tea issue and I'm going to recommend that Eric 12
Sideman (ph) who shared the task force will serve as 13
co-chair along with Dennis Holbrook. So I'll reserve 14
that until tomorrow. 15
CHAIRPERSON CARTER: Okay, Rose. 16
MS. KOENIG: And just for clarification, I 17
guess for Richard and Barbara maybe it'll be a little 18
bit more palatable. Some of the discussion is that -- 19
that according to what is stated on the website, it 20
just nullifies the use of any kind of compost tea and 21
it's argued in the field that many compost tea products 22
don't use manure. And so we want to make sure that the 23
compost task force looks at this again, and at least 24
breaks out the products that would not, in the compost 1
-- they would like to examine all the types of products 2
that would fit within that category, and see if they at 3
least could not be looked at separate entities, because 4
there may be some that are -- it's such a general term 5
within the field, that many of them may not even 6
include manure products, and those especially may not 7
have a problem. That's the background. 8
CHAIRPERSON CARTER: So it's not exactly 9
asking the same question. 10
MS. KOENIG: No, it's not. 11
CHAIRPERSON CARTER: It's a new compost tea. 12
It's compost coffee. 13
MR. BANDELE: I just have a question at this 14
point. I think in one of my discussions with Emily, I 15
think she pointed out that there were several compost 16
tea products that are on recertified at this time. 17
What would be the state of ... 18
(several speak at once.) 19
MR. BANDELE: No I said ... I had a couple 20
conversations with Emily, and she stated that there are 21
a few compost tea formulations that are almost approved 22
at this time. What would be the status of those that 23
have ... approval? 24
MR. MATHEWS: They're not approved. 1
MS. KOENIG: And that was where some of the 2
question lies, because on some products, as I 3
understand, they don't even have -- they just have a 4
plant component, that the compost is actually made out 5
of a plant with no -- 6
CHAIRPERSON CARTER: Okay, then -- Mark and 7
then Barbara. 8
MR. KING: Well, and Barb may go into this, 9
but I guess one of the things that -- and not that I'm 10
a regulatory reviewer -- but compost is a process, and 11
I think that when you put that word in any product, 12
that you lend yourself to certain things, shall we say. 13
So -- and so -- go ahead. 14
MS. ROBINSON: I just want to say it's not -- 15
it's not just -- you focus on manure and that's -- that 16
is an issue, but manure is narrowing the issue. The 17
issue is really pathogens. It's not whether -- and 18
pathogens can be caused -- I'm no scientist, but my 19
understanding is pathogens are not limited just to 20
manure. So that's part of the issue. Now, I also 21
thought that we had decided to tell people that you had 22
to treat compost tea like raw manure. So we're not 23
saying you can't use it, we're saying you've got to use 24
it with those restrictions in terms of time before you 1
apply and harvest from the ground. 2
MR. MATHEWS: That's correct, that's what we 3
did say. 4
PARTICIPANT: ... tea ... 5
MR. MATHEWS: Yes, that's the other thing. 6
Don't call it compost tea. 7
MR. MATHEWS: Plant-based foliar spray. 8
MS. ROBINSON: I mean at the end of the day, 9
see you've got to come back to 205203(C). I can do 10
that too, Rick. Which says that you can't -- which 11
says that no producer should apply things or do things 12
to the soil that da-da-da. So that's the binding 13
constraint that producers operate under. We don't 14
really care where it's coming from, but you can't 15
contaminate the soil or cause increase in pathogens and 16
that sort of thing. 17
MR. MATHEWS: Or a food safety crisis. 18
MS. ROBINSON: Right. 19
MR. MATHEWS: Which kills -- 20
MS. ROBINSON: Or a food safety crisis which 21
would cause devastation in the program overall. This 22
is not a food safety program, and we aren't going 23
there. 24
CHAIRPERSON CARTER: Emily. 1
MS. BROWNROSEN: So let me get this straight. 2
So you're saying it's not allowed because it doesn't 3
meet 203(C). Now our position has been that the 4
compost we review meet the regulation as written for 5
compost, and we require pathogen testing, and we say 6
they do meet 203(C) on the terms of contaminating the 7
crops with pathogens. In order to be on the list they 8
have to have pathogen testing and they have to be 9
composed and reach the temperature and turned five 10
times, and et cetera, the whole nine yards. So when 11
the guidance says it's not eligible to meet 203(C), is 12
that what you meant? Or do you mean to say that it 13
must meet 203(C) to be eligible to be compost tea? Am 14
I talking too fast? 15
MR. MATHEWS: We have said no to compost tea. 16
MS. BROWNROSEN: Right. 17
MR. MATHEWS: If the Board wants to 18
reactivate it -- task force, and come back with 19
additional information, we'll be glad to review it. 20
MS. BROWNROSEN: Okay, because I just thought 21
I heard you say in September -- in September there was 22
some -- Barbara mentioned, I believe, that if they had 23
pathogen testing, that wouldn't be a problem, or if 24
were treated like raw manure it wouldn't be a problem. 1
MR. MATHEWS: I think she just told you not 2
to call it compost tea. 3
MS. ROBINSON: Don't call it compost tea. 4
The problem is that there are people -- 5
CHAIRPERSON CARTER: Use the mike. 6
MS. ROBINSON: The problem is that we know 7
that there could be an inappropriate or an 8
indiscriminate use, or somebody's not paying any 9
attention, and what we wanted to get -- the point we 10
wanted to get across to people is it doesn't matter 11
what you call it, but you can't contaminate the soil or 12
the food. I don't care if you call it marshmallows. I 13
mean it doesn't matter. A soil amendment. It's a soil 14
amendment. 15
MR. MATHEWS: We have said that it could be 16
used in the same way that you would raw manure. But 17
what you have to -- but part of the problem that we 18
have is that for every farmer who is using a 19
manufactured product that went through a real, rigorous 20
process that guaranteed not to be a problem, there's 21
probably a hundred of them out there making it in their 22
own back yard, who are not going through that rigorous 23
testing, and that are the ones who could lead to food 24
safety crisis, and one we want to protect you from. 1
MS. ROBINSON: The only way that we can give 2
certifying agents the ability to ask the questions and 3
enforce the regulations is to say it like this, and 4
basically say -- what we're saying to certifying agents 5
is you have every right to expect that this stuff is 6
being -- whatever it is -- that it's being made 7
appropriately and applied appropriately. That if there 8
are questions in your mind, it should be tested -- that 9
sort of thing. Because -- 10
MS. BROWNROSEN: But they do have the ability 11
to do that? 12
MS. ROBINSON: Yes, certifying agents have 13
that right. They have that ability. Do they not? 14
CHAIRPERSON CARTER: Okay, sounds like a task 15
force issue. Marty, did you have something you needed 16
to add? You were pacing -- 17
MR. MESH: No, I'll wait for the task force. 18

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From: mrill <[email-masked]>
Date: Sat, 9 Nov 2002 23:10:32 -0700

Now I am really confused.  Can anyone clarify the NOSB meeting minute
tidbit extracted in Frank's post?  The interesting conversation about
compost tea on this list has been based, I thought, on a concern about
the NOSB Compost Task Force recommendations against the use of molasses
or other sugars in teas used closer than 120 days til harvest.

But the conversation from this NOSB meeting just a few weeks ago makes
it look like Mr.Mathews and Ms. Robinson -- both NOP staff -- have
decided compost tea can't be used -- unless its treated like manure --
and also, don't call it compost tea.

This is not what I understand the NOSB  task force to have recommended
in May.

Can anyone clarify -- do I just misunderstand the technicalities?  What
does it mean when an NOP staff member says: "We have said no to compost
tea."  Where is this discussion in the minutes?!
thanks, Mrill

--
Mrill Ingram
217 N. Third Street
Madison, WI 53704
[email-masked]
608-242-1836 (h)
608-265-9023 (w)

.

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From: Elaine Ingham <[email-masked]>
Date: Sun, 10 Nov 2002 09:11:10 EST

Let's clarify the different kinds of compost tea that you might be concerned
with, and ones that you don't need to be concerned with.  If I forget a
category, or you see the need to split a category, please chime in  -

First,  if you apply tea made from any source more than 90 to 120 days before
the crop surface would be consumed, there are no worries.

Second, compost tea made from plant-based, no human waste compost.  E. coli
is not present in the starting materials, not present in the compost.  This
category should be of no concern to folks with respect to the human pathogen
question.

Third, compost tea made with food waste material that could have low levels
of E. coli.  E. coli is fairly easily reduced to non-detectable levels with
this type of compost.  Testing might be necessary to document that E. coli is
not present in the final compost material, and that it is then safe to apply
to food plants.

Fourth, manure-based tea is what the E. coli concern is all about.  We can
make compost tea from manure-based compost without any E. coli in the final
tea.  BUT people also manage to make compost tea from manure-based compost
that contains E. coli.

The problem becomes, how do you KNOW that you managed to exit the E. coli
from the tea?  What are the parameters that allow E.coli (and other human
pathogens) to be destroyed?  We have done it, but now we need to understand
what the important factors are in producing these teas routinely.

So, that's where the situation is.  Don't go ballistic about compost tea in
general.  But on plants that you eat without washing the surface of the
material you are going to consume, stay away from compost tea made with
manure-based compost.

Elaine Ingham
President, Soil Foodweb Inc.
www.soilfoodweb.com