[compost_tea] CTTF Comment

From: Kirk Leonard <kirkleon_at_open.org>
Date: Sun, 16 Jan 2005 17:40:14 -0800
I thought about sleeping on this another night, but decided Sunday was a
good day to loose it.  Arrives bright and early in DC, too.  For those who
aren't aware, the folks at US National Organic Program tried to ban compost
tea in 2002, and vermicompost is still not officially organically
certifiable!  I won't go into how absurd that feels.

I look forward to other comments here, and what ICTC, CTIA and CTERF may
have to say.  Hope we can bat this around.  The best opportunity this year
to have a positive effect is now.

Testing, sanitation and potable water were the open issues pending an NOSB
recommendation at their last meeting.  A revised recommendation is possible
in March.

----- Original Message -----
From: "Kirk Leonard" <kirkleon_at_open.org>
To: <NOSB.crops_at_USDA.gov>
Cc: <Katherine.Benham_at_USDA.gov>
Sent: Sunday, January 16, 2005 5:25 PM
Subject: CTTF Comment

> Dear NOSB Crops Committee,
>
> This is a comment on the April 2004 Compost Tea Task Force report
> recommendations which you discussed in the October 2004 board meeting and
> are currently under consideration by NOSB.
>
> First, as a user of compost teas, I want to express my appreciation to
NOSB
> and the Crops Committee for keeping compost teas alive despite NOP's
evident
> desire to ban them as an organic practice. This is most puzzling to me, as
I
> believe it may be for NOSB, because no incidents of the dire potential NOP
> imagines have ever been reported for compost teas of any type, though they
> have been used for many years, many centuries for some.
>
> The newest form, aerated compost teas (ACT) for foliar applications, 20
> years in development, very promising, also never reported to present a
> pathogen problem, and used worldwide by thousands of growers today, is
> emerging as a good, safe organic practice, and ought to have USDA/NOP
> support.
>
> Second, recognizing the apparent position that NOP will not allow compost
> teas for foliar applications without some kind of testing, I offer the
> following suggestions, which comprise a range of options for growers, and
> includes manufacturers. Rather than specify one way, why not several
> options?
>
> I am addressing foliar compost teas only with these suggestions, all other
> uses ought to be allowed without restrictions.  I also suggest a parsing
of
> water standards between foliar and other uses.
>
> If, as I suspect, NOP will not support foliar compost teas without
testing,
> I urge you to include in your recommendation requirements for them to
> collect the data and provide test cost support for compost tea users and
> machine manufacturers, per existing USDA data collection and certification
> support programs. I also heartily endorse the Compost Tea Task Force
(CTTF)
> recommendation for more USDA research on compost teas.
>
>
> BASELINES
>
> 1.  Compost tea is not raw manure, as NOP would have it.  The CTTF report
> properly distinguishes "manure extracts" from compost teas.  Even if raw
> manure was used to make a tea, the result would not be raw manure, so the
> assertion is preposterous.
>
> Compost teas, broadly defined, are water extracts of composts or
> vermicomposts, with or without additives or adjuvants. The definitions set
> out in the CTTF report are sound.
>
> 2.  EPA standards for compost, already included in NOP's Final Rule
section
> 205.203, and EPA standards for recreational water present appropriate
> pathogen threshold standards, although irrigation water might be more
> appropriate.
>
> 3.  The Compost Task Force (CTF) April 2002 report on compost tea
> recommended that compost teas made from certifiable compost but without
> molasses or added sugars should be allowed without restrictions. This
> conclusion, while commendable, was premature because none of the machines
or
> methods apparently used to establish a molasses problem were able to deal
> with the bacterial blooms and low-oxygen conditions that can result from
> molasses in compost teas.  To me, this is a red herring, not real world
> worthy, because machines capable of dealing with these conditions are
> available in the market today, and information about managing for these
> conditions is likewise readily available.
>
> 4.  Compost tea adjuvants or additives named in the CTF/CTTF reports
present
> zero pathogens. There was confusing language about this in both reports.
> Molasses and the other materials named are not pathogen sources. The most
> significant source is composts, if poorly made, or possibly bad water, but
> potable, recreational or irrigation water should not present problems.
>
> 5.  Compost teas require five key things:  Good compost or vermicompost,
> good water, good additives, cleanliness in preparation and use, good
methods
> and machines.  None of these conditions are extraordinary.
>
>
> SUGGESTIONS FOR CERTIFICATION WITH COMPOST TEA
>
> 1.  If potable water is used, all equipment is kept clean, additives are
> organically acceptable, and the compost is certifiable, foliar tea should
be
> allowed without restrictions.
>
> This evidence and its documentation is the best solution for
certification.
> No tests, just evidence and documentation.
>
> 2.  Two tests of compost teas using a fixed compost and additive recipe,
per
> EPA recreational water standards for escherichia coli or enterococci.
>
> This is the current recommendation in the CTTF report, but it can be
> prohibitive for growers of many different crops, because variations in
> composts and additives are common, depending on the crop, so too many
tests
> and too much expense might be required. If a grower can sequester compost
> and use fixed additives, it can be made to work, but more flexibility
would
> be better and is likely needed. There is value in retaining this as an
> option, however.
>
> 3.  Test the compost. If the compost shows pathogens below EPA Class A
> compost standards, the tea should be certifiable. The making of tea with a
> tested compost, water, additives and cleanliness acceptable, should be
> allowed without restrictions.
>
> This, ultimately, could be the best baseline test for the safety of
compost
> teas, because if good water is used, it's the only possible source of
> significant pathogens.
>
> 4.  Test the machine. ACT development has led to the manufacturing of
> compost tea machines in the last ten years. The trend among these
> manufacturers is to provide composts and additive recipes that provide
> proven, safe, aerated compost teas for foliar uses.
>
> A given machine tested with compost that exceeds Class A compost pathogen
> standards some number of times, and shown to meet the requirements of #2
> should support its certifiability. This would support manufacturer,
> farm-made or site-built machine certifiability.
>
> A tested machine, NOP-certifiable compost, use of potable water and
> maintenance of clean conditions should be sufficient to support
certifiable
> compost tea for any use.
>
>
> All tests done should conform to EPA and USDA standards in place today,
> which most labs support, with test documentation provided to certifiers to
> confirm certifiability.
>
> Again, since NOP's primary concern appears to be foliar use of compost
teas,
> these suggestions apply to foliar teas only, not to soil-applied teas or
> other uses, which should be allowed without restrictions if acceptable
> composts and additives are used.
>
> The requirement for potable water should also not apply to soil or other
> uses, for which irrigation or recreational water standards should be
> sufficient.
>
> Finally, on another subject, the specification that sanitizers be as
defined
> in 21 CFR 178.1010 is unnecessary. Sanitizing agents already specified in
> the National List are sufficient.
>
> I hope this is useful and would be glad to respond to any questions or
> concerns you have as you develop compost tea certification standards.
>
> Sincerely,
>
> R. Kirk Leonard
> P.O. Box 4489
> 2250 Strong Rd SE
> Salem, Oregon 97302
> 503-391-6735
> kirkleon_at_open.org




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Received on Sun Jan 16 2005 - 21:37:56 EST

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