NOP Organic Seed Rule Discussion
The following is a response to a letter sent to Rodale’s online magazine, New Farm, by organic farmer Richard Glenister. Glenister was responding to an article “Let’s get real, and all commit to using organic seed” written by The Rodale Institute’s farm manager, Jeff Moyer.
Jeff’s article was posted November 9, 2006
Richard’s letter was posted February 16, 2007
OSA’s response posted on March 15, 2007
By Matthew Dillon
I would like to address Richard Glenister's very well-written and important contribution to the dialogue on the use of organic seed. As someone who has worked in the world of organic seed for going on a decade, I would like to affirm some of Richard's concerns as well as suggest directions for going forward. First, some background:
I am the founder and current executive director of Organic Seed Alliance (OSA). I will soon step down from this role and transition to advocacy director, a position we are creating to focus more attention to issues and successes in the world of seed. The alliance is a public nonprofit whose mission is to support the ethical stewardship and development of seed. OSA is funded primarily through USDA grants, private foundations and individual donations from the public at large.
We work in partnership with organic farmers, university educators and researchers, as well as the seed industry. While we partner with the seed industry, we are not an industry association, and less than 2 percent of our budget comes from industry donations (mostly from booths at our seed conference). We do not sell seed or have income linked to sales of organic seed. We do not always agree with the industry, but we see its players as important, vital and well-meaning partners in creating healthy and ecologically, socially and economically sound seed systems.
While there are the obvious large gene giants out there that are wreaking havoc, there are also dozens of small regional companies that care greatly about the success of farmers. Some of these companies are 100-percent organic, while others are just putting their toes in the water. Both types are important to the success of improving our seed.
OSA believes the current seed exceptions within the NOP rule are necessary given the current state of organic seeds – the lack of commercial availability, lack of diversity of varieties, and quality issues. Forcing farmers to use the limited organic seed that is presently available would result in severe shortages and would deprive producers of the best available genetics and quality for their production systems. The loss of choice of genetics is particularly an issue in minor regional crops such as overwintering brassicas in the Northwest, or short-season crops as was exemplified by Richard's corn.
However, the exception creates the potential of an endless loophole, as well as an inconsistency in the enforcement of standards. A producer would never be required to transition to organic seed if they are using a variety that is proprietary and if the seed company producing this variety chooses to not offer it organically. This exception could go on without end, damaging the credibility of organic standards.
Companies left in a quandary
In terms of the rule’s effect on seed quality, the current exception leaves the seed industry straddling a fence on this question whether to invest or not invest R&D dollars in organic seed development and production. Unsure of the return on their investment, companies are not fully addressing quality and quantity issues as directly as they could be, and so the cycle continues. Without investment, how can regional varieties be developed that meet the needs of farmers like Richard? How can small companies invest in quality controls to prevent sales of low-germ seed? How can organic farmers learn the intricacies of producing good organic seed?
More importantly, an endless allowance to use conventional seed would fail to fulfill the spirit of organics. The production of conventional seed requires heavy application of chemical pesticides (being a non-food crop, the allowances are much higher, and the rate and amount of use are rarely fully reported), including methyl bromide. In the spirit of the movement, organics needs to be concerned about the ecological effects of all inputs – the upstream and downstream costs.
Seed production is fairly centralized, and as such so are the ecological costs. In areas such as the Willamette and Skagit valleys of Oregon and Washington, where we produce a high percentage of the world's dry-seeded specialty seed, the costs translate into compromised water and soil systems that impact the entire biotic web. If you don't bury your head in the sand to ignore it, what organic farmer wouldn't want to use organic seed for this reason alone?
But there is a better reason for supporting investment in and usage of organic seed than regulation, or even preventing localized ecological contamination. Organic agriculture as a whole will find even greater success as we develop truly “organic cultivars” – organic not just because the seed was produced on organic ground and sold by a company certified to handle organic inputs – but cultivars that have been adapted for low inputs, exhibit elasticity in the face of environmental extremes and that enhance the health of local food systems by extending seasons, that increase crop quality and that have improved nutritional capacity.
This will not occur without an organic seed partnership between public and private interests, a healthy partnership in which the organic community invests in seed systems that:
- * maintain farmer's rights to save seed
- * involve farmers in the breeding and genetic screening process
- * encourage rural development that includes the return of responsive, regional, organic seed companies.
Time to focus on seed
It is time for those of us concerned with organic agriculture to focus on the seed issue. Investments need to be made in creating a healthy organic seed infrastructure. Research into organic seed treatment and seed diseases, varietal evaluations, collection of data on the quantities of seed needed for organic agriculture and surveys into producers' needs are but a few of the steps necessary to build an organic seed system.
Demanding – and I mean demanding – our federal and state representatives to fund organic research in a manner that is equitable is also paramount. They need to understand that we need immediate funding that at a minimum is at a level equal to our percent of the market, and that ideally would be higher than our percentage. Research projects what future needs are, and projecting that organic agriculture will continue to grow does not require Nostradamus. Now is the time to lobby for this increase – we have a more open ear in Washington, D.C., than ever before.
From a regulatory approach, the Organic Seed Alliance recommends that a stakeholder task force be formed to work with the National Organic Standards Board and the National Organic Program. The task force would create a list of the issues that are hindering the use of organic seed, categorize these issues and articulate categorical approaches to move forward. Categories might include varietal equivalence, seed transmitted diseases, appropriate breeding techniques and others.
As an example, specifics under a category might include “Use of silver thiosulphate in hybrid parent lines” under appropriate breeding. After articulating the categories and specifics, the committee would create a timeline (in contrast to a deadline, a timeline having check points with definitive steps along the way with no set endpoint) for implementation of the rule as it pertains to seeds, to the fullest spirit of the law.
OSA believes that the committee should be composed of organic farmers, representatives of certifying agencies, university researchers, organic seed companies and others involved in the development of organic agriculture. The organic seed movement, much like the greater organic movement, has a long and rich history. It is only natural that the regulatory bodies look to those who have invested in and had success with organic seed production as counsel on this issue. This issue needs serious deliberation, not a denial or a deadline approach. The success of organic farmers and seed companies and the credibility of organic agriculture as a whole is at stake.
Regardless of the approach, we at OSA believe that education is a key component. Organic producers need to have strong crop-evaluation skills to determine equivalent genetics. Those in seed production need to understand the best practices for yielding quality, disease-free seed. Public breeders need to increase their understanding or breeding for regional needs in minor crops – areas where large private breeding firms will not meet the needs of organic producers. Seed purchasers (both farmers and catalogs) need to have easy access to sourcing the product they need.
OSA is committed to this work, as exemplified by our Organic Seed Growers Conference (our last conference focused on seed quality as its theme), field days, workshops, educational publications, breeding work and our advocacy outreach to work with public and private interests in furthering healthy seed systems.
I congratulate and thank Richard for taking the time to express his concerns. He speaks for many. He also has obviously not given up and become cynical – if he had he wouldn't have bothered to write or to contact Cornell with his breeding needs. And this, too, is the spirit of organics – not simply to criticize the status quo in agriculture, but to work to make it better.
I applaud Richard, and the myriad of farmers like him working under this principle of betterment.