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organic standards

Standards Review: Behind the Scenes

in 2020/Current Issue/Livestock/Organic Community/Organic Standards/Standards Updates/Winter 2020

Tristan Banwell

How did I come to be involved in the 2020 Review of the Canadian Organic Standards from my organic outpost near little old Lillooet? Well, Anne Macey talked me into it, of course. By email. She’s very charming and persuasive, even in text.

I am glad she did recruit me, because I now realize how important the process is. I have also become very familiar with the livestock standards, and I have heard the perspectives of producers from many regions of Canada and all scales of production. It was eye-opening and rewarding (and time-consuming!). I have a deep appreciation and respect for the people at the Organic Federation of Canada who made this process happen. A lot of hard work and organizing goes into this process, and a lot depends on us, the volunteers on the Working Groups.

It’s my turn to talk you into getting involved, or at least convince you to read Rebecca Kneen’s article all the way through so that you know what is going on.

Throughout 2018 and 2019, I volunteered on the Livestock Working Group, and sat on smaller groups called Task Forces for Poultry, Swine, and Ruminants. Many of the participants are producers, some large and some small. Others are inspectors, consultants, agronomists, veterinarians, or employees of various organizations, like the SPCA (or COABC!). I was surprised to find there are also industry group representatives participating on behalf of their constituents, such as the Chicken Farmers of Canada and Egg Farmers of Canada.

Each of the Livestock Task Force groups included 8 to 20 individuals, while the Livestock Working Group was comprised of 40 to 60 people. Meetings were two to three hours long by teleconference, with participation on Google Drive for document review and collaborative editing. The Working Group met monthly from September 2018 to April 2019, and again in the winter of 2019/20 to complete the process. Task Forces met an average of three times.

New Task Forces cropped up within the Livestock Working Group to deal with petitions related to Apiculture, Bison, and Rabbits. Members of our working group were also recruited to advise the Genetically Engineered (GE) Task Force, and invited to join the Social Fairness Task Force. Sometimes a petition for another Working Group would come across to Livestock for comment, or seeking the answer to a specific question. But primarily, we got down to work reviewing petitions for changes to the Standards with regard to swine, ruminants, and poultry.

Often, especially when a petition was unrealistic to implement or perceived to weaken the Standards, the groups could quickly reach consensus with a recommendation. I came to appreciate the flexibility of the Standards to apply in so many different contexts, while ensuring a basic set of principles is respected. It is easier to understand the complexity of the Standards when you realize that they are built and revised one particular circumstance at a time.

We also navigated many controversial conversations. What one participant may view as strengthening the Standards may be seen by another as a meaningless change leading to unnecessary expense. Dedicated volunteers gathered and shared research to support their positions and worked over wording repeatedly to solve disagreements. Consensus was sometimes difficult to reach, sometimes impossible. At times, a voting block would solidify and no proposal offered could progress. This was frustrating, but the system is designed to move discussions forward regardless: if a Task Force cannot make a recommendation, the topic goes back to the Livestock Working Group for further consideration. If that still does not help, it’s back to the Technical Committee.

After suggested changes go out for public review over the summer, the comments come back to the Working Groups. We must address all comments. In the case of Poultry, so many comments came back that the conveners further divided the Poultry Task Force into a small and nimble committee that could make recommendations that then returned to the larger group. In the end, our recommended changes to the Canadian Organic Standard will go up to the Technical Committee, who can then accept, revise, or reject the changes. This group will consider not only the recommendation but also the context, and if a topic was highly controversial or many negative comments are received, they should take that into consideration.

I am interested to see how our hard work influences the Canadian Organic Standard, and I know that when the process comes around again, I will step up and put in the time to make my voice heard. I hope that you will too.

Tristan Banwell is a founding director of both the BC Small-Scale Meat Producers Association and the Lillooet Agriculture & Food Society, and represents NOOA on the COABC Board. In his spare time, he manages Spray Creek Ranch in Lillooet, operating a Class D abattoir and direct marketing organic beef, pork, chicken, turkey, and eggs. farmer@spraycreek.ca

Organic Standards: The Process and the Principles

in 2020/Current Issue/Organic Community/Organic Standards/Standards Updates/Winter 2020

Rebecca Kneen, BC board representative to the Organic Federation of Canada

Once upon a time, we in BC wrote our own organic standards. Those of us with the inclination got together regularly to figure out the problems and decide how best to address them while staying true to our principles. Every year, at the COABC conference, we’d debate all the proposed changes to the standards. Some of us will never forget the epic eight-hour discussions we had about treated posts, and the many-year discussions on poultry standards!

It was a tremendous group effort, and a huge amount of thought and work went into it—and it created the bonds which still hold COABC together. 

In 2009, after long discussion throughout the organic community, we collectively decided that a national organic standard was necessary. More and more products labelled as “organic” were coming into Canada, with no verification as to their actual quality or how it would compare to our own standards. Even within Canada, most provinces lacked their own certification regulations. The goal was to create a robust, thoughtful, and ethical standard which could be used to improve the quality and scope of organic production within Canada, and a measurement to accept or reject incoming goods as equivalent organic quality. The BC and Quebec standards formed the basis of the current rules—and the system has been evolving ever since, as techniques, resources, and markets have changed.

Most of us are concerned about the standards themselves—the rules about what, how much, how often. We refer to them when we are looking at such things as a new process, crop input, sanitizer or cleaner, or when we are designing a new livestock barn. We check them right after our annual inspection, when the Verification Officer (VO) references a particular section and we need to understand it. Sometimes we read the Q&A when the E-News comes out and we realize that there might be something that affects our farm. What we mostly DON’T do is think about how these standards are created and who’s involved—unless we think a new decision is wrong. In order to understand why certain decisions are made, we need to understand the structure, membership, and pressures in the organic system.

So, who is it that is looking after the standards? What pressures do they operate under, who’s the boss, and how do we make sure that our standards embody the ethics and values that created the organic idea in the first place? This is where we get to play the acronym game.

The Canada Organic Regime (COR) is the system of organic certification. It has two parts: enforcement and regulation. The entire system is part of the “Safe Food for Canadians” act, and is enforced by (in descending order): the Canada Food Inspection Agency (CFIA), the Conformity Verification Bodies (CVB) like COABC’s Accreditation Board, and finally Certifying Bodies (members of COABC such as NOOA, FVOPA or the for-profit CBs such as Eco-Cert). The regulations apply to any product that moves between provinces or internationally that carries the COR logo.

The Canadian Organic Standards themselves are owned by the Canadian General Standards Board (CGSB) which makes the rules about how frequently the standards must be updated and the process used. The CFIA establishes organic equivalency agreements with other countries (Japan, USA, EU, Switzerland, Costa Rica). The Standards are owned by a government agency but reviewed every five years in collaboration with the organic industry. CGSB staff are not knowledgeable about organic agriculture; they only verify the review process and have nothing to do with the content.

Here’s where the rubber meets the road for most of us: the standards writing and review process. The top level of this process is the Standards Interpretation Committee (SIC). 

The CFIA created the SIC to resolve conflicts between CBs and producers. The SIC is made up of appointed members from across the organic sector and is managed by the Organic Federation of Canada (OFC). You will have seen the many lists of questions put to the SIC: the answers published on the OFC website are legally enforceable. CBs and producers have to comply with SIC decisions, as per the CFIA Operating Manual. The OFC ensures that SIC members have the required expertise and deep knowledge of a variety of areas of organic agriculture and processing, and provides guidance to the SIC.

The CGSB appoints its own Technical Committee, also made up of industry experts, but in this case,  they are selected by the CGSB not by the OFC. This committee has the power to modify the standards, whereas the SIC can only clarify the meaning of the standards. The Technical Committee analyzes recommendations from the SIC and the OFC Working Groups or the public when an amendment or a full review of the standards is launched.

The OFC working groups are made up of volunteers from across the country with expertise in specific areas. There are working groups for livestock, specific crops, and so on. Petitions for changes to the standards are received by the OFC, then brought to the various working groups for discussion, research, and recommendation. The working groups have up to 20 members, all participating in the entire process of reviewing questions and petitions for changes. They are able to do their own research and to share information widely. This is not a secret process!

In previous standards reviews, proposals have been received on a huge range of issues. As an example of how the working group works, one proposal received in the last round requested that the use of non-organic manure be prohibited, another that manure from non-organic sources including confined livestock or stock kept in the dark be permitted. In the first case, the proposal was rejected because there is a large deficit in the supply of organic manure, and such a restriction would create a huge barrier to organic production. In the second case, the proposal was also rejected on the grounds that the petition would weaken the standards and erode public confidence.

There are many areas where this process can be influenced in any direction. The membership of the working groups, technical committee, and SIC itself can be manipulated (intentionally or not). How questions are grouped for presentation to the working groups, and which resources are used will influence the outcome. 

The OFC is serious about upholding organic values and principles. In soliciting members for the working groups, we aim for skilful, balanced representation with people whose interests go beyond short-term financial gain. We try to balance technical expertise with breadth of experience, large and small producers, cross-country representation, and commitment to organic principles. 

There is a lot of pressure on all parts of the organic industry to allow more money to be made, to loosen regulations so that they are “more accessible”, and to allow foreign influence on our standards. The recent move by the USA to push for Canada to include hydroponics in the organic standards is one example. In this case, the OFC, Canada Organic Growers (COG) and the Canada Organic Trade Association (COTA) collectively repudiated this move (see the excerpted letter in this issue of the BCOG). We’re also seeing livestock standards pressured to allow more confinement and less outdoor access, and crop standards pushed to allow indoor growing without natural sunlight.

The three national industry groups (OFC, COG, and COTA) are working together to find more ways to inextricably embed our principles into the entire regulation and the processes for amendment. 

What this really needs is support from our membership: from you. We need more people to volunteer for the working groups and the CGSB Technical Committees. We need you to put your expertise and ethics to work for the whole community. You don’t need to be a world-renowned expert, you just need to want to work, learn and do a lot of reading and talking. Most of all, you need to want to support the community that supports you. 

Contact Nicole at the Organic Federation of Canada to find out how to volunteer for any of these committees: nicole.boudreau@organicfederation.ca

Read more:

Organic Federation of Canada

Canadian Organic Growers

Canada Organic Trade Association

Rebecca’s parents led her down the sheep track to food sovereignty and food systems analysis through their Ram’s Horn magazine and Brewster’s many books. She farms and brews in Secwepemc Territory at Left Fields/Crannóg Ales and is COABC’s representative to the Organic Federation of Canada.

Re: Official position of the Canadian Organic sector on Hydroponics being considered in organic 

Excerpts from the full letter:

“We stand united and unequivocally reject the allowance of hydroponics by the Canada Organic Regime (COR) for sale in Canada and for export to other trading partners. The very notion of being asked to articulate why hydroponics is banned from COR is similar to being asked why we would ban synthetic pesticides, genetically engineered seeds and have built humane treatment of animals into the organic standards.

The global definition of organic (despite the USA’s National Organic Program recent ruling permitting hydroponics) prohibits hydroponics. In fact, there is a court hearing challenging the NOP’s permittance of hydroponics currently in the US court system as the USDA’s allowance of hydroponics is a fundamental shift away from the global norms of what is defined as organic. We fully support and stand behind the organic sector in the USA who is challenging the NOP/USDA for allowing this egregious act. 

The organic sector is a $5.4 billion market in Canada, with over a billion in export sales worldwide. The USA’s NOP hydroponic products are banned from all export sales due to not meeting international standards. We stand united in that we do not want any US hydroponically produced products entering Canada and lowering the public trust that we have worked to establish in Canada. We also do not accept or support the Canadian Horticulture Canada (CHC) and the Ontario Greenhouse Growers position that there is a trade harmonization concern. 

Our Canadian organic standards and US-Canada Equivalency Arrangement is absolutely clear that operators must adhere to Canadian standards and respect the details of the equivalency arrangement. The system has been set up banning hydroponics since 2009, calling out critical variances in our US- Canada Equivalency arrangement. It is of utmost concern if the Government of Canada wishes to alter the established organic standards and trade arrangement details that the organic sector has been functioning under (and strongly support). Amending the Canadian organic standard (or other mechanisms available to government) to permit organics to be produced through hydroponic methods would not only damage the trust and reputation of the Canadian organic label, but also override the research and decision reached by the Organic Agriculture Technical Committee. Any changes to current practises made without the consensus of the Technical Committee would be a breach of the consensual principles embedded in the policies and procedures of the Canadian General Standard Board. 

Our concern is that we risk retaining our respected global position in the organic marketplace and that significant trading partners, such as EU, Japan, Switzerland, would need to alter the equivalency arrangements we have with these markets should hydroponics in the organic system be permitted under any circumstances in Canada. With the court case ongoing in the USA, we certainly feel it would be detrimental to our sector to allow CHC’s argument of not being able to access the US market opportunity as a worthwhile argument to alter the standards/trade arrangement or create any policies which would change the current practise of banning all hydroponics under the COR. We support the horticulture sector accessing the US market with their conventionally grown produce but we diametrically oppose their position of trying to drag the Canadian organic sectors reputation down to the US’s “lowest common denominator” which is globally rejected and may be overturned through a court process. There is no other country in the world that permits hydroponics in their organic programs and it would be a fatal error to move in this direction for the sake of an opportunistic market opportunity.”

More reading: 



Aquaponics and the Organic Movement

in Crop Production/Organic Standards/Summer 2017

Gabe Cipes

Editor’s note: Aquaponics is a hotly debated topic in the organic sector. As the BC Organic Grower strives to make space for open discussion on all things organic, these pages provide an excellent forum to examine aquaponics in an organic context.

The fate and state of the world now depends on innovation in many forms to be supported and embraced where they are appropriate—that includes recognizing the organic nature of aquaponics.

The organic movement is based on a set of principles: health, ecology, fairness, and care for future generations and the environment. Following these principles, aquaponics is a method to produce a vast plethora of aquatic animals, fruits, and vegetables using a small fraction (~5%) of the water and on only a fraction of the land it takes to produce terrestrial crops. The soil is a recirculating, closed loop, self-sustaining, aquatic rhizosphere. The bi-product is a high value nutrient and biologically rich soil amendment.

The Soil is the Water

Within the system, we feed the aquatic animals, such as fish, crayfish, shrimp, turtles, or alligators, and they populate all surface areas of the system with their gut biomes and provide nutrients. A diverse host of bacteria, protozoa, worms, fungi, and microbes convert solid waste and ammonia into nitrites and then into nitrates. The plant archaeon in the system perform phytoremediation for the water before it returns to the animals by absorbing the nitrates and nutrients transformed by the microorganisms. The plants release their own microbiology through their roots. Their secretions mix with the secretions of the other microorganisms to create humic acid (humus!). Carbonic acid is created through the cycle of death within the system. Mineralization and aeration are integrated through biological and mechanical zones. Thus, the living soil ecology is born in the water. The soil is the water.

Aquaponics is not soil-less agriculture. In fact, it brings us more in touch with the essentials of organic soil biology in a not so much controlled, but created and containable environment. The same impetus to create a self-sustaining, bio-diverse ecological balance by feeding the soil biome as is indicated in the organic and Demeter standards is practiced in aquaponics.

Aquaponics is not an easy or simple method of agriculture. It can involve highly mechanized functions and be energy intensive, although there are passive solutions available. Creating a system requires a high degree of biological, mechanical, and regenerative knowledge as well as careful insight. Just as with any method of farming there can be a broad spectrum of health in practice. Creating and stabilizing this natural food producing ecosystem organically can be a life long journey for an individual or a collaborative team effort involving many different skill sets.

Photo Credit: Gabe Cipes

Aquaponics vs Hydproponics

It is critical to draw the distinction between hydroponics and aquaponics and not lump the two together as soil-less agriculture even though they may look alike in certain regards. Hydroponic growing removes the crucial soil factor and replaces it with soluble nutrient solutions force fed directly to the plants. Hydroponics can in no way duplicate either the complex benefits of soil or the beneficial environmental impact as aquaponics can.

Hydroponics was unfortunately accepted as organic by the USDA standards due to corporate lobbying and bureaucracy. In their 2010 objection to the organic certification of soil-free farming in the US, the National Organic Standards Board (NOSB) wrote “The abundance of organisms in healthy, organically maintained soils form a biological network, an amazing and diverse ecology that is ‘the secret,’ the foundation of the success of organic farming accomplished without the need for synthetic insecticides, nematicides, fumigants, etc…” (NOSB 2010) The “secret” to aquaponics is the same. Hydroponics is not certifiable in Canada, while aquaponics is certifiable under the Organic Aquaculture Standards CAN/CGSB- 32.312-2012. [Editor’s note: None of the Certifying Bodies (CBs) accredited by COABC are currently certifying aquaponics.]

An Ancient Practice

Millennia ago some of the most powerful nations in history utilized similar agricultural practices: the Chinampas, floating gardens of the American Aztecs, the rice paddies of ancient China, and ancient Greek descriptions of the hanging gardens of Babylon, one of the seven wonders of the world. They all relied upon fish and aquatic animals to fertilize their agricultural systems.

It is possible to grow crops this way because aquatic animals such as fish, crustaceans, and many other aquatic creatures do not carry the same potential pathogens in their manure as terrestrial animals do. The difference in application is the time and processing of the manure when comparing terrestrial manure to aquatic manure, which is pretty much immediately available as long as the system is colonized by the gut biota of the animals living in it. It can take two to six months to establish a living system. Multi-trophic remediation (involving aquatic plants and crustaceans) is encouraged in organic aquaculture.

The contemporary mastery of this method of agriculture in Canada has yet to be realized. The potential to grow fresh fish and vegetables all year long on a commercial scale is enormous. Large scale systems could economically compete with conventionally grown imported crops for the bulk foods market, supplying restaurant chains and big box stores without competing with high end niche organic markets or polluting the environment. It is accessible to all demographic and geographic variables. Due to its productivity and ability to provide both animal and vegetable products together in a compact space it can empower people to overcome hunger and starvation in remote areas.

Farming fish and crops this way allows our natural watersheds and natural soil ecologies to heal and regenerate. The vast majority of our planet is covered by oceans, which are under extreme stress today. One of the major sources of stress is over fishing (Rogers 2014). Aquaponics or variations thereof are the most sustainable methods of producing high quality and environmentally friendly fish.

Photo credit: Emmanual Eslava

Closing the Loop

The primary input of an Aquaponic system is the feed for the fish. Organic feed for salmonids, coregonids, tilapia, koi, sturgeon, cat fish, perch, and other commonly used species is commercially available upon demand in BC through at least three major pet food distributors, namely: Ewos, Taplow, and Skretting. Major strides have been made recently in designing low cost sustainable organic formulas for fish feed, with the inclusion of insect larvae, yeasts, invasive species of shrimp, algae/phytoplankton/kelp, organic grains, and tailings from the fishing industry. It is possible to close the loop on the need for aquatic fish protein and oils if organic aquaculture and aquaponic farmers work together to provide different species of tailings for formulas to be used within the organic industry. The goal is to be independent from relying on depleting oceanic sources of aquatic proteins.

There are many aquaponics operations currently certified organic in BC. You can learn more about the organic standards for aquaponics by reading the 32.312 Organic Aquaculture standard. You will see that the crop standards are pretty much identical to the 32.310 Terrestrial standard. Most operations, especially in BC, are contained structures to maintain bio-safety and bio-security. It is becoming increasingly vital to maintain organic integrity by avoiding contaminants in our environment.

In regards to pests or disease, crop pests would either be contained mechanically or be subdued by an introduced species to balance the disease or infestation. Beneficial fungi, insects, plants, and animals are introduced and form symbiotic relationships. Antibiotics and hormones are also prohibited in organic aquaculture and stocking density needs to be kept low to prevent lice or other diseases. The prohibited and allowed substances align with 32.310 in regards to all materials and devices.

As this technology and its applications develop, so too will the organic standards. They will evolve and adapt through consensus of multiple organizational bodies to include better ecological practices. I hope to be involved in that conversation for many years to come. The standards are a base for the development of this method in Canada and should inspire best practices for the burgeoning organic aquaponics industry.

Organic Aquaculture Standards:
www.scc.ca/en/standardsdb/ standards/26378

Gabe Cipes is a Permaculture designer and Biodynamicist practicing out of Summerhill Pyramid Winery in Kelowna, BC. Gabe keeps bees, chickens, creates the nine biodynamic preparations, and over sees the culinary gardens, forest gardens, and insectary habitats on the largest certified Demeter/Organic vineyard in Western Canada. Gabe serves on the board of COABC, the Biodynamic Associations of BC (BDASBC), and Demeter Canada as well as the Central Okanagan Food Policy Council (COFPC) and the Organic Okanagan Committee. Gabe has been collaborating with a team of entrepreneurs, aquaculture specialists, scientists, engineers, and biologists to develop organic and biodynamic managed commercial aquaponics facilities. The compa- ny’s mandate is to help supplant some of the conventional ravages facing the world with the highest quality, nutri- ent rich, and harmonious fish and produce, allowing our planet and populations to heal.

National Organic Standards Board (NOSB). (2010). Formal recom- mendation by the National Organic Standards Board (NOSB) to the
National Organic Program (NOP). https://www.ams.usda.gov/sites/ default/ les/media/NOP%20Final%20Rec%20Production%20Stan dards%20for%20Terrestrial%20Plants.pdf
Rogers, A.D. (2014). State of the Oceans Report 2013. Internation- al Programme on the State of the Ocean. http://coastal-futures.net/ archives/220
Savidov, N. (2005). Evaluation of Aquaponics Technology in Alberta, Canada. Aquaponics Journal 2nd Quarter: Issue 27, pp. 20-25.

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