Click here for the PDF version of our Standards

Call for comments: We welcome the feedback of the organic community. The standards board meets in December of each year to vote on any proposed changes. To contribute to the standards discussion, please send an email with thoughts for changes and improvements, to james@realorganicproject.org with the subject line Standards.

Real Organic Project respects the inspections conducted by MOFGA, NOFA-NY, OneCert, OEFFA, New Jersey DOA, and VOF for adhering to the soil fertility requirements of 205.203. As such, the inspections approved by these certifying agencies are a first step toward qualifying farms for Real Organic Project certification, assuming they complete the entirety of Real Organic Project certification process.

Our mission is to grow people’s understanding of foundational organic values and practices. We have created an add-on label to USDA certified organic to provide more transparency on these farming practices. USDA organic certification is a prerequisite to participate in the add-on program.

Real Organic Project is family farmer-driven and embraces centuries-old organic farming practices along with new scientific knowledge of ecological farming.  We believe that crops grown in soil and livestock raised on pasture-based systems are fundamental to organic farming.  Healthy soils equal healthy crops and livestock, which equal healthy people and a healthy climate.

The USDA has recently embraced hydroponics and has dropped the proposed rule on animal welfare. Many farmers now feel the USDA organic label no longer adequately reflects how we farm, and many in the organic community feel a loss of identity within the label. Our community worked for years to build an organic label that people can trust.

Much about the National Organic Program is a success, and most of the farms being certified deserve to be called real organic. But the farm products from a tiny minority of large industrial operations now being certified are at odds with the original intent of organic farming. Unfortunately, these few operations produce a large, and growing, proportion of the food labeled organic on the market today.

Organic Farming was defined back in its infancy as a farming method that is centered on maintaining fertile and biologically healthy soil. The Organic Foods Production Act (OFPA), and the resulting USDA/National Organic Program (NOP) Standards reflect this well. Section 205.203 of the National Organic Program Regulations does a fine job of describing soil management practices on an organic farm.

However, there is an issue. Even though the word “must” is used in the pertinent opening paragraphs of this section of the regulation, the NOP has allowed certifiers and their growers to ignore soil management if they (the certifier) think it is not applicable. Although we believe there are a handful of situations where soil is not required for production, traditional organic standards require soil for ALL production of plants to harvest.

Furthermore, it is the management of the soil that makes the farm system and land organic. In most instances, it is the land that gets certified and the farm creates a farm system plan to outline the practices that build soil health. The driving force behind the Real Organic Project is our belief that organic production standards should be based on the traditional organic guidelines of crops being grown in managed soil, with only a few, very clear exceptions explained below.

The ROP standards for soil management are the NOP standards stated in Section 205.203 of the NOP Regulatory Text, however the ROP standards honors the legal meaning of the word “must.” In section 205.203 the National Organic Program uses the word “must” because that is what is required by the law (the OFPA). Crop production that is not based on soil may be productive, safe, environmentally sound, etc., but it is not organic.

Two areas of the NOP soil management section need clarification. First is the misinterpreted section on managing livestock manure and composting guidelines. Second is the limited exceptions to the soil management requirement.

Compost

At the heart of soil husbandry on many organic farms is livestock manure. Livestock manure carries human pathogens and other contaminants. As a result, the NOP regulations require that manure must be handled in such a way that it does not “contribute to contamination of the crops, soil or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances.” In order to reduce the risk of food contamination from human pathogens, the NOP requires either a waiting period between application of manure and harvest of the organic crop, that it be applied to land producing non-food crops, or composting of the manure.

In Section 205.203(c)(2) in their regulation the NOP presents an example of how to make compost. This was misinterpreted by many growers and certifiers to be the only way to make compost. Recognizing this misinterpretation, the National Organic Standards Board (NOSB) convened two task forces that delivered comprehensive reports to the NOSB on compost (2002) and compost tea (2004). The NOSB then made a final recommendation to the NOP on compost, compost tea, processed manure, and vermicompost in November 2006.

The NOP concurred with the NOSB that the examples provided in § 205.203(c)(1-3) is not a finite list of acceptable plant and animal materials for use in organic production. For example, there are many other acceptable ways to make compost. Site-specific variation in feedstock materials, management practices, and production requirements dictate that organic producers exercise flexibility in managing plant and animal materials on their operations.

On July 22, 2011 a Guidance from the NOP went into effect (NOP 5021 – Compost and Vermicompost in Organic Crop Production). This is presented in the Appendix.

Explore Our Standards

  • Real Organic Project Standards for Origin of Livestock

    1. Dairy cows can only be transitioned from conventional to organic with a one-time transition of a single-entity dairy herd during a 12-month transition period. The continuing or recurring transition of conventional animals to organic is prohibited.

    2. A maximum of 200 dairy animals may be transitioned in a one-time transition, and at least 40% of the transitioning herd must be under two years of age.

    3. A 12-month transition, from conventional to organic, does not begin until a completed application is received by the Real Organic Project program administrator.

    4. All animals to be transitioned must be on the farm at the beginning of the transition, and each animal must have an identification name or number that can be positively associated with the animal (e.g., ear tattoo, or ear tag).

    5. A complete list of all animals on the farm, including identification number, breed, dam, and birthdate, must be submitted with the initial application.

    6. 100% of organic standards, including pasture requirements, outdoor access, feed requirements and appropriate healthcare materials must be met for all groups of animals for the entire transition year.

    7. Organic and non-organic lactating animals may not be kept on the same farm.

  • Real Organic Project Standards for Grazing of Ruminant Animals

    1. A minimum of 40% DMI and a goal of 50% or greater DMI from pasture averaged over the entire grazing season for each type and class of animal (e.g., milking cows, dry cows, heifers). Farms below 50% DMI must provide a plan for how to achieve 50%, or describe the reasonable impediments to achieving 50%.

    2. The grazing season is defined as beginning two weeks after the average normal 24-hour temperature for the farm’s specific locale rises above 45° F and ends when the average normal 24-hour temperature declines to 45° F. It includes all months in between in which pasture forages normally grow in the locale. The grazing season can be suspended for time periods when the average normal 24-hour temperature in the locale rises above 80° F. It must commence again two weeks after the average normal 24-hour temperature declines to 80° F.

    3. The Real Organic Project program administrator can make exceptions for documented cases of droughts or floods.

    4. The maximum herd size for dairy cows grazing pastures associated with a single milking facility shall be 1000 animal units. Upon written request, variances may be granted based on uniquely favorable growing climates that can achieve 50% DMI or greater from pasture.

    5. Certifiers must require producers to complete a calculation matrix for each grazing group and for each time period in which the ration changes. Inputs for the calculation matrix should include the average animal weight, average total daily DMI, and the DMI from non-pasture feed sources. The calculation output must document the percent DMI from non-pasture feeds, and by subtraction specify the percent DMI from pasture grazing.

    6. Producers must document their pasture acres, average pasture yields, and numbers of grazing animals in each grazing group.

    Terms Defined
    Animal Units: The sum of the weights of all animals in a group divided by 1000.

  • Real Organic Project Standards for Grown in the Ground

    1. Intent. Organic crops are grown in the soil, in the ground. Organic terrestrial plant production must be a soil-based system in which plant roots grow in healthy, living soil. Biological activity, essential for healthy crops, must be supported by sound soil stewardship. Soil management must maintain or improve soil organic matter content and must select and implement stewardship practices that maintain or improve the physical, chemical and biological condition of the soil and minimize soil erosion. Importantly, soil must provide the significant majority of nourishment for plants.

    2. Connection to Subsoil. Organic terrestrial crops must be produced in-the-soil in-the-ground with plant roots in living soil, or in living soil mixed or fertilized with materials and products allowed in organic production, in connection with the subsoil and bedrock. Aquatic plants, such as water cress which naturally grow in water, are excluded from this requirement. Mushrooms, which are not plants and therefore do not depend on minerals from soil, are excluded from this requirement.

    3. Hydroponics Prohibited. All forms of hydroponic crop production, which is a generic class of soil-less production whereby terrestrial plants are grown with their roots in a nutrient solution only or in an inert medium to which a nutrient solution is added, are prohibited. Aquatic plants are excluded from this prohibition.

    4. Containers Prohibited. Growing terrestrial plants to harvest in containers, bags, or similar vessels, in which the roots are not in connection with the soil, the subsoil and the bedrock is prohibited. Real Organic Project farms may harvest minor production from containers provided products harvested from containers are not labeled Real Organic Project, and do not represent more than 1% of total farm sales.

    5. Transplants Allowed. In order to facilitate traditional organic propagation and production methods, growing annual or perennial seedlings or transplants in container vessels for further transplanting into soil is permitted so long as: 1) all substrate materials used are allowed in NOP organic production, and 2) the transplant growth life cycle occurs where plant roots in living soil in connection with the subsoil and bedrock must provide the majority of nutrients, as measured from time of initial seeding/propagation to time of commercial crop harvest, and is measured by crop mass.

    5. Ornamentals and Herbs Sold in Containers. Ornamental plants and herbs may be grown and sold in the containers in which they grew. This will ensure that consumers understand how these plants were produced. All substrate materials used must be allowed in NOP organic production.

    6. Microgreens Production. Microgreens are a crop analogous to sprouts. Therefore, microgreens may be grown in container vessels provided that 1) no solid or liquid fertility is added to the container after the crop is planted, and 2) the microgreens must be harvested within 21 days after planting. Analogous to sprouts, the seed used in the production of all microgreens must be NOP Certified Organic.

    7. Greenhouses and/or high tunnels with insulation/barriers below in-ground growing spaces must meet the following criteria:
    a. In-ground crops grown in greenhouses and/or high tunnels with insulation/barriers below in-ground growing spaces will not be Real Organic Project certified. These crops must be labeled as “not real organic project certified” at the point of sale if that point of sale is controlled by the grower (i.e. a farm stand or farmers market booth)
    b. In-ground production takes place in a mix of primarily soil and compost. Largely inert media such as coconut coir is not allowed as a primary soil component
    c. Growing area has enough soil depth that plants can grow as they naturally would in unmodified outdoor soil environments
    d. Growing crops for harvest in greenhouses/high tunnels with insulation/barrier below in-ground growing areas is not the primary means of farm’s crop production”

    Clarification: Bedding plant production is allowed to be Real Organic Project certified when produced in the above facilities

    Temporary Exemptions. Farmers who have in the past grown NOP Certified Organic plants in container vessels not connected with the soil, subsoil and the bedrock, for three or more of the last five years, and require time to transition to in-the-ground production, upon submission of a written transition plan, which demonstrates substantial dedication to the transition process, as well as effective metrics for monitoring transition progress, may be granted approval in writing from the program administrator to a limited, one-time, revocable, conditional exemption from Section 1.4 for a period not to exceed 24 months from the date of initial publishing of these standards, so long as in the sole judgment of the program administrator, the aforementioned approved transition plan is being strictly adhered to.

  • Real Organic Project Standards for Soil Management

    The Real Organic Project standards for soil management are the EXACT NOP standards stated in section 205.203 of the NOP Regulatory Text, however the Real Organic Project standards honor the legal meaning of the word “must.”

    The producer must select and implement tillage and cultivation practices that maintain or improve the physical, chemical, and biological condition of soil and minimize soil erosion.
    The producer must manage crop nutrients and soil fertility through rotations, cover crops, and the application of plant and animal materials.

    The producer must manage plant and animal materials to maintain or improve soil organic matter content in a manner that does not contribute to contamination of crops, soil, or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances. Animal and plant materials include:

    1. Raw animal manure, which must be composted unless it is:Applied to land used for

    a. crop not intended for human consumption;
    Incorporated into the soil not less than 120 days prior to the harvest of a product whose edible portion has direct contact with the soil surface or soil particles; or

    b. Incorporated into the soil not less than 90 days prior to the harvest of a product whose edible portion does not have direct contact with the soil surface or soil particles;

    2. Composted plant and animal materials produced through a process that:

    a. Established an initial C:N ratio of between 25:1 and 40:1; and

    b. Maintained a temperature of between 131°F and 170°F for 3 days using an in-vessel or static aerated pile system; or

    c. Maintained a temperature of between 131°F and 170°F for 15 days using a windrow composting system, during which period, the materials must be turned a minimum of five times.

    NOTE: The NOP published a guidance document that is meant to help certifiers and producers interpret the manure composting guidelines presented above. Real Organic Project will inspect the compost standards as specified in the Appendix.

    3. Uncomposted plant materials.

    A producer may manage crop nutrients and soil fertility to maintain or improve soil organic matter content in a manner that does not contribute to contamination of crops, soil, or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances by applying:

    1. A crop nutrient or soil amendment included on the National List of synthetic substances allowed for use in organic crop production;

    2. A mined substance of low solubility;

    3. A mined substance of high solubility: Provided, That, the substance is used in compliance with the conditions established on the National List of nonsynthetic materials prohibited for crop production;

    4. Ash obtained from the burning of a plant or animal material, except as prohibited in paragraph (e) below: Provided, That, the material burned has not been treated or combined with a prohibited substance or the ash is not included on the National List of nonsynthetic substances prohibited for use in organic crop production; and

    5. A plant or animal material that has been chemically altered by a manufacturing process: Provided, That, the material is included on the National List of synthetic substances allowed for use in organic crop production established in §205.601.

    The producer must not use:

    1. Any fertilizer or composted plant and animal material that contains a synthetic substance not included on the National List of synthetic substances allowed for use in organic crop production;

    2. Sewage sludge (biosolids) as defined in 40 CFR part 503; and

    3. Burning as a means of disposal for crop residues produced on the operation: Except, That, burning may be used to suppress the spread of disease or to stimulate seed germination.

    Exceptions to Real Organic Project Soil Management Standards are limited to:

    1. Seed Sprouts and Microgreens
    2. Mushrooms
    3. Aquatic plants
    4. Seedlings and planting stock for transplanting

  • Real Organic Project Standards for Greenhouse Production

    Control of soil-borne pests and diseases. Soil health must be primarily maintained by the addition of biologically active compost and other organic materials, by the addition of rock powders, by good sanitation, and/or by practices such as crop rotation or other forms of plant diversity (such as intercropping and undersowing). Solarization and shallow steam treatment of the soil (to a maximum depth of 4 inches) are allowed. Deep steam treatment of the soil (to a depth of more than 4 inches) must only be allowed under exceptional circumstances (e.g. severe infestation with nematodes), which must be documented by the grower, and must require special permission from the program administrator. Steam sterilization of growing media is not allowed.

    Light. The provision of artificial light is allowed, if the normal daylight is insufficient for the normal growing of crops. It must only be allowed on dark, overcast days and for extending the daylight period, and only during autumn, winter and early spring. Artificial light is also allowed for the production of container plants such as seedling, herbs, and ornamentals under the same limitations as already described. Artificial light may also be used for photo-periodical induction of flowering. Seedlings may be grown using 100% artificial light. This exception only applies to plants being grown for on farm transplant or sale within the container they are being grown in.

    Exceptions to Soil Bound Production. Growing in substrates (containers) is accepted for seedlings and transplants, and for plants which are sold to the consumer together with the pot/container in which they grow (e.g. herbs in pots, ornamentals). Harvested organic vegetables or fruits must come from plants grown in the soil, and not from container or isolated substrate cultures. Microgreens may be produced in containers if there is no feeding of any kind to the container after seeding. Harvest must occur within 21 days of seeding. Seed for microgreens must be 100% organic.

    Energy use. If the greenhouse energy consumption exceeds 41,000 BTU per ft2 per year, an energy analysis is required and a plan for increased energy efficiency and/or greater use of renewable energy must be produced. The need for lighting and heating, the availability of different sources of energy and the state of the art of greenhouse production vary greatly between different regions. Depending on such regional conditions, different strategies may be necessary to achieve the goal of responsible energy use. We recognize that there is no single recipe for the most responsible use of energy. This task will therefore be difficult to achieve with a single regulation, as long as no scientifically based limit exists. But a process of continuous attention and improvement can lead the way to real change. The heating of greenhouses to assure frost protection to 40°F is allowed without limitation.

    Rotation. Crop production without a rotation in protected (greenhouse or tunnel) culture is allowed if the producer can:
    demonstrate that the system builds and maintains the health of the soil and crops;
    demonstrate that the system is not reliant upon routine use of (approved) pesticides for insect control. Pesticides are intended as a fallback strategy. Intensive growers must create a level of soil health and a rich biological community that allows production without the regular use of pesticides.

    The farm must produce a fertility management plan for the protected cropping system. The plan must demonstrate that the growing system maximizes the efficient use of nutrients and builds soil health and fertility.

  • Real Organic Project Standards for Animal Welfare

  • Real Organic Project Standards for Split Farms

    1. Prohibited Practices on Split Farms
    a. Farms operating confinement production of livestock (AFOs) are not eligible for Real Organic Project certification. Confinement production is defined as operations where, regardless of size of operation or species of animals, livestock are confined to indoor and/or outdoor environments where they cannot express their natural behavior for the majority of their life cycle. Real Organic Project Standards for Grazing of Ruminant Animals Part 4 may act as an exemption to this standard at the discretion of the program administrator.

    b. No hydroponic production

    c. No simultaneous parallel production of certified organic and non-certified organic productions within the following categories:

    • Vegetables and small fruit (including berries)
    • Microgreens
    • Tree fruit
    • Tree nuts
    • Tree sap/syrup
    • Hay and pasture
    • Grain and pulses
    • Fiber from the same species
    • Dairy from the same species
    • Eggs from the same species
    • Meat and byproducts from the same species

    2. Allowed Practices on Split Farms

    Statement of Intent: Real Organic Project’s long term goal is for farms to become 100% certified organic. We strongly encourage farmers to develop strategies to remove barriers towards 100% organic certification. The Split Farm Standards create a viable path to certification for diversified operations that choose to have certain portions of their farm certified organic while choosing not to certify other enterprises.

    a. Real Organic Project requires certified farms to earn at least 51% of their gross farm income (defined as income from raising crops or livestock) from certified organic products. The following must apply to all production on certified farms.

    • No systemic confinement of livestock
    • No use of preventative antibiotics in livestock
    • No hydroponic production
    • All ornamental/bedding plants are managed organically while on farm
    • No use of prohibited synthetic herbicides, pesticides, fertilizers in crop production or excluded methods as defined by the NOSB
    • No production practices that could reasonably present a risk to organic integrity

    b. Production from buffer strips required for organic certification does not count as parallel production.

    c. Production from transitional land does not count as parallel production according to Real Organic Project Standards.

    d. Exemptions are allowed for animals that are raised according to Real Organic Project standards but are not slaughtered in a USDA organic facility. Farms that sell more than 50% of gross income as “NOT CERTIFIED ORGANIC” due to meat sales coming from a non-organic slaughterhouse are still eligible for Real Organic Project certification for products that otherwise qualify. This exemption for non-organic slaughterhouses sunsets on April 1st, 2026.

    3. Transitional Organic
    a. Real Organic Project certification of transitional production will not be allowed. Farms with land, crops or livestock undergoing bona fide 3-year transition to certified organic will remain eligible for Real Organic Project certification of their NOP production as long as the transitional land is managed according to Real Organic Project standards as well. [For purposes of calculating the 49% exemption, sales of transitional products will be counted towards total farm revenue but will not count towards the 49% exemption.]

    b. Land must not be rotated in and out of organic certification. An individual plot of land may only be transitioned once into organic certification without approval of the Real Organic Project standards board.

    4. Non-certified production subject to point-of-sale disclaimer

    When non-NOP certified production is grown, raised or processed under the above exemptions, and offered for sale to the public using the Real Organic Project-certified farm name or logo on packaging or placards, packaging and placards must clearly identify the product as “NOT CERTIFIED ORGANIC.” Farms must require compliance with this provision by all resellers.

    The NOT CERTIFIED ORGANIC disclaimer must appear beside the farm name or brand on placards and on the primary display panel of packaging in such a manner that a potential purchaser will take notice of it. Fonts, font size, font color, sticker size, sticker color and other methods must be employed to achieve sufficient effect.

    5. Definition of a farm

    For the purposes of Real Organic Project certification a farm should be considered, in its entirety, to include ownership or management of all enterprises on all owned or leased properties. Distinct farm operations and/or enterprises that share a substantial portion of labor, land base, equipment and/or management will be considered to be under common ownership or management. Any farm involved in Hydroponic or CAFO production shall be barred from Real Organic Project certification. This definition of a farm does not apply to land trusts, formal farm incubator programs or nonprofits that provide land access to farmers as a core mission. The specific farm enterprise reviewed by Real Organic Certification would need to meet Real Organic Project standards, but other enterprises within the above listed entities would not.

  • Real Organic Project Standards for Hired Labor Protections

    These standards are intended to ensure that Real Organic Project certified farms are providing these labor protections provided by law. We support efforts to improve protections afforded to workers and farmers under the law. These standards are explicitly not intended to serve as fair labor standards.
    Real Organic Project’s labor protections standards only apply to hired labor. The following groups are not considered hired labor:

    -Immediate family members – parents, children, brothers, sisters and
    their children (unless they are on the official farm payroll).
    -Volunteers – crop mobs, school, club or church groups who work for a few
    hours or a day, CSA members who do working shares in exchange for food or
    reduction in share price.
    -Educational programs and tours including short term work stays such as
    WOOFing. Apprenticeship and Internships are not considered exempt from Real Organic Project hired labor standards and must be a bona fide educational program.
    -Apprenticeships/Internships must have at least one of the following: a written educational curriculum, an individualized learning agreement/contract, or be formally associated with a college or university program.”
    -Work trades or barter relationships with neighbors, relatives or friends.

    1.Documents
    a. All Real Organic Project farmers will be provided with a template for a work contract along with a 1 page workers rights document. As part of Real Organic Project’s certification, farms must agree to provide these documents to their employees on an annual basis.

    2.Hiring
    a. Hiring ads and practices do not discriminate against any state or federally protected groups.
    b. Employers must not receive any payment from employees or prospective employees for any cost associated with obtaining a job.
    c. Employers agree to disclose to Real Organic Project whether they use contract labor, and the name of the contract labor organization they use.

    3. Pay
    a. All employers must have a system that can reasonably provide employees with pay stubs for every pay period detailing hours, pay, taxes and employer deductions. Farms in their first 5 years of operation may provide this information in an alternative written format provided that employees can still clearly determine their pay, hours and deductions within a given pay period.

    4. Housing (If an employer provides housing to their employees) must
    a. Be a safe physical environment
    Have a natural source of light and a safe source of lighting
    b. Have a clean, private and cleanable space with a space for personal cleaning and access to a sanitary bathroom or latrine
    c. Have access to potable water
    d. All employee housing must be described accurately and in detail previous to employment. This must include a special emphasis on non-traditional housing

    5. Workplace
    a. All documents provided to farm workers (such as pay stubs, work contracts etc.) must be provided in the native language of the farm worker.
    b. Employees must have complete freedom of movement and association.
    c. Employees must have access to medical care, access to transportation, communications (phone/computer), and shopping for basic needs.
    d. Employers must not, under any circumstances, hold on to employee passports, immigration, or work documents.
    e. Employees are provided, at no cost
    -All tools, supplies, and equipment required to perform their assigned duties.
    -Appropriate safety equipment when exposed to levels of high noise, dust or dangerous chemicals, or are working with dangerous equipment.
    -Appropriate safety training by their employer on all potentially hazardous equipment and materials.

  • Real Organic Project Standards for Processed Products

    All certified Real Organic Project processed products must be NOP certified. A processed product made with at least 90% Real Organic Project certified ingredients, by weight or volume, can use the Real Organic Project logo. If a processor has less than 90% Real Organic Project ingredients, by weight or volume, they cannot use the Real Organic Project logo, but they can identify on the front panel specific Real Organic Project ingredients and/or percentage of ingredients that are Real Organic Project certified. Producers must be able to verify that no ingredients are sourced from CAFOs or hydroponic operations, as defined by Real Organic Project, in order to qualify for the above. An individual ingredient that is sourced from both Real Organic Project certified and non Real Organic Project certified sources cannot be labeled as a Real Organic Project ingredient. All processing of final products must take place on the Real Organic Project certified farm producing the key ingredient, with the exception of single-ingredient products.

    In instances where operations do not have access to an on farm processing facility they may use a commercial kitchen or certified organic processor. The program administrator, at their sole discretion, reserves the right to review off farm processing arrangements to ensure they have a low likelihood of creating product integrity issues. In instances where the processing arrangement is deemed to have a significant likelihood of product integrity issues the program administrator may, at their sole discretion, choose to deny certification to processed products that would otherwise qualify for Real Organic Project certification If the production exceeds Real Organic Project’s capacity as a program to inspect the program administrator may, at their sole discretion, chose to not certify a processed product.

  • Real Organic Project Standards for Farm Operations

    An operation whose Real Organic Project certification has been suspended or revoked, may appeal to the standards board for reinstatement after a minimum of 12 months. Certification will not be reinstated less than 36 months from any application of prohibited materials. No operation may apply for an appeal more than once for the same violation.

    Real Organic Project may, on occasion, need to protect the integrity of the program by rejecting certification for farms due to reasons unrelated to farming practices. At their sole discretion the program administrator may reject a farm for certification if:

    1. The farm is deemed, by the program administrator, to have violated Real Organic Project’s “Code of Conduct” which reads as follows: Real Organic Project seeks to promote fairness, inclusivity, and equity in our own work and at large in our role in the community. Real Organic Project celebrates and encourages ideological, political, and personal diversity amongst its participating farms and other partners. Physical and emotional safety of Real Organic Project staff, and the farmers and farm workers that we work with are of utmost importance to our organization. Accordingly, Real Organic Project expects respectful and kind treatment to be practiced by, towards, and among all participating farmers, donors, staff, partner organizations, and other stakeholders and supporters.

    Real Organic Project does not exclude from participation any person due to discrimination because of race, color, national origin, gender, religion, age, disability, political beliefs, sexual orientation, or marital or family status. Real Organic Project reserves the right to exclude individuals from our program(s) who engage in physical, psychological, verbal, or sexual harassment or other abuse of any kind towards Real Organic Project staff members, volunteers, contractors and partners. Real Organic Project does not condone or tolerate denigrating speech or behavior in any interaction with Real Organic Project staff, volunteers, contractors or partners.

    2. As an “add-on” certification Real Organic Project requires all of the farms it certifies to have a current NOP certification, or its equivalent in Canada and/or Mexico. All farms Real Organic Project certifies must have a current and substantive relationship with an NOP (or equivalent in Canada/Mexico) approved certifier. Real Organic Project recognizes there may be circumstances where farms may not have a certifier for a specific reason over a limited period of time (for example: when transitioning from a certifier that is closing to a new certifier). However, in circumstances where a farm has gone a significant period of time without a current and substantive relationship with a certifier (for example: while undertaking administrative action or appeals) the program administrator, at their sole discretion, may suspend or revoke that farm’s Real Organic Project certification.

  • Appendix

    NOP Guidance 5021 Compost and Vermicompost in Organic Crop Production
    1. Purpose
    This guidance provides clarification on allowed practices for composition, production, and use of compost and vermicompost in organic crop production.

    2. Scope
    This guidance applies to National Organic Program (NOP) certifying agents, all certified and exempt organic producers, and input suppliers.

    3. Background
    The NOP regulation 7 CFR 205.203(c), the soil fertility and crop nutrient management practice standard, sets forth the requirements for management and application of plant and animal materials. This section of the NOP regulations provides specific requirements for the use of compost and raw manure, but does not describe the full range of methods that may be used for compost production.

    A key provision of the NOP regulations regarding addition of organic matter is found at ¤ 205.203, which states: “The producer must manage plant and animal materials to maintain or improve soil organic matter content in a manner that does not contribute to contamination of crops, soil, or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances.” Section 205.203 further states that animal and plant materials include three types of materials: raw manure, composted plant and animal materials, and uncomposted plant materials. Raw manure is restricted in use, and compost containing animal materials must be produced under certain conditions.

    The designated types of systems do not include common methods of composting such as in piles (rather than windrows) or include any reference to vermicompost. The National Organic Standards Board (NOSB) convened two task forces that delivered comprehensive reports to the NOSB on compost (2002) and compost tea (2004). The NOSB then made a final recommendation on compost, compost tea, processed manure, and vermicompost in November 2006.

    The NOP concurs with the NOSB that the examples provided in ¤ 205.203(c)(1-3) is not a finite list of acceptable plant and animal materials for use in organic production. Site-specific variation in feedstock materials, management practices, and production requirements dictate that organic producers exercise flexibility in managing plant and animal materials on their operations. In July 2007, the NOP issued NOP 5006 – Processed Animal Manures. NOP 5006 clarifies the criteria for production of processed manure products that may be used without restriction in organic production.

    While the use of processed animal manures was clarified in NOP 5006, the use of vermicompost was not addressed in that guidance. Vermicompost is an alternative method for meeting the NOP compost requirements. Vermicomposts are organic matter of plant and/or animal origin, consisting mainly of finely-divided earthworm castings, produced non-thermophilically with bio-oxidation and stabilization of the organic material, due to interactions between aerobic microorganisms and earthworms, as the material passes through the earthworm gut. Feed stocks for vermicompost materials include organic matter of plant or animal origin, preferably thoroughly macerated and mixed before processing. Pathogenic organisms are eliminated in 7–60 days, depending on the technology used.

    Vermicomposting systems depend upon regular additions of thin layers of organic matter at 1–3 day intervals to maintain aerobic conditions and avoid temperature increases above 35°C (95°F) which will kill the earthworms. Methods of vermicomposting include outdoor windrows (usually managed for 6–12 months), angled wedge systems (usually managed for 2–4 months), indoor container systems (usually managed for 2–4 months) and continuous flow reactors (usually managed for 30–60 days). For outdoor windrows, one indicator that the process is complete is when the worms move out of the compost, which would typically take 6 months in warm conditions, or up to 12 months in colder climates. Earthworms fragment the organic wastes into finely-divided materials with a low C:N ratio and high microbial activity. Nitrogen is mostly found in the nitrate form, and potassium and phosphorus are in soluble forms. For most organic wastes, no traces of the raw materials are visible. Processing is maintained at 70–90% moisture content with temperatures maintained in the range of 18-30°C (65-86°F) for good productivity.

    4. Policy
    4.1 General

    Compost and vermicompost production practices should be described in the operation’s organic system plan (OSP). Certifying agents may allow the use of compost if they review the OSP and records and are assured that all requirements are met. Compost production records should include the type and source of all feedstock materials. When animal materials are used in compost production, the certified operation should maintain temperature monitoring logs, and document the practices used to achieve uniform elevated temperatures. Vermicompost production records should include the type and source of all feedstock materials. When animal materials are used to produce vermicompost, the certified operation should maintain a log of duration of vermicomposting with a description of the practices used to achieve aerobic conditions and maintain adequate moisture. Certifiers reviewing compost inputs produced by commercial operators should similarly review the production methods and source materials.

    Certified operations can also demonstrate compliance with the compost requirements by measuring temperature, time, moisture content, chemical composition, and biological activity. These measurements may include testing feedstock materials and compost for one or more characteristics including initial and final carbon to nitrogen ratios, stability (using ammonia/nitrate ratio, O2 demand, CO2 respiration rate, or other standard tests), pathogenic organisms, or contaminants.

    4.2 Compost

    Compost containing plant and animal materials is allowed in accordance with ¤ 205.203(c)(2). Other examples of acceptable composting methods include:

    1. Compost that is made from allowed feedstock materials (either nonsynthetic substances not prohibited at ¤ 205.602, or synthetics approved for use as plant or soil amendments), and

    2. The compost pile is mixed or managed to ensure that all of the feedstock heats to the minimum of 131°F (55°C) for a minimum of three days. The monitoring of the above parameters must be documented in the OSP in accordance with ¤ 205.203(c) and verified during the site visit.

    4.3 Vermicompost

    Vermicomposting is an acceptable method of composting when:

    1. It is made from allowed feedstock materials (either nonsynthetic substances not prohibited at ¤ 205.602, or synthetics approved for use as plant or soil amendments);

    2. Aerobic conditions are maintained by regular additions of layers of organic matter, turning, or employing forced air pipes such that moisture is maintained at 70–90%; and

    3. The duration of vermicomposting is sufficient to produce a finished product that does not contribute to contamination of crops, soil, or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances.

    4.4 Permitted Uses

    Composts containing animal materials that do not meet the requirements at 4.1 and vermicomposts containing animal materials that do not meet the requirements at 4.2 of this policy may be permitted subject to restrictions of ¤ 205.203(c)(1), similar to raw animal manure, provided all feedstocks are allowed materials (either nonsynthetic substances not prohibited at ¤ 205.602, or synthetics approved for use as plant or soil amendments).

    Compost and vermicompost made without animal materials as feedstock are not restricted in use, in accordance with the provision for uncomposted plant materials at ¤ 205.203(c)(3), provided all feedstocks are allowed materials (either nonsynthetic substances not prohibited at ¤ 205.602, or synthetics approved for use as plant or soil amendments).

    5. References NOP Regulations (as amended to date) 7 CFR ¤ 205.203 Soil fertility and crop nutrient management practice standard.
    (c) The producer must manage plant and animal materials to maintain or improve soil organic matter content in a manner that does not contribute to contamination of crops, soil, or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances. Animal and plant materials include:

    1. Raw animal manure, which must be composted unless it is…
    2. Composted plant and animal materials produced through a process that…
    3. Uncomposted plant materials.

    7 CFR ¤ 205.602 Nonsynthetic substances prohibited for use in organic crop production. NOSB Recommendations
    November 2006, Final NOSB Recommendation on Guidance: Use of Compost, Vermicompost, Processed Manure, and Compost Teas. NOP Program Handbook: Guidance and Instructions for Accredited Certifying Agents and Certified Operations NOP 5006: Processed Animal Manures. July 22, 2011.
    Approved on July 22, 2011