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Pundit’s Mailbag — CCOF Speaks Out
On ‘Spiked’ Organic Fertilizer

Our pieces, ‘ Spiked’ Organic Fertilizer Raises Consumer Doubts About Organic Definition, Pundit’s Mailbag — Organic Industry’s ‘Situational’ Standard and Pundit’s Mailbag — As ‘Spiked’ Organic Fertilizer Investigation Widens, Potential Grows For Weaker Consumer Confidence In All Fresh Produce, brought this response from California Certified Organic Farmers (CCOF):

Thank you for your recent coverage of the spiked organic fertilizer issue in California. Discussion is always healthy and helps keep the public fully informed. With this in mind, CCOF would like to comment on a number of the questions you ask and points you raise.

Firstly, with regard to CCOF you question:

“Is it really possible that executives at California Certified Organic Farmers are ‘shocked’ that a vendor would attempt to enhance his profits by misrepresenting his product?”

The answer is a simple ‘yes’. Despite recent growth, the organic sector remains a tight-knit community with the shared core belief in the benefits of organic farming and food in terms of sustainability, environmental impact and a healthy diet. When a member of this community betrays the trust of the rest of the community, we are “shocked”. It’s not the organic way. One might assume that, in any industry, bad players can be expected to enter the market when growth and profit opportunities present themselves, but this does not diminish the shock and dismay felt when it happens.

Secondly, we would like to refute the assertion that CCOF is not a consumer group. CCOF does not perceive itself as a producer group, advocating only for the organic farmer. CCOF’s mission is to certify, educate, advocate and promote organic both for the producer and consumer. We interpret this mission broadly. Our advocacy efforts are based on protecting the integrity of organic for both producers and consumers alike. Similarly, our outreach activities are as much about consumer education as they are about educating producers.

While we certify over 2,000 organic operations, we also have over 350 supporting members who include students, individuals and families who have joined CCOF in support of our mission and who believe in the important work we do to protect the integrity of organic and educate consumers on the benefits of eating organic. An overview of our current activities on the liquid fertilizer issue can be viewed at

Thirdly, we would like to clarify why CCOF took the decision to avoid recalls and the reclassification of land as transitional. CCOF is accredited by the USDA to certify organic, and ultimately report to the USDA. To suggest we made the decision based on fear of raising the risk of investing in organic agriculture shows a lack of understanding of organic farming practices. Organic agriculture is readily accepted as being a riskier business due to the very fact that organic producers work with nature and find ways to let nature to do its job more of the time rather than using the methods of conventional farming.

CCOF made a balanced decision based, firstly, on not penalizing the initial victim, in this case, the farmers who inadvertently used the fertilizers in question, and secondly, on not punishing the consumer. Organic farmers are the victims of the recent suspected fraudulent activities of two organic liquid fertilizer companies. CCOF did not believe it was in the interest of either the farmers and producers or the consumer to penalize the victim. Returning land to a transitional status would have resulted in the consumer becoming the victim too. You correctly state:

“…consumers want to eat not just organic today but that they want to see the range and availability of organics increase.” (Pundit Mailbag, February 6)

A reduction in the land in organic production would have led to a decreased supply and increased prices, neither of which is in the consumer interest. We believe that if you ask the organic consumer if they would want organic farmers, who had been the victims of fraud, to be put out of business, many would answer no. As you correctly surmise, “consumers would rather cut producers some slack under difficult situations”. (Pundit Mailbag, February 6)

We would also like to question your view of the organic consumer and the assumptions you make. You state:

“Our take is that when organic was a small community, it was reasonable to think that consumers deeply committed to organic would have thought it important to encourage the growth of the organic industry. Today, however, the typical organic consumer is some mom at Wal-Mart buying organic baby food or milk, and the mom has no connection to the “organic community.” (Pundit Mailbag, February 6)

The above reflects an elitist standpoint. Since when should eating organic only be the preserve of the few who can afford to pay higher prices? Why should the benefits of eating a healthier organic diet not be available to the mass market? Also, it is wrong to assume consumers are not well informed or connected to the organic community. Numerous magazine articles on the benefits of eating organic have resulted in an informed, well-educated organic consumer, including those who shop in supermarkets.

We would also like to counter your statement “….people are just being tricked because organic standards are too situational.” (Pundit Mailbag, February 6)

There has been no attempt to trick the consumer. Quite the opposite, the excellent work done by the media and journalists like yourself has meant that the consumer has been kept informed of what is happening and able to make their choices accordingly.

And last, but by no means least, we would also like to address the statement made by David Sasuga in his letter to the Pundit’s Mailbag:

“…the organic leadership and organic certifiers are not willing to do the right thing…” (Pundit Mailbag, February 19)

And to pick-up on your statement:

“CCOF needs to have an audit procedure for all organic inputs”

Over the past month, CCOF has implemented a number of steps to introduce increased regulation and oversight of the organic liquid fertilizer input industry. CCOF recently introduced a new organic liquid fertilizer policy,
(You correctly comment:

“It is good to see that Earthbound Farms is stepping up testing and experimenting with new techniques to identify non-organic fertilizers. However one suspects that smaller organic producers would have a lot of trouble with this regimen; they need a certification they can rely on, not a procedure they can do themselves.”

This is why CCOF also launched a fertilizer sampling initiative, (Similarly you say, “Perhaps the USDA needs to insist that all inputs not only be organic but be certified to be organic.” CCOF supports increased regulation of the organic input industry by the USDA and here in California by the California Department of Agriculture (CDFA). CCOF applauds the new notice from the National Organic Program (NOP), (
), which reflects the policy recently implemented by CCOF.

In conclusion, CCOF and others in the organic sector are fully aware that we depend on consumer confidence in organic and consumer trust in the USDA organic seal. In light of recent events, the organic sector has taken swift and decisive action to improve and enhance regulation of the organic liquid fertilizer industry to ensure that organic standards are not compromised in the future. We have taken immediate action to reassure consumers that they can continue to rely on organic certification, accredited certification agencies such as CCOF and can trust the USDA organic seal.

— Jane Baker
Director of Sales and Marketing
Santa Cruz, California

We certainly thank Ms. Baker and California Certified Organic Farmers for reading and for taking the time to keep the industry informed. Ms. Baker raises several key points:

1) We accept at face value the assertion that executives at CCOF were shocked at the notion that a vendor would cheat to enhance its profits. What can we say, except for the future we are reminded of the old adage: “Fool me once shame on you, fool me twice shame on me.”

Whatever expectations are in one’s heart, clearly the policy that should be followed should not rely on blind trust. Hopefully Ms. Baker and her fellow executives at CCOF will develop systems that presume there are bad apples in every bushel.

We suspect this has always been a problem but, clearly, as organic grows, it is safe to assume that many growers, retailers and vendors will get involved in organic not for love, but for money.

2) It is always interesting to see how people perceive themselves, but despite Ms. Baker’s fervent desire to “refute the… assertion that CCOF is not a consumer group,” clearly CCOF is not a consumer group. The Chairman of the Board works for Earthbound Farms, the Vice Chair works for Bolthouse, the board Secretary works for Alexandre Ecodairy Farms; there are five other directors on the board right now and all of them work for organic producers.

So the board is 100% made up of producers. That means it is a trade association.

Now this does not mean that the board members of CCOF don’t care about consumers; we assume they do. But the decisions are made by the trade and, inevitably, in the interests of the trade. To claim otherwise is disingenuous.

3) Sometimes the explanation of an act turns into a de facto confession. We have not the slightest doubt that CCOF made, as Ms. Baker points out, a “balanced decision” in deciding not to demand recalls and not to decertify land after the non-organic fertilizer was added to the land.

The question… the essence of the dispute… is whether a “balanced decision” should, in fact, be made at all, or if this is a case that requires an absolute decision.

We go back to the original analogy we made, which looked at how a kosher-certifying authority would view such a matter:

The other issue raised by this piece is the question of whether organic certification is not too protective of the industry and too dismissive of consumers.

We can agree with not “penalizing” growers who didn’t know they were being sold a synthetic chemical. In other words, they shouldn’t be fined or go to jail. On the other hand, if organic is to have meaning, consumers have to be able to rely on the certification to consistently mean something.

It is not really a question of evil intent or not; it is a question of consumer protection. If a kosher hot dog manufacturer in good faith orders kosher beef but a vendor delivers pork and it is put into hot dogs and shipped, that hot dog manufacturer has to recall the hot dogs as they are falsely labeled and then the entire plant has to be made kosher again through a process involving both cleaning and rabbinic authorization.

This is not to punish the hot dog manufacturer but to protect consumers who wish to pay for kosher food.

Why would organic consumers merit any lesser protection?

Put another way, a kosher-certifying authority is not permitted to make a “balanced decision.” It is not permitted to consider the long term interests of consumers in cheaper kosher food or more available kosher food.

Its purpose is to certify if the food in question is kosher or not.

CCOF seems to be arguing that when consumers see the USDA Certified Organic logo, they are looking to support organic agriculture — as opposed to gaining an assurance that they are consuming organic food. We think this is an argument that is very hard to sustain.

4) An “elitist standpoint” — us? — sacre bleu! Actually we in no way said or implied that eating organic should be the preserve of any demographic group. Nor did we “assume” anything about consumers and their knowledge of things organic. What we did say, and stand by, is that the organic consumer is changing. When people used to go out of their way to a special store to buy organic, you got a much more committed consumer. Perhaps in those days it was logical to assume that these consumers felt a special desire to help build the organic movement. Today, a mother who confronts two brands of baby food in a store and elects the organic baby food is willing to pay a premium to get her baby organic food. She may or may not want to support organic agriculture, but she definitely wants organic baby food.

If as an industry we knowingly allow her to buy baby food that does not meet organic criteria, aren’t we defrauding her?

5) We are pleased that CCOF is taking steps to improve oversight of the organic liquid fertilizer industry. We think, in general, that all inputs need to be third-party verified as to their suitability for use in organic production. We doubt that the liquid-fertilizer producers are uniquely malicious, so we suspect there are many other input problems all across the country.


We suspect that as the organic industry grows, there will be a separation between those who promote organic agriculture and those who certify product as organic. There is a conflict of interest between these two functions. Interestingly enough, this is why food safety advocates do not approve of the USDA being responsible for food safety in any sector. They feel this regulatory role conflicts with USDA’s role as a promoter of American agriculture.

We thank Jane Baker and the CCOF for sharing their views. Only through such dialog can the industry grow and prosper.

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