National Organic Program Issues “No Confidence” Rating On Two Fertilizer Products
February 23, 2009 The National Organic Program (NOP) is no longer confident that Marizyme and Agrolizer liquid fertilizers comply with NOP regulations, according to a letter issued by USDA Feb. 20.
“Your clients should be aware that continued use of Marizyme and Agrolizer, and products made from these materials, puts their operations at considerable risk. You are advised to notify your clients of this immediately,” USDA wrote in the letter, which is addressed to all USDA certifying agents.
The products were manufactured by Port Organic, Ltd., which is currently being investigated by the USDA Office of Inspector General. Port Organic, Ltd. is not operating at the present time.
In response to the situation, USDA issued a series of steps that must be completed before products can be approved by NOP:
• By October 1, 2009, approval of all high nitrogen liquid fertilizers (nitrogen analysis greater than 3%) must be accompanied by documentation that demonstrates their compliance with the NOP regulations, based upon a third party inspection that meets the criteria below. If such documentation is not provided, all certifying agents (ACAs) must immediately rescind approval for the use of these materials by certified organic operations.
• By October 1, 2009, NOP will require all third party reviewers to implement a system of audit and inspection for branded products they deem compliant with the NOP regulations as a condition of recognition as a third party reviewer by the NOP. Inspections must include but not be limited to high risk inputs such as liquid fertilizers and other inputs where synthetic substitutes are readily available and have the potential to be concealed.
• NOP will also require all third party reviewers to undergo audits by NOP as a condition of ongoing recognition as a third party reviewer for materials by the NOP.
• NOP will focus increased scrutiny on how inputs are approved for use by certified organic operations during accreditation audits of ACAs conducted beginning in 2009, beginning with an emphasis on liquid nitrogen fertilizers.
In order for their products to be approved, fertilizer manufacturers must show the following documentation from a third party evaluation:
• No evidence of fraud in formulation, including verifying the presence of all necessary infrastructure to produce the approved finished product. This includes: dry and liquid storage, all necessary conveyance (forklifts, trucks, piping, etc), finished product storage, and both the ingredient and finished product transportation infrastructure.
• Verification of no synthetic nitrogen equipment, tanks, or supplies within 100 yards of the facility that produces the organic approved inputs at any time of the year.
• Verification that a successful audit was conducted comparing incoming materials with outgoing finished products and complete, detailed explanations for any deviations.
USDA also reiterated the responsibility assigned to growers under the NOP soil fertility and crop nutrient management practice standard:
• Producers must select and implement practices to maintain and improve the condition of soil and minimize soil erosion.
• Further, producers must manage crop nutrients and soil fertility through rotations, cover crops, and the application of plant and animal materials.
• Finally, producers must manage plant and animal materials to maintain or improve soil organic matter content. The management of plant and animal materials must be done in a manner that does not contribute to contamination of crops, soil, or water.