National Organic Program Issues “No Confidence” Rating On Two Fertilizer Products

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.

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“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.

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Avatar for Anonymous Anonymous says:

This could be devastating to small organic manufacturers! Our building (12,000sq.ft.) + property (3000sq.ft.) is only 15,000sq.ft.

This is a excerpt of my letter to the USDA:

“Your recent letter dated on February 20, 2009 has basically shut down all small facilities that manufacture both organic and conventional products.

Let’s take a look at the 100 yard rule for Oct implementation. That’s 300 ft.. Let’s take a look at the mathematics of the declaration. Most buildings are a rectangular shape and for a building to have the inorganic material 300 ft from organic material signifies that plant must be using the diagonal of a triangle, minimum 200ft X 225 ft or about 45,000 sq ft. building in our case. I haven’t done the math, but logic dictates that 40- 50,000 sq ft is around the minimum that a building/area must be to comply with the rule. I can brush up on my calculus and send you a mathematical proof if necessary , but one can see what the declaration means to the small manufacturer and AGAIN benefits the larger corporate producers that got caught cheating!

I implore the USDA/NOP to review their requirement for the 100 yd rule. My suggestion and what we are willing to do is move the inorganic nitrogen bearing material to an outside storage container and bring the exact amount required for our conventional formulations in for production. That means we can weigh our material outside, bring in the exact amounts and add directly to our tanks using our current SOP and protocols to avoid cross contamination.

There must be other options available for smaller producers that are the backbone/ innovation of the industry and strive to maintain compliance. We should NOT be penalized because the big guys got caught with their “hands in the cookie jar”.

Please review the 100 yd. requirement our survival and many others depend on it!

Regards,

George Kanellos, Agrowchem Inc.”

Avatar for Anonymous Anonymous says:

“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” – so dedicated equipment is required? You can’t use the same equipment with an approved purge? This is more restrictive than the food processing requirements and overly burdensome.

I have a small fertilizer company that produces both organic and non organic fertilizers. I wouldn’t have been able to start up if restricted to just organic fertilizers. Maybe now I can drop the non organic lines but it will mean less business to spread all of my costs over increasing the costs to the organic producers.

Its a bad rule and punishes the honest people.

Avatar for Anonymous Anonymous says:

This could be devastating to small organic manufacturers! Our building (12,000sq.ft.) + property (3000sq.ft.) is only 15,000sq.ft.

This is a excerpt of my letter to the USDA:

“Your recent letter dated on February 20, 2009 has basically shut down all small facilities that manufacture both organic and conventional products.

Let’s take a look at the 100 yard rule for Oct implementation. That’s 300 ft.. Let’s take a look at the mathematics of the declaration. Most buildings are a rectangular shape and for a building to have the inorganic material 300 ft from organic material signifies that plant must be using the diagonal of a triangle, minimum 200ft X 225 ft or about 45,000 sq ft. building in our case. I haven’t done the math, but logic dictates that 40- 50,000 sq ft is around the minimum that a building/area must be to comply with the rule. I can brush up on my calculus and send you a mathematical proof if necessary , but one can see what the declaration means to the small manufacturer and AGAIN benefits the larger corporate producers that got caught cheating!

I implore the USDA/NOP to review their requirement for the 100 yd rule. My suggestion and what we are willing to do is move the inorganic nitrogen bearing material to an outside storage container and bring the exact amount required for our conventional formulations in for production. That means we can weigh our material outside, bring in the exact amounts and add directly to our tanks using our current SOP and protocols to avoid cross contamination.

There must be other options available for smaller producers that are the backbone/ innovation of the industry and strive to maintain compliance. We should NOT be penalized because the big guys got caught with their “hands in the cookie jar”.

Please review the 100 yd. requirement our survival and many others depend on it!

Regards,

George Kanellos, Agrowchem Inc.”

Avatar for Anonymous Anonymous says:

“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” – so dedicated equipment is required? You can’t use the same equipment with an approved purge? This is more restrictive than the food processing requirements and overly burdensome.

I have a small fertilizer company that produces both organic and non organic fertilizers. I wouldn’t have been able to start up if restricted to just organic fertilizers. Maybe now I can drop the non organic lines but it will mean less business to spread all of my costs over increasing the costs to the organic producers.

Its a bad rule and punishes the honest people.