Making “black and white” out of a “shades of gray” world
October 25, 2012
I had the opportunity to attend the National Organic Standards Board (NOSB) meeting for a day last week. The day was devoted to the Crops Subcommittee which is charged with looking at all the production inputs to be allowed or prohibited in organic agriculture. This is a daunting job, and board members (who are volunteers) must review volumes of information on numerous materials for each meeting. Most members do not have a technical background related to the material or topic they are voting on, so they rely on prepared documents, testimony, their own investigation, and discussions among board members. They are each trying to do their own “sustainability” analysis in the context of the organic rule (and enabling legislation) as well as the stakeholders they represent.
To me, this often involves turning “gray” (which is how I consider much of the natural world, existing as a continuum of properties) into the “black and white” needed for a regulation like the organic standard. The board does thoroughly examine the available “facts” about a material as well as its use and importance for organic growers, and the various public comments that are submitted.
A good example was the discussion on biodegradable mulch materials. These have become commercially available in recent years and are being used by more growers as an alternative to black polyethylene plastic, which has to be removed from the field and often goes to the landfill. WSU is the lead on a specialty crops grant project evaluating biodegradable mulch, and results from that project as well as previous work that was funded by WSU CSANR were used during the NOSB deliberations. Growers use black plastic to help warm soils earlier and to provide weed control. The organic rule specifically allows for the use of this material (which is made from non-renewable resources and is generally not recyclable due to contamination with soil) as long as it is removed from the field at the end of the season in annual crops. Biodegradable plastics can be made from renewable materials (generally plant starches) or from petroleum, they generally contain a synthetic additive for polymerization, and they degrade to carbon, hydrogen, and oxygen in the soil, thereby eliminating the labor cost and waste stream from removal of the polyethylene plastic.
At first look, the biodegradable materials appear to provide a step forward for sustainability. But since they are a synthetic material, they have to go through the rigorous evaluation for suitability in organic agriculture despite the initial assessment that they look like a better choice than what is currently allowed. Had they existed when the initial rule was passed, one can speculate that they would have been included and polyethylene plastic might not have been. The NOSB did vote 12-3 in favor of adding biodegradable mulch to the National List and it will be allowed in the future once the rule-making is done.
Not everyone agreed with the decision – why add another plastic when maybe plastics (synthetics) should not be allowed at all? To me, the decision to add biodegradable mulch represents a step to move organic agriculture a little further towards the goal of sustainability – maintain economic and weed control benefits of plastic mulches while reducing their environmental footprint (perhaps a life cycle assessment should be conducted to see how they stack up). And it represents the viability of the NOSB review process to interface with a changing world. While the organic rule is a standard (“black and white”), it is a living document that evolves along with the world around it.