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Jeff Moyer


Letter on the 2010 NOSB Recommendation to NOP – 

Historical Process Based on Memory


Jeff Moyer, NOSB member 2006-2011, Past Board Chair, Vice Chair, Crops Committee Member, Livestock Committee Member




The first point has to do with the “input for input” substitution model for organic production. That is we simply look for approved non-synthetic materials to replace non-allowable synthetic materials as the primary tool for crop production. This feeds into the “feed the crop not the soil” model as opposed to the “feed the soil not the crop” model which is more in line with traditional organic production strategies.

  • The second point and larger issue with this thought process is that at the very core of organic production, as initially described by the founder of the US organic movement, J.I.Rodale, is that our goal as farmers/growers/ranchers is to improve the health of people, and that the health of a population is intrinsically linked to the health of the soil. So, what this means in terms of hydroponics is that; while we may be able to scientifically put into a container the essential ingredients we need to grow a head of lettuce for 30 days, we cannot determine what to put into a container to sustain a person for 90 years. If it isn’t in the soil, it isn’t in the food and it isn’t in us. This input for input substitution model will ultimately lead us to an unhealthy conclusion. Eating only hydroponically produced food over the course of a lifetime would lead to serious deficiencies of minor materials only found in complex soils.

  • The third point is that while OFPA does not mention hydroponics or soilless production, it does specifically discuss the need for a soil fertility building program based on organic matter improvement. The assumption from consumers is that there is an environmental component to organic production whereby the soil health is being improved, natural resources are being protected and that their food is produced on a farm in soil.


In conclusion; terrestrial food crops grown to maturity, should be produced in soil, not containers where soil is absent. Certain practices have already been excluded from organic production based on the concept that they don’t fit within the design paradigm of what organic means. Hydroponic production, or soilless production of terrestrial crops, should be included as a prohibited practice and not be allowed under organic certification.

For clarification, by “produced in soil”, I am referring to the European interpretation of soil-grown, meaning “soil we can walk on,” not containers with soil added to other materials. This standard is intended for terrestrial plants. The Canadian standard permitting production in containers leaves the door open to difficulties with the certifier trying to verify a nebulous standard. I’m in favor of drawing a clear line that is easily verified, and meets the consumers’ idea that healthy soil is the only direct link to human health. Soil is the key, not manufactured soil in a container. The crops committee of the NOSB felt that the recommendation was clear, and that the language voted on (after a great deal of discussion in committee and by the full board) reflected the opinion and science of the members. As with any recommendation document the program can find interpretation issues with language if it wants to. I stand by what we wrote then and believe it works. If some language needs to be tightened up then we should do that. But, to say the recommendation was too open ended is not correct.



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