Over the last 2 months Seb and I have agonized over a particularly tough decision. Our commitment to ecology, soil improvement, and nutrient dense food production is at the core of why we became farmers. This year, our involvement in the bureaucratic effort that is Organic Certification became stressful, disheartening, and complex. We want to take a moment to tell you a bit of our experience and the learning that we did about the organic industry. We hope to enlighten and to inspire you to support the growth of the organic industry in the most impacting ways possible.
Since we bought our farm in 2014 we have sought organic certification, which means we have followed a strict set of guidelines that are made by the Canadian Organic Regime, and overseen by the CFIA. The standards are in place (in theory) so that all certified organic growers are following the same best practices and that consumers looking to buy organic products have a third-party validation that these products meet the standard. The previous owner of our farm, the legendary John Sutherland, operated as Certified Organic. In the context of taking over his business we felt it would be a good idea to be certified in order to create continuity while transitioning into the business. Being certified also helps with transparency in our less-direct client relationships (such as a sale of a bag of our greens in a retail store.) Prior to owning this farm, when we were running our farm business on rented land, we never chose to go through the rigours of being certified. At that time, it didn’t seem necessary, and the extra paperwork and cost was prohibitive. We also felt (and feel) that our direct-to-consumer relationships offer us a way to tell the whole story of our ecological growing practices and our values to those we grow for.
To be certified organic requires that you submit all of our growing plan in the winter, the plans are reviewed and checked over, you log everything you do, then you are inspected and must ensure that everything you are doing is in accordance with the National Organic Standard. There is a strict protocol of standards that dictate everything from how we purchase supplies, plant, harvest, wash, process, and store our vegetables. Provided there is nothing to correct based on the inspection, you are given a certificate at the end of the year after paying your fees.
In the 3 years of being certified we’ve learned first-hand the challenges for small farms like ours to be Certified Organic. Previously a small farmer could ask their inspector questions if they needed help interpreting the standards, or for advice on how to implement something in a practical sense. If a new rule about composting were to come into place, for example, a farmer could ask how this would typically be carried out. Rules have changed and now inspectors and certifiers are no longer allowed to offer advice, and individual farms, whether big or small, are expected to be experts on the standards. For large farms they navigate this by having staff members or consultants who specifically make sure that everything they do is in accordance with the standards. Small farms usually do not have the resources to do anything other than interpret the standards themselves. The Organic Council of Ontario (the only trade organization working and advocating on behalf of the Ontario Organic industry) recognizes this short-coming, and is currently working on surveying and coming up with ideas for moving the industry forward in a way that supports all sizes of farms. Meanwhile, another major problem is in the implementation of the standards; standards are not always applied equally to farms. Where our certifier might ask us for documentation on a given tool, another certifier may over-look this. This means that seeking advice from peers can lead to problems.
And this is exactly the problem we found ourselves caught in this past season. Unfortunately this lack of support and inequality in the application of the standards made something that should have been a small problem on our farm morph into a catastrophe for our business. Our issue relates to a variety of lettuce called Salanova. It is grown as a head lettuce and the leaves stay small so it has the more complex flavour of a head lettuce, but can be cut from the stem and separated into baby leaves for baby salad mixes. It recently became very popular in organic growing, and other certified and non-certified ecological farmers we know recommended using it. Not only does it have great flavour, it also helps us speed up the very tedious and slow process of greens harvesting. Once we started growing it, we were hooked! The seed comes covered in a clay coating to make the planting easier (lettuce seeds are tiny). While the seed is allowed under USDA National Organic Program standards, the pellet has not officially been approved for use in Canada. We weren’t aware of this, and thus made a mistake. Essentially the company that does the pelleting has only disclosed their ingredients to the American regulators so it was listed as organic on the website, but has not yet been formally approved by any Canadian-based certification body (though many certified organic peers advocate for it and use it).
In May, 2 months after we had already planted the lettuce in our greenhouse and fields, our certifier asked us for a list of ingredients in the pellet. We attempted to acquire the ingredients, and the seed company informed us that the issue of this particular seed pellet was a controversial one. They were trying hard to get their pelleting company to officially release the ingredients to Canada (which involves some sort of bureacratic rigamarole). So we put our certifier directly in touch with the seed company and our certifier promised to stay in touch about the issue. We were baffled by the fact that none of our peers also growing this lettuce under organic certification were being asked for the pellet ingredients, and it seemed to us that our certifier was being particularly strict. We needed to focus our efforts on managing the very real drought in the field, so we put the issue on the back-burner for a couple months. In the fall we followed up with our Organic Certifier and asked what needed to happen to finish our 2016 certification. Because they had not received ingredients of the pellet from the seed company, we were issued a “non-compliance.”
What does this mean?
We didn’t know what a non-compliance was, but we learned quickly that it’s a very serious thing. For us it means that everywhere we have grown this lettuce (and 8 meters surrounding) is “contaminated” according to the Organic standards. The land will not be certifiable for 3 years. This means our whole greenhouse, 1 of our 3 hoop houses (high tunnels), and about 3/4 of an acre of field space. We are allowed to grow crops on this land, but they will not be certifiable. Additionally, any crops grown in these “contaminated areas” cannot look similar to ones grown in other areas because they need to be clear what is certifiable and what is not. This was a big deal for us.
We’ve given a lot of time and energy to understanding Organic Certification, and this much loss for what we feel was a small mistake was heart-breaking to us. Initially our approach was to try to seek lesser repercussions for our mistake. Our ecological farming peers, some certified and some not, had much to say on the issue. Some farmers are worried because they also grow Salanova and if their certifiers were to issue a non-compliance to them it would be equally challenging to navigate. Some farmers advised us to take legal action because our certifier didn’t notify us of an issue until after a lot of damage was done; we had sent our seed search documents in March. Legal action or appealing the decision proved to be beyond our means. One farmer advised we should take the pellet to the university of Guelph and get it tested ourselves to prove it is clay, but we had no proof that our certifiers would approve it; they indicated needing the information from the pelleting company itself. We sought written proof from other certifiers that have allowed Salanova, but they were not able to give it because they know that it is a controversial issue and it would bring to light the inconsistencies in applying the standards. We considered changing certifiers but were advised that the issue would stick with us and to sort it out before doing so. We gave our 2 cents to those at the head office of Pro-Cert, our Certifier, and given feedback to the Organic Federation of Canada.
We were at a loss for what to do next. So we decided to turn to our clients. We’ve grown a lot from our 10 member CSA is 2012, but we’ve always made a point of staying connected closely with our clients. Generally when we need help on our farm, we tell our story. So we told our story and asked for feedback. We were honest and expressed that being Certified Organic both helps and hinders our ability to do what we set out to do on our farm- grow great food using the best ecological methods to feed our community. We told our clients that because of how much time and stress went into the certification process that we would prefer to forgo the process of certifying while still maintaining our high standards of quality and regard for ecology IF they would continue to buy from us.
1. In the future, you would continue to purchase from us even if we were not certified organic?
2. If we do continue with the certification, in the following 3 years while we re-transition many areas of our farm back to certified Organic with our certifier, will you be willing/able to purchase from us even if we won’t have all of our crops listed as Certified Organic.
The response was resounding. “Yes we will continue to support you whichever route you decide to go”. Over 70 emails, texts, or calls from clients (CSA, restaurant, retail) indicating that this wouldn’t effect their businesses or families. Their support would not change based on our decision of Organic Certification. Some advised that we continue because they thought it would be beneficial for our business, or because they first connected with us because we had been certified. Most felt they would rather see us focused on growing the delicious and sustainable food we always have rather than stress about this issue.
So we have made our decision. As farmers who advocate and practice being mindful of the amount of mental and physical stress we put ourselves through to run our business, we simply couldn’t deny the negative impacts this was having on both of us. It took over our lives at times, and answers were not easily found. We felt alone, until we reached out and asked for client feedback. Based on the positive feedback from our customers and the lack of support we have found in applying the standards and navigating a non-compliance, we have decided to forfeit our Organic Certification. This has many impacts for us, which would take a whole other blog post to express. A shift in identity is never easy. Becoming re-certified in the future is a possibility if we see the support networks strengthen for small farmers. There’s lots more to say on a personal level, but for now we are eager to share our story, and to return to preparing for the coming growing season with this decision made.
Here are few final other thoughts:
Our decision and our story should not, we hope, cause you to stop supporting the organic industry. Roadblocks like this threaten the organic system by making certification less accessible for small farmers. More organic-specific funding is needed, so that the industry can provide services to fill the service gaps that we have fallen into, and advise changes needed to reduce the burden on small farmers. We’ve talked extensively about these issues with the folks at The Organic Council of Ontario and these are things we agree would improve the current situation:
- More education and subsidized/free services to help farmers and businesses navigate the standards (like a help line, mandatory workshops and other resources)
- A clear way to log complaints
- Faster processing of compliance questions
- An actual mechanism for monitoring Certifying Bodies’ activities and ensuring that they are not overcharging, properly communicating, etc.
- Also, a way to support farms in funding and undergoing an appeal process.
- More subsidies for certification and streamlined paperwork (such as online forms that pre-populate from previous years).
The industry will hopefully shift in these directions. Ecological farmers need to be valued for accounting for externalities that conventional agriculture does not. We need to be supported with relevant programming and funding.
Until these shifts occur we want to thank all of the people who offered us encouragement as we sought direction during a difficult time for our farm. Thanks to the CSA members who felt the overwhelm with us, for the restaurant who offered to buy extra produce to cover any losses from this decision, for the farmer friend who called from across the country to commiserate about bureaucratic ridiculousness, for the friends who tolerated our grumpiness when we couldn’t see a feasible way forward. And for many more, thank you for your support in this part of our evolution.
Bethany and Seb
ps. For now we’ve decided to keep our farm name because we don’t have the capacity to rebrand, but we acknowledge that calling ourselves organic but not certified can create confusion in the marketplace. We apologize for contributing to this as we understand it is not ideal, and we promise to continue to educate and inform our eaters about our farming practices with full transparency. Should the regulations change in Ontario, and the use of the word organic become regulated, we will have to change our name. Read more here on provincial regulations and stay tuned!