I am a fertilizer official for the Oregon Department of Agriculture. Fertilizer products must be registered with our program prior to sale in Oregon, and nearly every other state. Our registration process includes approving labels and labeling–which includes all statements made about the product by the manufacturer. We also inspect retail and wholesale establishments to ensure products are registered, and sample products for laboratory analysis. Oregon also requires a heavy metals analysis for arsenic, cadmium, mercury, lead, and nickel for every product registered for sale. Only the three Pacific states regularly require heavy metal analyses.

I read your Feb. 2010 post on the SafeLawns.org titled, “Beware the Phrase ‘Organic-Based’”. Your observation that there is a lot of confusion regarding the use of the term organic on ag, lawn, garden, and horticultural products is certainly true. I appreciate your effort at explaining the nuances of how some of these terms are used, but your description does not accurately describe the use of these terms, at least in Oregon. Focusing on Oregon might seem parochial, but if a company wishes to sell a product in Oregon, and use the same label anywhere else in the country, they must comply with our definitions. For product registration we use the following definitions:

Organic. Organic ingredients were once part of living organisms, have an organic carbon base, are 100% natural, and are allowed in organic production. An example would be kelp to which nothing has been added.

Natural. Natural ingredients are allowed in organic production, are 100% natural (i.e. exists in nature) and may be altered from their original structure only by physical manipulation (e.g. ground, or screened), but do not have an organic carbon base. Examples would be mined limestone and sulfate of potash, to which nothing has been added.

Organic-based. A mixed product in which more than half of the materials are organic. If it is an organic-based fertilizer, more than half of the sum of the guaranteed primary nutrient percentages must be derived from organic materials. If it is an organic-based agricultural mineral, more than half of the sum of the guaranteed nutrient percentages must be derived from organic materials.

Natural-based. A mixed product in which more than half of the materials are natural. If it is a natural-based fertilizer, more than half of the sum of the guaranteed primary nutrient percentages must be derived from organic materials. If it is a natural-based agricultural mineral, more than half of the sum of the guaranteed nutrient percentages must be derived from organic materials.

Natural and Organic. Products containing both natural and organic ingredients may be listed as “natural and organic.” Product labels may list the proportions of these materials, i.e., “95% organic.” As an example a product made of 30% blood meal, 20% bone meal, 20% kelp meal, and 30% greensand could be described as “70% organic.”

Organic Input. A product whose ingredients comply with the requirements of the National Organic Program (NOP) Final Rule as specified in 7 CFR Part 205.

Allowed in organic production. This phrase is used to describe an input that complies with the requirements of the National Organic Program (NOP) Final Rule as specified in 7 CFR Part 205. Such ingredients may be used in organic production under certain circumstances, but may not be natural or organic. This definition also applies to other acceptable phrases used as descriptors which include, but are not limited to, “suitable for organic farming”, “acceptable for use in organic production”, “meets National Organic Program requirements for organic production,” “meets USDA standards for organic production,” or “suitable for organic gardening.” Product labels and labeling may not include any seal, logo, or similar device that would lead the consumer to believe the product has been approved for organic production under NOP.

Approved for Organic Production. An organic input that is approved by a USDA Accredited Certifying Agent as meeting the requirements of the National Organic Program (NOP) Final Rule as specified in 7 CFR Part 205. Only approved organic inputs may use the logos issued by certifying agencies, state programs, or other recognized organic input listing services.

You’ll note, for example, that compliance with NOP, such as an OMRI listing, is not enough to term a product as organic. NOP allows a number of synthetic materials, our definitions of “organic” and “natural” do not.

I’d also like to thank you for reminding consumers that “organic” is not necessarily synonymous with safe. I’d also like to suggest that, contrary to the claims of some, organic fertilizers can be overapplied and misapplied. Most organic materials contain some amount of water soluble nutrients. When applied at a rate greater than the plants and soil can contain, water percolating through the material can carry excess nutrients to streams and other bodies of water. As I tried to explain to some folks washing their hair in a small high mountain lake, your shampoo may be organic and biodegradable, but that doesn’t mean it doesn’t have an impact or belongs in the lake.

Cordially,
Don Wolf
Fertilizer Program Specialist
Oregon Department of Agriculture

For more information visit our website:
oregon.gov/ODA/PEST/fertilizer.shtml