What constitutes an organic farm is now generally agreed upon by practitioners in the international organic community. This is largely due to the fact that organic farmers and philosophers, going all the way back to Sir Albert Howard, Rudolph Steiner, J.I. Rodale, and Mokichi Okada, have generally accepted a common philosophy of organic agriculture.

While there are still arguments over the extent to which "input substitution" should be allowed in an organic system, there is overall agreement that an organic farm is a holistic, agroecological unit, functioning as a self regulating, natural organism that recycles nutrients and keeps pests in check. There is a general recognition that introducing "silver bullet" inputs to insure fertility or pest control can, at best, provide short term relief while exacerbating the long term problem.

Unfortunately, the organic industry has not yet developed a comparable understanding of "organic" processing. The absence of such a philosophy has led to considerable disagreement and debate. The purpose of this essay is to begin the process of crafting such a philosophy.

Much of the debate has centered on the use of synthetics in processed foods. The federal Organic Foods Production Act of 1990, which outlines the framework for the national definition of organic production and handling in the USA, states that no certified organic "handling operation" may "add any synthetic ingredient during the processing of any post harvest handling of the product." [6510 (a) (1)]. The National Organic Standards Board, on the other hand, specifically allowed synthetic ingredients to be used in 5% of certified organic processed food so long as the synthetic ingredient was listed as an "allowed synthetic" on the National List. (Recommendation adopted October 31, 1995, Austin, Texas).

However, because the legal prohibition on synthetics was emphasized by the law's lack of criteria for deciding "which" synthetics to allow, the National Organic Standards Board was reduced to permitting synthetics based solely on their "essentiality" for the manufacture of the intended product.

During the public comment period on the USDA proposed rule, consumers made clear their expectation that synthetics would not be allowed in food labeled "certified organic." When the National Organic Standards Board revisited the issue at their February 9-11, 1999 meeting in Washington D.C. the Board, in a deeply divided vote, refused to reconsider its previous position of allowing synthetics in processed foods labeled "organic."

Back to Basics

Understanding the philosophical basis for any disagreement requires a return to fundamentals. Arriving at a common understanding of organic processing requires that we return to the fundamental meaning of "organic."

From its inception, the term "organic" was used to describe a particular way of farming. The term "organic" is rooted in the notion of agriculture as a natural system. What Howard, Rodale, Okada and others proposed was that farming was part and parcel of nature's eco-system. In their view a farm was an organism, not a factory. The best farming, therefore, was farming that mirrored the natural ecosystem in which the farm was located. The word "organic" was used to describe this type of farming. The word organic, in this usage, literally means "parts integrated into a whole"--into an organism. Okada preferred the term "nature farming" to describe such a farming system. But the kind of farming he had in mind was identical to that described by Howard, Rodale and others who used the term "organic."

Accordingly, the word "organic" is an adjective describing a method of farming that uses natural, whole systems designs. Organic farmers recognize that "silver bullet" therapeutic interventions (be they fertilizers used as a substitute for nutrient cycling, or pesticides used as a substitute for management that maximizes nature's natural systems of pest control), at best provide very short term solutions to production problems. Nature inevitably neutralizes "silver bullet" effects.

Recognizing this fundamental principle of organic farming Rodale objected to the notion of defining organic agriculture as farming without synthetics. The issue, he said, was not one of synthetic vs. natural. The reason that organic farming generally rejects synthetic inputs, he said, is not that they are of themselves bad. Rather, it is that synthetic inputs, as a rule, are used to circumvent, rather than enhance natural systems.. Synthetics are usually used as a substitute for organizing the parts of the system into a productive, self-regulating whole. (Rodale, 1949) The use of synthetics, therefore, tends to create an artificial system of individual parts, rather than a natural system integrated as a functioning whole.

Defining "Organic" Processing

If the word organic defines a farming system, what relationship does it have to food processing? We believe this is the fundamental question that is not often asked as part of the organic food processing debate.

On the face of it the answer to the question appears simple. If "organic" is an adjective that describes a particular system of farming, then the only food that can be called organic is food that comes directly from such farms. Since processing is not a part of the farming system that "organic" describes, technically there can be no "organic" processing.

But one might still conceivably call a mode of processing "organic" if there were analogies to ecological farming practices in the processing system. Are there such ecological relationships in processing? In one respect there may be.

For example, Nichols Fox argues, persuasively we think, that escalating food borne illnesses are directly attributable to the uniform mediocrity that we have imposed on our modernized food system. "Whenever there is a lack of diversity, when a standardized food product is mass-produced, disease can enter the picture." (Fox, 1997)

In other words Fox is proposing that there is an ecology of food and that retaining its original integrity may therefore require that its original wholeness and complexity be preserved. One could argue, then, that processing which retains the original wholeness and complex ecological character of food is a kind of "organic" processing.

In any case we argue that processing which fails to retain the original integrity of the food produced on organic farms should no longer be labeled as organic food. Such foods should be labeled "made with organic ingredients." That label would truthfully recognize that some of the raw materials that went into the food were produced on organic farms, but the processing used to manufacture the food did not meet the requirements of retaining its overall original wholeness and complex ecology.

Unfortunately the argument has, until now, turned largely on which, if any, synthetic ingredients were added.

In other words the organic industry currently defines "organic" processing in a manner analogous to the way some segments of the industry once defined organic farming. In some circles farms were once considered organic simply because they avoided using synthetic inputs. Eventually organic farmers agreed that an industrial, monoculture farming system, even one that uses no synthetic inputs at all, is still not an organic farm. Farms that are not organized as whole, self-regulating natural systems, farms that rely on off-farm inputs and use therapeutic interventionist strategies to control pests, cannot be called "organic" just because they use natural or biological, instead of synthetic inputs. Such farming systems are still industrial farms. (Rosset and Altieri, 1997, Lewis, Lenteren Phatak and Tumlinson, 1997, Lampkin, 1990)

Whither "Organic" Processing?

How can our philosophy of organic farming help us clarify the issues concerning the processing of organic food? Clearly the ingredient list approach to determining "organic" processing is no more satisfying than the "input substitution" approach to organic farming. Even if no synthetics at all are added, do we label as "organic" foods manufactured from raw commodities produced on an organic farm, but changed so dramatically that they cannot be recognized as real food? Current rules, focused as they are on the ingredient list, would require that we say "yes" to that question.

In the certification of organic farms we have now moved fully away from the ingredient list approach. In order for farms to be certified organic they must conform to numerous nutrient cycling and natural systems management requirements. Simply refraining from using synthetics or feeding 100% organic feed will not suffice. A whole, integrated, natural system must be in place before a farm can be certified "organic." We need a similar bench mark for processing.

The National Organic Standards Board obviously agonized over the issue of defining "organic" processing. But in wrestling with the general standards for certified organic handling as outlined in the OFPA, it missed an opportunity to give more substance to the processing debate. The Act states that "If a production or handling practice is not prohibited or otherwise restricted under this chapter, such practices shall be permitted unless it is determined that such practice would be inconsistent with the applicable organic certification program." (6512) (emphasis ours) In other words the Act avoided any attempt to specify a particular kind of processing as "organic," but created an opportunity for the NOSB to determine what kind of processing practices would be consistent with organic certification and what kind are inconsistent with an organic label.

The NOSB started down the right track by mandating that a food, to be certified organic, must be handled so as to "prevent the 'loss of organic integrity'." (April 25, 1995, Orlando, Florida) But in its final recommendations six months later (October 31, 1995) the Board failed to seize the opportunity to delineate the kind of processing practices that were consistent with organic certification.

Instead, when the Board determined ways in which "organic integrity" might be lost, it limited itself to the issue of preventing "commingling" and "contamination" with non-organic product. The NOSB failed to use this occasion as an opportunity to include certain processing practices among the ways that food produced on an organic farm could lose its "organic" integrity.

We believe that "retaining the integrity" of food produced on organic farms will require us to take this additional step. If the definition of "organic" is derived from the farming practices that produce the food, then food can lose that label once its original character has been fundamentally changed. As soon as food produced on organic farms loses its original wholeness and complexity or is combined with other ingredients that were not produced on such farms, then such food should no longer be called "organic." Foods from organic farms that are used as ingredients in such altered, processed foods could, and should, be labeled as "made with organic ingredients."

Retaining Original Integrity

Of course few organic foods that we eat remain in exactly the form they were when they were harvested from organic farms. So what changes do we allow? How do we judge whether a food has been significantly changed? By what criteria shall we determine whether the "original integrity" of food produced on organic farms has been retained?

Federal Trade Commission (FTC) staff tackled this question 25 years ago. Although the rule they proposed was not adopted because of political interventions, over a seven year period the FTC crafted standards, with input from many thoughtful experts, that would have established the requirements for the use of the claims "organic" and "natural" in advertising. Their work resulted in a framework for claims with four major elements:

1. organic and natural are two different concepts---one describing a food production system, the other a processing system;

2. only some foods can be expected to be handled and promoted as "natural";

3. the standard for a natural food must incorporate limits on both processes and additive ingredients;

4. to meet consumer expectations, commercially produced natural foods should be similar to those produced in home kitchens. (Raj and Clancy, 1992)

This framework makes it clear that the FTC intended that the requirements for labeling processed organic and natural foods constitute a two-pronged standard, limiting both additives and processing.

With respect to labeling organic foods we have the additional burden of making clear that "organic" is a term that describes a farming system, not a processing system. We think it is confusing if not misleading, therefore, to use the phrase "organic processing."

Yet, as Nichols Fox (1997) reminds us, food has its own ecology, and we ignore that ecology at our peril. We believe that one way to move us to a more ecological type of food processing is to maintain the wholeness of food to the full extent possible, and that it is especially imperative that we retain this integrity in organic food. Processing is what most affects a food's integrity on the manufacturing side (and the type of processing then frequently determines what additives are used).

However, even if the processes used do maintain a food's wholeness, we do not argue that food processing can be described as an "ecological system" as we do on the farming side. Because processed foods have become such a large percentage of the food supply over the last 50 years, a standard that seeks to maintain the integrity of foods, using the two-pronged requirement, is likely to apply to a very modest percentage of the supply. That is, the number of foods expected to meet the standard is fairly small. This logic seems to have escaped many food manufacturers, a sign that these businesses are not necessarily interested in maintaining the differentiation or integrity of natural or organic foods. We seem determined to hammer most of our food into standardized mediocrity.

The two-pronged standard is essential to maintaining the integrity of organic food. When the FTC started its work, claims of "natural" were for the most part intended to convey the perception that the foods contained no synthetic additives. However, the staff recognized that this did not in any way capture what manufacturers were doing which greatly diminished the integrity of foods-processes that dramatically changed the food's wholeness and particularly affected its nutrient content.

Interestingly, several consumer surveys done around that time showed that most consumers thought that natural foods were not processed much, if at all. In fact, a significant percentage thought, not illogically, that only raw commodities could be described as natural. (Federal Trade Commission, 1978)

In light of these facts, it was imperative that the FTC propose a standard that addressed processes as well as additives. We note here also that a survey done several years later for the Organic Foods Production Association of North America (now the Organic Trade Association) found that natural foods industry members felt that the processes/operations meeting acceptability guidelines were limited to those that entailed the use of steam, heat, and a number of mechanical actions. Those operations using synthetic chemicals as processing aids, additives, and preservatives were deemed unacceptable. Furthermore, members felt that there was a clear interaction among processes and additives. (Raj, 1991)

Accordingly, the task before the FTC became one of identifying acceptable processes---those that would maintain the integrity of foods. On a continuum these could range from no processing to processes that caused significant change in many food characteristics. There was recognition that in most cases cooking, for example, destroys nutrients, and that cooking was an acceptable process. Thus, there was a need to reach a reasonable point between none and excessive. Those processes identified were called "minimal", and by the time the final proposal was published the list had been discussed and reviewed by chemists, nutritionists, food technologists and many others.2

At the time there was widespread (and uninformed) consumer expectation that any chemical additives were "unnatural". But there was a recognition by all witnesses and commenters that there was a set of chemicals that had been used in food preparation for hundreds of years, such as salt, baking soda, baking powder, natural flavors, etc. that should be allowed. The proposal included these additives, but excluded all others except for nutrient additives that are added through government mandate for public health reasons.

The two-pronged standard, which mandates restrictions on both, the degree of processing and the types of additives allowed, accomplishes several objectives. Together, minimal processing and limited additive use, come as close as possible to maintaining the integrity and wholeness of foods and traditional recipes. They separately and together exclude manufacturing operations that (to use the language of organic farming) solely substitute an input or technological intervention for a natural management system. In essence, the commercially processed foods that carry a "natural" or "organic" label are, in the main, those that would be prepared by cooks in home kitchens, using the equipment and food ingredients available in retail markets.

We hasten to add that the standards do not impose dietary restrictions on consumers. They do impose labelling restrictions that insure that consumers get what they expect. This means honey as sweetener, whole grain flours, cold pressed oils, and only natural colors and flavors. It means fermented foods produced in natural and traditional ways; without synthesized enzymes or other aids. It means a limited number of naturally processed or extracted preservatives.

Conclusion

If this two-pronged standard was established for the use of the "natural" label 25 years ago, can the organic food industry subscribe to a standard that is any less strict today? We believe that with respect to processing the same criteria apply to both "natural" and "organic". What distinguishes organic food from natural food is the farming practices by which it was produced.

The argument on the part of some that we cannot safely produce processed foods by following the strict two-pronged standard proposed by the FTC is hollow. In fact, one of the oldest, and largest, organic food manufacturers in the United States has recently argued passionately for maintaining just such a strict standard. (Organic and Natural News, April 1999) We suspect the reason that some argue for including additional processing and additives has more to do with the food system, than it does with food safety. Several years ago, Susan Hussey, vice president of marketing and advertising at Aubery Organics, argued that the only reason synthetic additives were necessary in natural cosmetics was that most of them had "been developed and used to solve problems of mass production and distribution." (Natural Foods Merchandiser, November, 1996) We suspect the same may be true of organic foods.

Finally, there is also an important market reason for adhering to the strict two-pronged standard proposed by the FTC. Organic foods are attractive in the marketplace precisely because they are differentiated. Consumers buy organic because it is "different"---raised differently, processed differently. The more that differentiation is accentuated, the more attractive the food is to consumers who shop for it. The more that differentiation is lost the less attractive it becomes.

References:

Federal Trade Commission. 1978. Proposed Trade Regulation Rule on Food Advertising: Staff Report and Recommendations. Washington D.C.: US Gov. Printing Office. September 25.

Fox, Nichols. 1997. Spoiled: The Dangerous Truth About a Food Chain Gone Haywire. New York: Basic Books.

Lampkin, Nicolas. 1990. Organic Farming. Ipswich, UK: Farming Press.

Lewis, W.J. et.al. 1997. "A Total System Approach to Sustainable Pest Management." National Academy of Sciences, Proceedings, Vol. 94, November. Available online at http://www.pnas.org.

Raj, Sudha. 1991. Attitudes of Processors and Distributors Towards Processing and Processing Guidelines in the Natural/Organic Foods Industry. Syracuse, NY: Syracuse University. PhD dissertation

Raj, Sudha and Kate Clancy. 1992. "Development of Standards for Natural Foods." Cereal Foods World. 37:4

Rodale, J.I. 1949. The Organic Front. Emmaus, PA: Rodale Press.

Rosset, Peter M. and Miguel A. Alrieri. 1997. "Agroecology versus Input Substitution: A Fundamental Contradiction of Sustainable Agriculture." Society and Natural Resources. 10:283-295.