Poisons In Certified Organic Food?
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I have long thought that the little USDA Certified Organic label being on a product, meant that the product I was buying was free from poisons. But that's not necessarily always the case.
In this article, we're going to take a look at what's really allowed in USDA Certified Organic products.
Most people are likely aware that the majority of the food-like products available in most grocery stores are full of poisons. I have been buying and eating organic food since just before my daughter was born almost 3 years ago. We don't eat 100% organic foods, but most of the food we buy is organic. While it may be true that foods with this certification must go through a testing process to check for prohibited substances, it does not mean there's zero poison in the food. Thankfully, the USDA has quite a bit of information available for anyone to look through freely.
I originally intended for this to be one article, but after a few days of researching and writing, I decided I would make it a series. This is part one.
The National List of Allowed and Prohibited Substances
The National List of Allowed and Prohibited Substances identifies substances that may and may not be used in organic crop and livestock production. It also lists the substances that may be used in or on processed organic products. In general, synthetic substances are prohibited unless specifically allowed and non-synthetic substances are allowed unless specifically prohibited. For example, a vaccine used to prevent pinkeye in livestock is an allowed synthetic substance and arsenic is an example of a prohibited natural substance. Some substances on the National List may only be used in specific situations, e.g. only for certain crops or up to a maximum amount.UẞDA: The National List of Allowed and Prohibited Substances
Right off the bat, before even getting to the actual list, you can see that synthetic substances are allowed, which I've made bold in the above quote.
Apparently, I'm not the only one that thought there was no synthetics in organic foods
A 2010 poll found that 69% of consumers believe that to be true. A survey from the Soil Association found that as many as 95% of organic consumers in the UK buy organic to "avoid pesticides." - RealClearScience
Another important point to emphasize, is that reading the ingredients label on a product, does not usually include things that were added before the end product is produced.
For example, if your buying some Pesto sauce, and you look at the ingredients, they don't have to list the fact that Glyphosate (Roundup) was sprayed all over the basil on a regular basis for the majority of the crops life, then shortly before it's harvested, they stopped spraying. Right before the certifying process happened. This is a lot more common than you'd think, like what happened here. A hydroponic farm was able to circumvent the rules because they were growing their crops in a container, rather than in the ground. (PDF Mirror). While this may be only one example of this happening, it shows that there are quite a few different loopholes in the certification process.
But wait, there's more!
If you've ever looked at a product that has been certified as organic, you'll notice that there are quite a few different companies that can certify a product as organic.
Organic operations are certified by private, foreign or State entities that have been accredited by USDA. These entities are called certifying agents and are located throughout the United States and around the world. Certifying agents are responsible for ensuring that organic products meet all organic standards. - USDA: Organic 101: Five Steps To Organic Certification
As you can see from the above quote, certifying agents can be "private, foreign or State entities that have been accredited by USDA". So really, it seems that pretty much anyone can become a certifying agent. This really makes me question the integrity of these certified organic products. At the time of me writing this article, there are a total of 76 certifying agents in the Organic INTEGRITY database.
Now, Onto The List!
Some synthetic substances are listed as exceptions to the basic rule and are allowed for use in organic agriculture. For instance, pheromones have long been used as an effective, non-toxic way to “confuse” insects that may otherwise infest organic crops, especially fruit. Likewise, vaccines for animals are important disease prevention tools against many infectious diseases, especially since antibiotic therapy is prohibited in organic livestock. - UDSA: Organic 101: Allowed and Prohibited Substances
Without displaying the entire list here, which is very long and contains a lot of things, I will just cover the ones that I feel are questionable. I will bounce around in the list, and organize them by how harmful they are, in my opinion.
Fungicides and Insecticides
Many people are under the assumption that organic pesticides are safer than synthetic (Organic meaning derived from naturally occurring substances), but this is not necessarily the case.
[T]here are a lot of myths out there about organic foods, and a lot of propaganda supporting methods that are rarely understood. … Organic farming, just like other forms of agriculture, still uses pesticides and fungicides to prevent critters from destroying their crops. … It has been assumed for years that pesticides that occur naturally (in certain plants, for example) are somehow better for us and the environment than those that have been created by man. As more research is done into their toxicity, however, this simply isn’t true, either. Many natural pesticides have been found to be potential – or serious – health risks. - Christie Wilcox: Scientist and Journalist for Scientific American
It is used as an insecticide, fungicide, plant disease control, as a soil amendment, and as a topical treatment, external parasiticide or local anesthetic for livestock.
As you can see, it's used quite a bit in USDA Certified Organic products. Here's a quote from the USDA about its use.
"Copper sulfate is listed as allowed for use in crop systems in 7CFR 205 for plant disease control, with a restriction that it be used in a manner that minimizes copper accumulation in the soil. It is also listed for use as a micronutrient with a testing requirement for documented deficiency. The petition is for use as an algicide and to control invertebrates, specifically tadpole shrimp in rice production. This material has been historically widely used for organic crop disease control in the US and internationally, but the EU has proposed a complete ban on all copper use scheduled to take effect in May 2002." - USDA: Copper Sulfate: Crops for use as algicide and invertebrate pest control(PDF Archived Here)
So, the EU was supposed to ban it way back in 2002. However, It is still currently allowed.
While it is true that copper is an essential mineral, the amount that is used in farming poses a risk because it is used so much.
Texas A&M Agrilife Extension shared how using copper sulfate to bathe the feet or heels of dairy cows contributes to the environmental toxicity of copper. The chemical is added to footbath mixtures to prevent the spread of footrot in dairy cows. -Dairy Footbaths and Environmental Toxicity of Copper
The article noted that once the footbath solutions are disposed of in the milking center waste, this raises the concentration of copper in the slurry, which leads to raising the levels of copper in the soil over long periods of time. This poses a threat to soil, crop, and livestock health. - johnnacrider.com
Then when you factor groundwater into the equation, you get quite the buildup.
"The negative effects of copper in ecosystems persist for long periods after exposure. The EPA drinking water standard is 1.33 milligrams per liter (mg/L), and levels that stress fish and kill algae are only slightly higher than the freshwater standard of 2.6 micrograms per liter (μg/L)." -Dairy Footbaths and Environmental Toxicity of Copper
They go on to describe how even low levels can damage crops in a very large way.
"The potential for soil toxicity is high where copper-rich manure or wastewater has been applied long-term. Although copper is an essential micronutrient, high concentrations in the soil can be toxic to plants. The degree of copper toxicity varies by plant species. - Dairy Footbaths and Environmental Toxicity of Copper
As for copper toxicity in livestock, most swine and poultry are often fed high levels of copper to promote growth. Sheep, however, are so sensitive that they could die within hours of ingesting feed containing only 10 ppm.- johnnacrider.com
As you can see, the levels do not need to be very high at all. For reference, 100 micro grams (μg) is equivalent to about 1/10 a grain of sand, and there's 1000 micrograms (μg) in 1 milligram (mg). I'm not sure how much is used on a farm nowadays, but in 1971, it was used at a rate of 4 pounds per acre.
They allow chlorine to be used, according to EPA standards (4mg/liter or 4ppm). Drinking chlorinated water has been shown to have numerous negative health effects. There is quotes all around the internet, mostly which have just been copied without reference links, but here's two of the references that I was able to track down. The bottom line is that chlorine is toxic and there are alternatives available that are not harmful, like using iodine. Here is an a book that you can see a number of quotes regarding the toxicity of chlorine, What's In Your Water by John Hinds.
- According to this study, Drinking water and cancer, The use of chlorine for water treatment to reduce the risk of infectious disease may account for a substantial portion of the cancer risk associated with drinking water. The by-products of chlorination are associated with increased risk of bladder and rectal cancer, possibly accounting for 5000 cases of bladder cancer and 8000 cases of rectal cancer per year in the United States
- "I am quite convinced, based on this study, that there is an association between cancer and chlorinated water," says Robert D. Morris of the Medical College of Wisconsin in Milwaukee, who directed the new study. Previous investigations showed no clear link between chlorinated drinking water and bladder or rectal cancer, but those efforts may have lacked the statistical power to find a connection, Morris says. - American Journal on Public Health 1992
Peracetic acid is not explicitly listed as GRAS (Generally Recognized As Safe) by FDA. However, PAA arguably benefits human health by controlling
food-borne pathogens - USDA: Peracetic Acid Technical Report Handling (PDF Mirror)
Quite alarming that it is NOT listed as GRAS.
Peracetic Acid is used in various different ways on farms. In organic farming, the applications are limited to the following uses:
- As algicide, disinfectants, and sanitizer, including irrigation system cleaning systems.
- As plant disease control.
- For Livestock: As disinfectants, sanitizer, and medical treatments as applicable.
- As an Additive; Nonagricultural (nonorganic) substances allowed as ingredients in or on processed products labeled as “organic” or “made with organic (specified ingredients or food group(s)).
In the Peracetic Acid Handling document from the USDA, it states that it's allowed for direct human consumption, and if it is applied to ready to eat products in solutions of less than 100ppm, it is not even required to be listed. I also stumbled upon another document related to the uses of this pesticide, and it states that it can be added directly to water.
Disinfection of animal drinking water: Animal drinking water is disinfected by automated dosing of the product into the water stream. - Assessment Report: Peracetic Acid
According to the National List of Allowed and Prohibited Substances, purifying water with Peracetic Acid by adding it directly to the water is not permitted in Certified Organic foods, but I had to point this out because it's absolutely insane. It's also important to note that in this study, it was shown that ingesting water containing Peracetic Acid regularly, induces the formation of lung tumors. It was also shown that it reduces White Blood Cell count (WBC), Red Blood Cell count (RBC), Hematocrit (HCT), and Platelets (PLT), so it definitely should not be used regularly on animals intended for eating, or in general.
hematological variables such as WBC, RBC, HCT and PLT decreased significantly in Peracetic acid treatment groups -The Effects of Subacute Exposure of Peracetic Acid on Hematological Indices in Wistar Rats
This sounds alright, but I had a feeling that they weren't referencing actual real soap here, and I suspected that they included synthetic soaps here like Sodium Lauryl Sulphate, which is toxic (PDF Archived Here).
But I was wrong about that. They are referencing actual soap made with Potassium (Lye), but alarmingly have recently allowed the use of Ammonium made soap, which is not good.
The materials on these substances leave questions unanswered. The original TAP review appears to have considered only potassium-based soaps, but the more recent TR considers both potassium- and ammonium-based soaps. Yet ammonium-based soaps seem to be limited to another use altogether by §205.601(d) “As animal repellents—Soaps, ammonium—for use as a large animal repellant only, no contact with soil or edible portion of crop.”
Secondly, despite the requirement in OFPA that the National list “shall contain an itemization, by specific use or application, of each synthetic substance permitted,”1 the use pattern is not defined. Although the materials included with the original TAP review and much of the discussion in the recent TR address a use in which the substance is sprayed on surfaces covered with algae or moss, the TR also discusses alternatives to use in ponds. This is important because while the use on surfaces like walkways and benches in greenhouses pose little environmental hazard, the use in a waterbody is quite different. As the TR says, “The acute and chronic toxicity of soap salts is markedly different for land- and water-dwelling organisms.”
Thus, the CS should specify which soaps and which specific uses are covered by the listing in a proposed annotation. - Beyond Pesticides: Comments on sunset 601-602
They do not specify how these ammonium made soaps are used, which is alarming because they are absolutely toxic to aquatic animals according to this document
I dug for quite a while to find out the toxicity of these ammonium based soaps, and did find one study that claims high doses result in reproductive and mutagenic effects. They are going from the basis that synthetic soap salts are identical to naturally occuring soap salts. Ammonium soap salts are synthetic.
The RED notes that soap salts of potassium salts of coco fatty acid and sodium salts of caprylic acid, when administered to lab animals at high doses cause reproductive and mutagenic effects. - Federal Register: Ammonium Soap Salts of Higher Fatty Acids
I also looked up the MSDS (Material Safety Data Sheet) for Ammonium Nonanoate, which seems to be the most common ammonium soap salt. From this, you can see that there's basically no data available on the safety of exposure to this particular soap salt. It's also imporant to note that this particular soap is NOT intended to be used on food crops, but the study from the Federal Register notes that it's likely that it will end up on food crops unintentionally.