As we cannabis farmers merge into the existing adventures of regulated agriculture production, and given that California is the nation’s leader in organic production, it would probably be a good idea if organic cannabis farmers become knowledgeable on CDFA and USDA/NOP Guidelines by the time cannabis is a nationally accepted agriculture crop; and be ready to fall into step with the nations 5.5 billion dollar industry.
Most of you know us, Spencer and Dia Damon of Nomad’s Landing, for our craft cannabis, natural farming methods, living organic soil or our Dragon Fly Earth Medicine Pure tips and chats. Maybe you know us from the Pro-biotic Farmers Alliance and our ‘Bio Remediation and Earth Worm Farming’ workshops, or perhaps this is our first encounter. However it is that we have connected, we are happy for it and want to bring you a little insight into a ‘Great Mystery’ for most of us farmers…the world of Regulated Cannabis Agriculture.
Understanding the logistics of these regulations can be hair ripping for most of us farmers, but it’s important for farmers to have a solid understanding of their responsibilities and due diligence to their craft, after all, it’s the farmers responsibility to ensure they produce a clean crop; and at the end of the day it is the farmer who is liable.
So what is Organic really?
Most consumers believe in the USDA Organic Label meaning no pesticides, no chemical or synthetic fertilizers and no GMO/ engendered seeds were used to produce said crop. Yet, there have been several cases through out the judicial systems over the past decade for faulty claims of some kind of miracle organic sauce to increase your taste, yield, your growing skills, and even save you some dough.
Some of these products were OMRI (Organic Materials Review Products) Listed and then taken off the list once confirmed non-organic substances were being used. So what is a farmer to do if you fall into the “bad sauce” skillet? A farmer could start by learning about bio remediation techniques and how to implement them into their farm system.
The bottom line is that there are a lot of products out there and CDFA (California Department of Food and Agriculture) and OMRI as well as WSDA (Washington State Department of Agriculture) all work together with the USDA/NOP to ensure organic standards are met. Farmers are busy people and trust in these certifying organizations to ensure that the products they are purchasing are up to USDA Organic Standards and are safe for the marketability of their crops, but what happens when the sauce get through the hoops like last years eye popper, with a grand slam of 14 OMRI listed products were taken off the Oregon shelves for pesticide contamination, and to current date the products continue to be removed from the shelves.
In 2011, that was the question that spread like wildfire when the Sacramento Bee released a story that exposed California Liquid Fertilizer for using synthetics in their certified organic products. This was almost a economic disaster for California’s Organic farmers.
By law, once organic plots have been contaminated, the plot must stop production for 3 years and have it tested to confirm no residue pesticides or synthetics are present. This situation could have also lead to a national loss of trust in the USDA Organic Seal, due to the fact that California leads the nation (then and now) in organic land use production and organic products sold.
When the scandal of the California Liquid Fertilizer broke, it was one of the most sought after fertilizers and used by everyone in large Ag businesses to Mr Green Jeans and his backyard home-grown goodness. It was easy to use, did not clog up the drip lines, was organic, cheap and everyone carried it. All the large organic Ag farmers were buying it by the barrel-full; and after years of being in production, a problem occurred; salmonella poisoning and rounds of testing began.
When the mist settled, the flow was tracked back to the source and that was California Liquid Fertilizer. The owners were indicted but what about the farms? Nothing happened in this case to any of the farms as to preserve the integrity of the USDA Organic Seal and the preservation of California’s Organic Farm, but it was made very clear that it is the farmers due diligence to know what is applied to their soil and crops.
It was on this issue that California began taking action to prevent future ”rotten sauce” from flowing onto California’s organic fields. The CDFA implemented Article 4 2320.2 which requires registration of all inputs and their sourcing for each product that is to be used or sold in California.
We have had our share of run-downs as well, not with the product being recalled, but more along the lines of contaminants through sourcing. For years we used Soft Rock Phosphate when we built our soil, top dressed, and feed our worms until we were educated by Clackamas Coot and Tim Wilson that depending on the location of where the SRP was mined that it could test positive for Plutonium 210 (a radioactive material), lead, and cadmium. Well needless to say once that realization rang the door bell we stopped using it.
For us there were two major reasons:
- Cannabis is a bio dynamic accumulator and we were not down to consume any of these extra minerals/elements into our bodies or our patients
- In 2002, California passed legislation, concerning toxic levels of heavy metals and dioxins such as Arsenic (As), Cadnium (Cd), and Lead (Pb) in our soils and waterways.
As a matter of fact, there is an initiative in play called the California Healthy Soil Initiative. It is an inter-agency plan to reduce agriculture green house gases, build soil carbon, and improve drought resiliency. One of the major goals is to reduce the amount of material that is deposited into our California Land fills every year; about 12 million tons of material that could be made into farm produced compost and mulch.
The main focus is to repair and restore healthy microbial communities back onto our soils, with farmer education on sustaining our crops to provide nutritious food, fodder, and medicine to the nation. The CDFA is looking for farmers to participate in this program. If your interested check it out http://www.cdfa.gov.healthysoil/
Here are a list off organic material review websites that you can go to and check out inputs that you are interested in buying or already using; just to make sure it’s all good!
- CDFA Fertilizer Product Database
- Agricultural Marketing Service
- Organic Materials Review Institute
- Washington State Agriculture Organic Brand Name Material List
Beyond checking web sites for approved input materials, what can a farmer do to insure everything is Kosher?
We recommend talking to Cannabis Certifiers such as Clean Green, Certified Kind, or us at Dragon Fly Earth Medicine Pure. We had the opportunity to chat with Christine Coltellaro from Certified Kind and she graciously gave us some helpful information we thought our farming friends and family could utilize.
1. What can farmers do to ensure that the products they use are safe?
Christine’s response: If purchasing inputs, farmers can look for the OMRI seal, or any other seal of an accredited material review organization (WSDA, CDFA). This seal means the input has been reviewed and is allowed for Organic. Farmers can also contact the manufacturer directly to get a breakdown of ingredients, as some prohibited processing aids or incidental ingredients are not required to be listed on the label.
Generating inputs on your farm is a great way to know what you are giving your plants and may save some bucks, utilize natural resources, and support biodiversity. Compost and vermicompost (direct application, teas, etc.), ferments, building Hugelkulture beds, etc. are great examples of this. Certified Kind is based on the National Organic Program Standard so we are really looking for inputs that aren’t synthetic or otherwise harmful. As a resource, our Big Green List is a breakdown of materials allowed and prohibited in Certified Kind production, and is available on our website. Our standards are also on our website.
2. What are good starter Best Management Practices for farmers?
Christine’s response: Spend time observing your plants. Scout for pests. A great way to combat pests is to stay ahead of them. Incorporate cover crops during the off-season for outdoor production. Cover crops can also be used in pots. For outdoor, in-ground operations, observe your soil – texture, drainage, exposure etc. – and amend accordingly. Use organic-approved inputs. Even if you aren’t planning on a certification now, Certified Kind requires land to be free from prohibited inputs for 3 years to be eligible for certification (I believe this is consistent with other cannabis certifiers). Keep detailed records. Start an observation journal.
3. What is the most recurring issues you find on farms?
Christine’s response: Inconsistencies in record keeping and accidentally applying prohibited materials (which is a real bummer!).
Record keeping does not come naturally for everyone, but this is the only way you can back up your practices. It is not realistic for a certifier to visit a farm on a weekly basis, so we rely on recordkeeping to verify practices and answer questions that may come up during an inspection.
Certified Kind has come to terms with differentiating certified flower that may not be suitable for extraction. This happens when test results come back for low levels of a prohibited material, usually due to drift – once we even found a minute level of a prohibited pesticide that we traced back to a flea collar – so really minor unavoidable stuff that does not compromise the certification and, as far as we know, is not harmful to smoke but because an extract is concentrated, that level increases to a point where it is now prohibited in the extract.
4. Do you have advise on documentation/record keeping for the farmer?
Christine’s response: Document everything. If spreadsheets are daunting, start with the aforementioned observation journal. Get in the habit of keeping track of when and where and how much of whatever was applied, of what you added to that batch of compost tea, the weather, general observations of your plants, what bugs are flying or crawling around, etc. Build this practice into your day as you would any other daily task. Taking pictures to remind yourself may also be a good idea.
5. What benefits will a farm see by being certified ?
Christine’s response: Happier and healthier plants, soil, employees, and customers! There is the chance you can charge a premium for your product if it is certified. Make sure you let your buyers know your products are certified so they can pass that along. Certified Kind is currently reaching out to dispensaries to hone in on the benefits of offering certified product in their stores (we know there is demand), and also to educate dispensary staff about certification.
We get feedback from farmers that because of the requirements of certification they become more organized as a business. Certified Kind is also a good resource for our clients (and also non-clients). When they hit a wall with their own research they know they can reach out to us with questions about inputs, allowed practices, or troubleshooting a pest or disease problem. As we grow, we are finding that clients are getting in touch with each other, it will be exciting to see where those relationships go.
If you have any bioremediation or soil fertility questions please feel free to contact us at firstname.lastname@example.org
We hope this article has shined some light on what will be in store for our future farming.
May love, light, laughter and abundance blaze your trail!