APPENDIX 16
Memorandum submitted by the Chief Executive,
Horticulture Research International (F 21)
Thank you for contacting me on 5 May, inviting
Horticulture Research International to submit written evidence
on the issues covered by the terms of reference of the Agriculture
Committee inquiry into organic farming. Your request was reinforced
by the Chairman of the Agriculture Committee (David Curry MP)
following HRI's evidence session with the Committee on 10 May.
INTRODUCTION
1. The Agriculture Committee's principal
focus is clearly on economic issues surrounding subsidy schemes
for organic conversion and production, processing, marketing and
other aspects of the organic conversion and production, processing,
marketing and other aspects of the organic food supply-chain.
Obviously many of these issues are outwith the specialist professional
knowledge-base of HRI's research staff. Nevertheless, significant
scientific opportunities and concerns arise from the projected
expansion of organic farming (including horticulture), the setting
of organic standards and tolerances, as well as food storage,
transportation and shelf-life issues. Independent, objective and
high-quality research in these areas is required urgently, in
order to gather sufficient reliable knowledge on which to base
future policy decisions, thereby avoiding possible future hazards
to the environment and consumer health.
2. To compile this Memorandum, I have consulted
widely with senior scientific colleagues throughout HRI. I am
particularly concerned that, with such an emotive, public and,
at times, controversial subject as organic farming, our collective
response is robust and based on a range of sound scientific analyses,
inputs and real data, not on myths, propaganda, market opportunism,
unsupported assertions, or intolerant extremist ideology.
3. Horticulture Research International was
established in 1990 as an Executive Non-Departmental Public Body,
sponsored by MAFF, it is also a Company limited by guarantee without
share capital, and a registered charity. HRI will be familiar
to the Agriculture Committee through memoranda and evidence from
witnesses on 10 May 2000 during an inquiry into its role, responsibilities
and a recent restructuring exercise. Further details are available
on our website (http://www.hri.ac.uk).
4. Significant in the context of the inquiry
into organic farming is the fact that HRI's mission is "To
innovate and communicate for the benefit of consumers and producers
of horticultural and other plant-based products". To achieve
this, HRI undertakes research and development for sustainable
horticulture world-wide, with particular strengths in: pest and
pathogen biology; biological control; integrated pest and disease
management (IPDM); plant-pathogen interactions signalling mechanisms
in plants; plant breeding and genetics; responses of plants to
environmental stresses; and horticultural crop production systems
(including organic).
5. In a recent report to BBSRC Council,
I wrote, "HRI . . . [is] . . . fully aware of the need to
bring sound science to bear on the processes, procedures and outputs
of organic food production. HRI is certainly in the vanguard of
these efforts". At HRI Wellesbourne (WB), we have a close
association with the Henry Doubleday Research Association using
our converted organic field trial plots and have carried out modelling/desk
studies on nitrogen cycling. Work in this area has been funded
by MAFF for three years, with two further years agreed. We are
presently negotiating with commercial grower(s) to undertake research
on organic procedures and protocols for modelling studies on quasi-commercial
scales. Moreover, HRI East Malling (EM) has recently received
ERDF funds (INTERREG) to establish a European centre-of-excellence
for organic fruit and ornamental nursery stock production. This
is in collaboration with the French equivalent of the Soil Association
in Nord-Pas de Calais. HRI has also won significant (£2.26
million) Treasury Capital Modernisation Funds to establish an
organic fruit research and public communication centre at East
Malling. Moreover, HRI-EM is engaged with Kent Enterprise Forum
in a bid to SEEDA to establish an Enterprise Hub in Food/Environment
and Healthcare. As well as attracting new investments in other
project areas (including biotechnology), we expect to underpin
further our research capacity to assess the claims and counterclaims
for organic food and production procedures. HRI has converted
organic research land at Kirton (Lincs), part-funded by the private
sector. HRI-WB is also participating in a major EC Framework V
bid on "Breeding for Organic Production". To conclude,
HRI is therefore uniquely qualified to become the "melting
pot" from which truly integrated crop management protocols
can emerge, based on high-quality research in plant genetics,
GM technology, conventional and organic farming systems.
6. Many recent, reliable and reputable sources
of information on organic farming are available, several of which
will be known to Committee members. These include the House of
Lords Science and Technology Committee Report (1999) on organic
foods and farming. MAFF has also produced a useful "Foodsense"
guide for the consumer (Ref No PB2085) on "organic food",
covering definitions, production standards and the inspection
system, animal health and welfare, labelling and importation issues.
The Committee may also be aware of the 10-year "Boarded Barns
and Bundish Hall Farms" project, funded by Rhône-Poulenc
Agriculture Ltd, at Ongar, Essex. This project ended in 1999.
Detailed annual reports and a final report are available and make
fascinating reading. This project compared and contrasted, over
10 years, a broad range of environmental impact measures and economic
(yield/quality) output indicators for a variety of crops grown
under conventional, integrated crop management (ICM), or organic
production systems. I commend these reports to the Committee.
A similar comparative research trial is underway at Hillsburgh,
Ontario in Canada to provide consumers, journalists and farmers
with information regarding the true costs, benefits, tastes and
consumer preferences of food produced by organic, conventional
or GM technologies. Further information is available (http://www.plant.uoguelph.ca/safefood/bt-sweet-corn/bt-index.htm)
or can be accessed through [email protected] (GM news,
Canada 7 June 2000).
7. The Royal Society organises one of several
e-networks/websites where organic farming issues, among other
controversial topics such as GM, the precautionary principle etc,
are debated internationally (for example, see Annex (not printed))
(http://www.agbioworld.org, http://agbioview.listbot.com) or contact
[email protected] (http://www.botanischegarten.ch/start.htm).
8. Contrary to the rhetoric from those who
promote and benefit directly from arbitrary, uncompromising and
intolerant edicts to define organic certification standards, protocols
and products, modern crop science and technology have, as their
key objectives: the development of increasingly sensitive, environmentally
sustainable cropping regimes; reduced inputs of all agrichemicals;
improved crop quality and greater food safety. These objectives
are being, and will be best achieved by an intelligent and inclusive
combination of "best practice" approaches, each underpinned
by sound scientific facts and knowledge. In each case, the final
result may include components of so-called conventional, organic
or biotechnological agriculture. For example, integrated pest
and disease management (IPDM) or integrated crop management (ICM),
using decision support software to minimise and target more precisely
the application of safe an defective chemicals, and/or to achieve
meaningful biological control, has already benefited the UK environment,
as well as our agricultural and horticultural industries, substantially.
9. Philosophically, organic farming is a
system of production which was practised for 10,000 years until
early in the 20th century when it was gradually replaced by more
intensive methods (now referred to as conventional farming) in
order to feed a rapidly growing population. There is nothing special
about organic production methods, other than they try to use more
"natural" inputs which, by dubious inference and no
proper definition, are assumed nostalgically to yield more "wholesome"
produce. (One could draw conclusions from diet and health data
through the 20th century, then compare it with earlier eras!)
In fact the active ingredients in many of these inputs are similar,
if not identical, to those used in conventional production, which
simply uses them in a purer form. For example, the nutrients taken
up by plants (N, P, K; nitrates, phosphates, potassium) are identical
in both systems, apart from their method of application. In organic
systems, they are introduced via manures or fertility-building
plant residues, which must first break down to release their component
nutrients to be used by the crop, whereas in conventional systems
they are applied directly in an inorganic form. Many of the chemical
pesticides used are similar or identical to the active ingredients
in organic treatments which seek to use "natural" products
and other defence strategies to protect the crops from inevitable
depredations by pest and pathogens. The main difference is that
the organic treatments are more hit-and-miss because there is
less control over the amounts of active ingredients applied. In
short, current regulations on "allowed inputs" are based
largely on arbitrary judgements and not on sound principles.
Turning now to the specific topics in your call
for information.
EXPANSION OF
ORGANIC FARMING
10. The UK currently supplies 18 per cent
of the organic market, so there is potential for growth—provided
consumer demand is maintained. The reverence with which organic
production methods are presently being promoted by vested interests
and the media is based on very uncertain arguments. This is largely
the result of a marketing ploy created by the Soil Association
and others, designed to play on the fears of a largely uninformed
UK public. Little has been done to allay these fears by the supermarkets,
who have also exploited them for market gain. Their actions have
done little to help the UK industry which has not been able to
redirect its activities quickly enough, or to comply with our
strict certification regimes, to supply this sudden demand. The
result has been the marked expansion in imported organic produce.
11. For many years, MAFF have supported
HRI and other public sector organisations in crop breeding programmes
to improve pest and disease resistance. The resulting varieties/cultivars
are essential to organic producers. Intrinsic genetic resistance
to disease is the most effective route to achieve yield and quality
under organic regimes. Regrettably, and unilaterally, the organic
movement has shunned modern biotechnology and its potential to
achieve a rapid, precise and targeted genetic improvement in crops;
even in "older" (hence more "natural"?) varieties
that succumbed to particular pests or diseases and were uneconomic
(although biodiverse).
12. In some cases, "organic" may
not be an option because of the requirements for crop rotation.
There can be inconsistencies between the apparently arbitrary
rules laid down for organic production and local best practice
for crop husbandry.
13. Any substantial expansion of organic
farming in the fruit and vegetable sector is likely to arise through
conversion of existing conventional production. In the fruit sector,
it is difficult to convince conventional, intensive growers to
convert to organic production largely because of technological
problems including excessive pest and disease damage and nutrient
availability. Growers feel that to sustain a healthy orchard over
its lifetime under organic regimes is unrealistic. However, they
are committed to reducing chemical inputs and wish to see more
research into biocontrol and ICM programmes which have had, and
continue to have, significant benefits for the whole industry.
Over 90 per cent of organic apples are imported. Current methods
of organic apple production are unsatisfactory; yields are low
and erratic (typically 50 to 80 per cent of conventional) and
quality is poor. The small number of organic apple growers in
the UK (approximately 12 above 1 ha) rely on high prices (50 to
100 per cent above conventional) and the acceptance of a lower
quality standard (classes I and II combined) to maintain economic
viability.
14. Expansion of organic farming in the
protected edible crops sector is likely to be limited under current
organic standards, particularly those set by the Soil Association
which, in many circumstances, renders conversion uneconomic.
MARKET TRENDS
AND CUSTOMER
DEMAND
15. There is an urgent need for a clear,
defined understanding and pronouncement to producers, marketers
and consumers of what constitutes "organic produce",
both to a realistic UK national standard, and for acceptance of
organic food produced overseas and imported (presently 80 per
cent).
16. Although still a minority niche market,
"organics" presents an irresistible economic opportunity
to some sectors of farming; hence, most organic markets are growing
rapidly. Growth in the organic fruit and vegetable sector is particularly
rapid and UK organic producers cannot keep pace with demand, leading
to large imports. Predicting the saturation point of the organic
market is difficult. On continental Europe organic markets are
more mature and premiums are much lower (10 to 30 per cent) than
in the UK. In some specialist food sectors, for example the processed
baby food market in Germany, organic products occupy over half
of the total market.
17. Clearly organic markets are driven by
a balance of perception and premium. In the UK, organic food is
perceived by major supermarkets as an attractant for general shoppers
and the range and quality of products in many major retailers
increases weekly.
THE ROLE
OF ORGANIC
CERTIFICATION SCHEMES
18. There is consensus among scientists
in HRI that certification schemes are essential for quality assurance
and customer confidence. However, there is also a strong view
that certification schemes should be based on rigorous science
and not on philosophical dogma. It is in this context that there
is an urgent need for more research and development into organic
production and the impact of organic systems on biodiversity and
the environment. There also needs to be research into the health
and safety of organic food in order to provide the public with
a more rational basis for choice and with genuine quality assurance.
19. There is a general perception among
scientists, and some growers, that the Soil Association can be
dictatorial, inflexible and illogical in certain instances. However,
there is a general consensus that a "policing" organisation
is needed to maintain standards and public confidence; but it
too should be accountable.
ROLE OF
ORGANIC CERTIFICATION
ORGANISATIONS
20. It is becoming clear that the plethora
of organic accreditation agencies, some trying to gain consumer
confidence and hence a greater market share by ever-more stringent
criteria, is a hindrance to the development of the sector from
a grower's perspective.
21. These organisations could play a more
positive and proactive role in facilitating "pull through"
from strategic research in the public or private sector to producer-oriented
protocols.
SETTING OF
ORGANIC STANDARDS
AND TOLERANCES
22. Organic standards and tolerances should
be based on rigorous science. A logical, rational approach based
upon sustainability, safety, quality and health should be adopted
wherever possible. A single, national, independent charitable
organisation should be responsible for setting and policing standards
under UK government and EU guidelines. This organisation ideally
should have a science base.
23. There is a growing view among the public
in the USA, and now in the UK, that "organic" may not
be as wholesome as it claims. In a recent study commissioned by
the American Broadcasting Company, reported on prime-time TV during
an interview with the head of the US organic organisation, independent
food analysts found no significant differences in macro- or micro-nutrient
composition between organic and conventional produce; however,
the former were contaminated with up to 100-times more bacteria,
including E-coli 0157:H7. This issue needs to be addressed,
ideally by bringing organics into the fold of NFU/retailer protocols
and quality assurance audits.
24. There are no clearly set-out protocols
for organics in either the "Organic Farm Management"
book or in the Soil Association Certification Ltd "Standards
for Organic Food and Farming", although there is a lot about
certification and registration. Among growers and scientists,
there is a suspicion that protocols can be generated expeditiously
and "on the hoof", and if there are serious problems
of disease (eg potato late blight) or shortages of supply (eg
organic seed), derogations can be given (eg on conventional chemical
sprays or seed).
25. As far back as the 1920's, in Switzerland,
the so-called "bio-dynamic agricultural movement" began,
based on "spiritual science" and the application of
small amounts of up to eight different manuring substances (six
composted solids or two field sprays), so-called "preparations".
Out of this the Demeter movement and (deep) organic certification
body emerged today in the UK (with 50 symbol holders). These "preparations"
allegedly work on homeopathic principles and can be bought; however,
new bio-dynamic growers are encouraged to make their own. Scientifically,
one can only ask: how does one standardise such a scheme?
ROLE OF
FARM ASSURANCE
SCHEMES
No comment.
AVAILABILITY AND
SUSTAINABILITY OF
PUBLIC AND
PRIVATE ASSISTANCE
FOR ORGANIC
CONVERSION (INCLUDING
THE ROLE
OF TRADE
ASSOCIATIONS, FOOD
PROCESSORS, SUPERMARKETS
AND THE
GOVERNMENT)
26. MAFF wishes to promote organic farming,
as do the proponents and potential beneficiaries of organics,
but there is no "new" money on the table for research
and development, despite there being a clear need to understand
and underpin systems and protocols for production. Some of this
will require new research, but there is also a need to appraise
the organic industry of the vast amount of information generated
for conventional production which they could legitimately use
within their self-defined regulations (eg adjusting sowing dates
to reduce the incidence of carrot root fly attack).
27. The MAFF organics R&D budget (currently
c £2 million for all sectors) is, and will continue to be
heavily focussed towards environmental impacts. This does not
provide much scope for strategic, production-targeted R&D
aimed at improving yields, quality, efficacy of disease control
and overall efficiency. It is somewhat counter to the stated policy
of Government of increasing organic production in the UK.
28. In much of the fruit and vegetable sector,
the economic burden of the conversion period is the major economic
constraint to organic production systems. An official "in
conversion" category, with modest premiums to balance substantial
yield and quality reductions would assist many growers alongside
additional government subsidies. Retailers find it difficult to
market such fruit alongside a plethora of other quality assurance
schemes.
OUTLETS AND
DISTRIBUTION SYSTEMS
FOR ORGANIC
PRODUCE AND
RETAIL PRICING
29. "Hard-line organic growers",
who are interested in organic production primarily as a lifestyle,
often prefer to market produce locally through box schemes, local
shops and farmers markets. This approach should be encouraged
to increase local, often rural employment and reduce food miles.
However, it would be difficult to satisfy the large national demand
in this way. Hence selling to major retailers is likely to be
important for larger-scale organic producers. This can be difficult
as the culture of large retailers is often counter to the organic
ethos; cosmetic quality is very important as is consistency of
supply. These problems may be overcome by supermarkets perceiving
and marketing organic produce as a speciality product. Appointing
an individual, as Sainsbury's have, for example, with responsibility
for sourcing and marketing all organic produce may be an effective
way forward. It is likely that supermarkets will have to adopt
a more flexible economic approach to organic growers, perhaps
developing partnerships through conversion periods, for example.
30. It is important that organic produce
retains its premium price in order to pay for the increased cost
of production. However, the current premium of over 100 per cent
in some cases for fruit and vegetables must ultimately limit the
market. Premiums of between 10 per cent and 30 per cent, as on
continental Europe should increase sales and meet additional production
costs.
LEVEL OF
IMPORTS AND
EXPORTS OF
ORGANIC FOODS
31. Prices for organic foods are under pressure
due to imports (80 per cent) allegedly grown under less stringent
criteria, hence achieving higher yields, better disease and blemish
control for transportation, and greater shelf-life. Will it continue
to be profitable for UK producers in the future, without further
subsidies?
32. It is important to bring down the current
level of imports of organic fruit and vegetables for two reasons:
import substitution and reducing food miles. With the application
of appropriate research and development to organic production
systems, there is no reason why the UK could not ultimately export
certain commodities.
33. In some crops, such as hops, it is considered
by experts that the UK will be unable to convert to organic. Hence
hops for UK organic beer are being grown in South America where
climatic conditions and certification standards permit. Will the
organic lobby and media effects on consumer opinion thus signal
the end of the UK hops industry?
INTERNATIONAL COMPARISONS
34. There is not a level playing field throughout
Europe. There are wide ranging levels of grant-aid support for
conversion in different European countries. In addition, European
organic standards differ between countries. For example, plant
extracts used to deter insect pests such as pyrethrum and Quassia,
are permitted in several European countries, but not approved
by the PSD in the UK. Granulosis virus, again for insect pest
control, although on the Soil Association's approved standards
list is not approved by MAFF PSD, and is therefore unavailable
to UK growers. There may also be implications for UK importers
of organic produce from other European states; organic produce
may not conform to UK organic standards.
35. Regulations and definitions for organic
certification are clearly not consistent throughout Europe, or
elsewhere. The UK seems to set the "gold standard" for
extreme intolerance, inflexibility and regulatory zeal, once again.
Plant extracts and field steaming are permitted for weed, pest
and disease control in some countries in Europe, but not in the
UK. (For possible implications on environmental biodiversity of
these techniques and soil-flaming in the UK, see "Further
Research" below.) In the UK, plant extracts must be tested
and approved in the same way as other pesticides by the Pesticides
Safety Directorate. Funding is a problem; but one possible way
to raise money for efficacy testing and PSD registration could
be to levy a tax on those who profit by promoting organic produce.
36. The degree to which EU governments promote
organic farming is not uniform. Several European countries have
well funded research establishments with programmes dedicated
to organic research and promotion, eg at the Louis Bolk Instituut
in the Netherlands and FiBL in Switzerland. The effects of these
differences selectively disadvantage the UK organic producer and
provide less incentive for conventional producers in the UK to
covert.
37. Multiple retailers are increasing pressure
to reduce the premium prices enjoyed by organic produce to the
levels of conventional foods, as seen in the Netherlands. The
standards and protocols applied in other countries should be studied
more closely as little information seems to be available and speculation
prevails.
FUTURE DEVELOPMENTS
(HORIZON SCANNING
AND AREAS
FOR FUTURE
RESEARCH)
38. There is an urgent need to look at safe
composting, the use of animal manures and the potential spread
of disease.
39. It is fallacious and incredible to promote
the notion that organic is chemical/pesticide free. Although obviously
little publicised, organic production permits the use of pyrethroids,
crystals of Bt toxin in killed bacterial sprays, toxic copper
compounds, sulphur, potassium soaps, rock phosphate and lime,
but curiously not nitrates—even if they are nitrate ores
from the Peruvian desert!
40. An issue of particular concern to plant
pathologists, and epidemiologists, is the likely increase in inoculum
pressure of fungal and bacterial spores, viruses and their invertebrate
vectors if (or when) the balance between organic and conventional
farming shifts towards the former. Lack of appropriate and effective
disease control inorganic crops will require increased pesticide
usage on neighbouring conventional farms. Mathematical modelling
and scaling in non-linear algorithms could be applied to predict
the critical threshold of organic field areas and patterns, crop
types and genetics, pests and pathogens, and prevailing climatic
conditions that would give rise to major epidemics of old (and
new) agricultural diseases.
41. The approval, by organic certification
bodies, of large-scale soil sterilisation by flaming, using large
methane burners to control weed seeds gives serious cause for
concern. First, the creation of large pulses of CO2 (a greenhouse
gas) not only derived from the fuel burned, but also from the
cremation of all organic matter (living organisms and dead humus)
in the soil, to an unknown depth. Second, the effect of this process
on overall soil biodiversity, beyond effects on the weed seed
bank. Insect larvae (beneficials as well as pests), nematodes,
earthworms, fungi, and micro-organisms (there are estimated to
be millions of bacteria, representing tens of thousands of species
in every gram of good soil) will be killed. What is the recolonisation
profile and process? It is therefore deeply misleading to say
that organic production necessarily assists biodiversity. It may
increase weeds, pests and pathogens above ground, but the chemicals
and protocols approved for extensive use in commercial organic
production systems clearly have detrimental effects as well. Yet,
in a recent MAFF call for proposals to undertake an "Economic
Evaluation of Organic Farming Schemes" (RU0102/3), paragraph
2 of the background text states: "Organic farming provides
benefits to consumers in the form of food which is perceived
to be of higher quality. There is some evidence to suggest
that, through the virtual absence of pesticide use, it also
benefits wildlife and biodiversity by allowing more plants
and invertebrates to flourish, thus providing food for birds and
mammals."
42. When combined with higher labour inputs,
lower yields (as low as 50 per cent for wheat, for example—Boarded
Barns Project) and more extensive land requirements, the balance
sheet for organics should certainly be more thoroughly researched
and transparent.
43. There is no evidence that organic produce
is more "wholesome" or of better quality than that grown
conventionally. Indeed, the former often has a greater incidence
of pests and diseases and a shorter shelf-life than the latter.
There is some evidence that organic produce is sweeter, but this
is almost certainly because it has been grown under nutrient-limiting
conditions, when plant assimilates (including sugars) are used
to sustain turgor pressure. There is nothing special about this.
Similar observations apply when inorganic fertilisers are reduced
or withheld in conventional production. It would seem therefore,
that investigations are needed to evaluate such claims by organic
practitioners and supermarkets to determine whether organic produce
is indeed of better quality.
44. Further research funding is needed to
evaluate fully the environmental impacts of alternative production
methods. Advocates of organic farming generally claim that it
is kinder on the environment than conventional methods. On balance
this may be true in the long-term, because crops are often grown
with lower (although less benign) inputs, but this assertion has
yet to be proved. In fact there are particular times in organic
rotations which pose potentially high environmental risks. For
example, the large release of nitrate following re-incorporation
of a fertility building crop (or green manure) into the soil.
On behalf of my expert colleagues who provided
much of the text above, may I wish the Agriculture Committee well
in its study of "Organic Farming". We believe that only
facts, knowledge-based regulations, specifications and protocols
can provide a safe, profitable and transparent future for this
sector of farming.
9 June 2000
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