ORGANIC CERTIFICATION IN PUERTO RICO
by Sadhu Govardhan / President
Fundacion Oro Verde
The issue of organic food
certification has received a surprising level of attention in Puerto
Rico as of late.
On Dec. 2, 2007, El Nuevo Dia published “Debate en el Campo Organico,”
which largely misrepresented the actual views of organic farmers in
Puerto Rico; this stirred unnecessary controversy and resentments in
the organic community.
On January 28, 2008, El Nuevo Dia published an article “La Cultura de
lo Organico,” where the topic of organic certification and its
problems was briefly touched upon.
Why is this sudden interest about implementing a certification process
for organic farmers so surprising?
For decades, the local government and one of its executive branches,
the Department of Agriculture, have shown no interest in supporting
organic agriculture. While the government supplied conventional
farmers with toxic fertilizers, herbicides and pesticides, organic
farmers did not receive any materials or support at all. In fact, the
very concept of supporting organic farming simply had no place in
But there is another, even more surprising fact: Puerto Rico’s
agriculture hardly produces any food – only 6-8% of the food consumed
in the island is locally produced. Out of this already minimal
percentage, not even 0.01% is produced organically. A recent survey of
organic farmers around the island, conducted by Magha Garcia, showed
that only Puerto Rico has only about 30-40 organic farmers. Only four
or five of those farmers produce significant amounts (over $12,000
yearly) of organically grown food.
Why, then, try to implement an organic certification law that
potentially has much more far-reaching consequences than an uninformed
person would generally assume? In order to make any answer
understandable, we need to look at the history of the organic
1) BRIEF HISTORY OF THE ORGANIC MOVEMENT AND ORGANIC CERTIFICATION
PROCESS Globally, agricultural practices were primarily organic
for thousands of years. However, insecticides were already used over
2,500 years ago—mostly sulfur. By the fifteenth century, western
“developed” countries began to apply toxic compounds like arsenic,
lead and mercury to their crops. It took almost 500 years before
people in these cultures realized that the staggering amount of human
poisoning was caused by these non-degradable toxic metal compounds.
In the early twentieth century, great agricultural thinkers like
Rudolf Steiner, Sir Albert Howard, Lady Eve Balfour and others urged
people to turn away from unsafe and unsustainable farming practices.
In the late 1930’s, however, the first of the second generation
pesticides—DDT—was discovered and celebrated as the “ultimate victory”
over pests. This was a major setback for natural farming practices
promoted at that time. Hardly anyone dared to question the new miracle
pesticide at first, but after the publication of American journalist
Rachel Carson’s environmental classic, Silent Spring, the truth about
DDT eventually became public. Today, we know that the use of DDT in
agriculture was one of worst mistakes made in its long history.
As a reaction to the severe worldwide environmental damage that
synthetic pesticides like DDT caused, a movement of conscious farmers
formed in the 1960s within the United States. These primarily small,
independent farmers soon became known as “organic” farmers, and the
“organic movement” was born. Their approach to food marketing was
mostly localized: small farmers’ markets, restaurants, and direct
visits to their farms. They established close relationships with
consumers, and thus their organic “certification” was based on trust.
They coined slogans such as, “Know Your Farmer, Know Your Food”. For
decades, both the consumers and small-scale organic farmers were
happy—but it wasn’t meant to last for long.
Mainstream agriculture continued to provide over 99% of the U.S.
population with “conventionally” grown food. The organic movement went
unnoticed for some time until the 1980’s, when factory-like
agribusiness farms noticed there was an increasing interest in organic
food. Their first reaction was to discredit the organic movement and
to push it out of contention, but their attempt largely failed.
Eventually, various groups approached the U.S. government and demanded
restrictions for organically grown produce.
At first, the government made an attempt to define the term “organic.”
In 1980, a team of scientists appointed by the USDA concluded that
there was no universally accepted definition of “organic farming.”
Their report stated:
“The organic movement represents a spectrum of practices,
attitudes, and philosophies. On the one hand are those organic
practitioners who would not use chemical fertilizers or pesticides
under any circumstances. These producers hold rigidly to their purist
philosophy. At the other end of the spectrum, organic farmers espouse
a more flexible approach. While striving to avoid the use of chemical
fertilizers and pesticides, these practitioners do not rule them out
entirely. Instead, when absolutely necessary, some fertilizers and
also herbicides are very selectively and sparingly used as a second
line of defense. Nevertheless, these farmers, too, consider themselves
to be organic farmers.”
Not satisfied with this nebulous definition, the Passage of the
Organic Foods Production Act (OFPA) forced the USDA to develop an
official definition. Although the USDA was opposed to the passage of
the act, the USDA Agricultural Marketing Service eventually proposed
rules for a National Organic Program. Their first published rules led
to an outrage amongst representatives of consumers and the health-food
industry because they permitted up to 20% of animal feed from
non-organic sources, antibiotics for raising animals, genetic
engineering and irradiation. The final regulations, published 2002,
eliminated these provisions. The revised rules went into effect on
October 21, 2002. The latest USDA definition states:
“Organic food is produced by farmers who emphasize the use of
renewable resources and the conservation of soil and water to enhance
environmental quality for future generations. Organic meat, poultry,
eggs, and dairy products come from animals that are given no
antibiotics or growth hormones. Organic food is produced without using
most conventional pesticides; petroleum-based fertilizers or sewage
sludge-based fertilizers; bio-engineering; or ionizing radiation.
Before a product can be labeled “organic,” a Government-approved
certifier inspects the farm where the food is grown to make sure the
farmer is following all the rules necessary to meet USDA organic
standards. Companies that handle or process organic food before it
gets to your local supermarket or restaurant must be certified, too.”
A year later, in August 2003, a similar law regarding organic products
passed in Puerto Rico. If one compares the laws, it becomes clear that
the P.R. law is a much-abbreviated and far more ambiguous version of
the original U.S. law. As with most agricultural laws blindly copied
from the U.S., no attempt was made to study the complexity of the of
certification issue, and the reactions it has caused worldwide. Nor
were the unique aspects of tropical agriculture taken into account.
2) THE PURPOSE OF CERTIFICATION
Organic certification is intended to assure quality and prevent fraud,
and to promote commerce. Such certification was not necessary or
required in the early days of the organic movement, when small-scale
farmers had a direct market and the trust of their customers. By
today, organic food is increasingly produced and distributed by large
corporations (like Dole, Kraft, or even Coca Cola). This means that
the consumer and farmer have been separated by the food industry, and
the consumer now relies on a third party for certification.
3) THE CERTIFICATION PROCESS
Globally, certification bodies are either non-government or government
regulated. In order to certify a farm through the USDA, the farmer is
required to study and follow new and additional regulations:
a) study the organic standards, including farming practices, storage,
transport and sale.
b) comply with farm facility standards and production methods, which
may involve additional investments in case facilities have to be
modified or new suppliers have to be sourced.
c) he has an additional load of paper work, detailing farm history,
current set-up, get soil and water tests done.
d) he has to write an annual production plan, detailing every aspect
from acquiring seed to sale; he has to reveal his seed sources, detail
his field and crop locations, explain his fertilization and pest
control plan, harvest methods, storage locations, etc.
e) he has to get his farm inspected annually; the inspection includes
a physical tour of the premises, examination of records and inquiries.
These inspections can be on short notice, or even unannounced. Not
only is this highly unjust but also unconstitutional. Even a police
officer cannot enter a property without permission or authorization by
a judge. While conventional farmers have no standards that they are
held to, the law treats organic farmers like criminals.
f) he has to pay an annual fee (depending on size of operation and
amount of crops). This fee can be anywhere from $500 to over ten
thousand dollars per year. A conventional farmer has no inspections,
and hence no fee to pay.
g) keep a day-to-day record of farming practices and marketing. In
short, the more diversified his operation is, the more demanding the
While uninformed people tend to believe that government-controlled
certification sets the highest standard, this is not always true in
reality. Often these certifying agencies have the lowest standard, but
are still the most expensive and bureaucratic. Many USDA-authorized
inspectors have been noted to be poorly educated in organic
cultivation; their visits are often focused mainly on examining
paperwork, rather than on analyzing the actual quality of soil, water
As a reaction to the high fees and for many small-scale farmers
burdening bureaucratic demands and invasive inspection methods,
non-government organizations have offered a higher quality service for
less money and a minimum of paper work.
One of the most successful alternative certification bodies for
small-scale farms in the U.S. and the U.K. is the non-profit
organization CNG (Certified Naturally Grown). Their members only pay a
recommended $50 per year. Their members are required to inspect at
least one other farm in their area per year.
In Puerto Rico, the process of organic farming inspection has been
practiced for several years already. The process was initiated by one
of the islands most important organic groups, the Cooperativa Madre
Tierra, and carried out by the agronomer Dalma Cartagena. The yearly
certification fee for the farmers is $60. The original certification
standards were USDA-based, but there is consideration to apply IFOAM
(International Federation of Organic Agriculture Movements) standards
because they are an independent organization and have more experience
in dealing with South American countries and the Caribbean.
Additionally, IFOAM policies about organic agriculture include
concepts like social justice, fair trade and ethics amid the health
and environmental considerations.
4) CERTIFICATION ISSUES
Needless to say, the certification issue is complex and has caused
serious concerns and problems. In a nutshell, here are some essential
Problems with the Term “Organic”
The term “organic” was originally coined by people who had a very
different understanding of organic farming than as the industry it has
become today. To them, organic farming was a holistic process that
included essential factors like the cultivation of highly diversified
crops, open-pollinated cultivars, and healthy living soil—as well as
using sustainable resources, strictly avoiding hazardous chemical
pollution for humans, plants, animals, water and soil; promotion of
biological and genetic diversity, locally grown produce (in contrast,
the average food item in today’s world travels about 1600 miles from
farm to plate), and other features that the current organic industry
Unknown to most, the term “organic” has undergone serious changes,
some of them so fundamental that the word itself has become ambiguous.
Many of the “original” organic farmers are disturbed about the usage
of the term for two main reasons:
According to them, their originally pure term has been stolen by the
USDA and been sold to large corporations. Only if an operation or
certification body is USDA-approved can the term “organic” be
officially used by a farmer. That means that even organic farmers who
have produced at a very high standard for decades, can no longer use
the term which they themselves conceived, developed and have
The large-scale farming industry has doubly injured small-scale
farmers by appropriating their own terminology, and then pushing them,
along with their high ethical farming principles, aside. While people
still think that they get “the good food” produced by what they’ve
come to know as “organic farmers”, most of foods marketed today as
organic have been produced by large farm factory corporations that
adhere to conventional monoculture principles—which have been the very
cause of most of the problems conventional farming is encountering.
In summary, the current USDA organic certification process is nothing
but the result of the commercialization of the term “organic”.
Favoritism Toward Specialized Agribusinesses
Another issue of concern is that the certification process favors
large corporations who only grow a very limited number of crops. For
them, paperwork is not only simplified (because they are not
diversified) but they also can afford to pay someone just to take care
of the required paperwork. An issue that has plagued the legislators
since they started to implement laws regarding organic products is
that corporations are pushing to have non-organic ingredients allowed
in “USDA organic” labeled foods. As of now, there are already 38
non-organic ingredients that the USDA is proposing to allow. America’s
largest beer marketer, Anheuser-Busch, is currently petitioning to get
conventionally grown and pesticide laden hops to be an authorized
ingredient in their “organic” beer.
A problem in this regard is that the USDA itself does not appreciate
the benefits of organically grown food. According to them, “organic
agriculture can not meet the world’s food needs,” and, “no
distinctions should be made between organically and non-organically
produced products in terms of quality, appearance, or safety.”
It is not surprising, therefore, that many critics of the USDA
certification process are worried about the USDA selling out to Big
Ag. After all, major industrial corporations like Monsanto, Cargill,
ADM and others have already succeeded in changing the very foundations
of agriculture and the food industry. Because of that, the term
“USDA-approved” means as little to many critics as “FDA-approved.”
Many people wrongly assumed that FDA-approved drugs are safe, but each
year prescription drugs sold in the U.S. injure 1.5 million people so
severely that they require hospitalization, 100,000 of whom die—making
prescription drugs a leading cause of death in the U.S. (Source: Oro
Verde – Securing the Future of our Food).
Anyone taking a closer look at the ingredients in the most popular
foods sold worldwide, will note that they contain dangerous substances
like high-fructose corn syrup (used in breads, soft drinks and other
processed foods; it has been positively linked to liver damage and
increased blood cholesterol levels, diabetes and obesity),
hydrogenated oils (found in almost any fat-related product; they are
linked to cancer, birth defects, heart disease, diabetes and liver
disease), or aspartame (an artificial, chemical sweetener commonly
found in countless products; by many considered to be the most
dangerous food additive on the market today; it is directly linked to
a host of diseases, too long to be included here). Nevertheless, these
and hundreds of other dangerous substances are approved by the FDA.
Another recent public outrage in this regard is that the USDA and the
FDA are opposed to the labeling of genetically modified food (about
60-70% of food sold in Puerto Rico contain genetically modified
substances) although 90% of the American public demands it.
It is therefore not astonishing that, “FDA approved” or “USDA
approved” are labels that don’t mean much to conscious consumers or
farmers. What these approval processes have in common is that they
suppress small-scale producers and favor large corporations who have
proven to always succeed in dangerous manipulation and pollution of
Problems of Cross-Contamination
An issue that is particularly complicated regarding organic
certification is that pure environments become virtually non-existing.
Organic farmers have increasing problems with surrounding
contamination by various industries, other farmers who use toxic
agrochemicals, and genetically modified crops that can destroy
open-pollinated strains that were carefully protected by generations
of conscious farmers. The same government that now wants to exert
increasing control over organic farmers, has sold systemic pesticides
that can stay up to several decades in the ground or in trees and that
have caused countless cases of cancer and other farm-related diseases.
These variations in purity warrant the specification of many levels of
organic standards. As of now, the USDA only recognizes 3 levels: “100%
organic”, “organic” and “made with organic ingredients,” and none of
them necessarily reflect truly organic cultivation practices. In order
to earn the faith of farmers and consumers, governments and their
agencies have to step up to the level of the same integrity they
expect their citizens to exhibit.
In Article 2 of Public Policies, the current P.R. law #228 (Ley de
Productos Organicos de Puerto Rico), the law makers “declare that they
follow a policy of promoting organic agriculture due to its benefits
of protecting the environment, soil, water and other natural resources
as well as the health of the people.” However, every organic farmer
knows that the same government has never supported organic farming in
any direct or indirect way. The law was passed in 2003, without
discussing it with local organic farmers or professionals who have
studied and practiced the issue for decades.
It is now February of 2008, and local organic farmers have still
received zero support from government agencies. Not only that, the
higher educational system (with the main faculty of agriculture in the
UPR Mayaguez campus), has never given students even the option to
study organic agriculture. It is clear that something simply does not
add up. When the law was passed in 2003, the plan was to create a
Board of Advisors to the Secretary of Agriculture. This board has
never been created. The five members of this board were supposed to be
composed of: - an organic producer - an organic product retail sales
person - a consumer representative - a representative of the Colegio
de Ciencieas Agricolas - a representative of the general public
All of these participants are supposed to work for free (which is an
obvious obstacle for participants of the private sector). The process
of finding and electing qualified people of each category is never
explained. The president of the board is to be selected by the
Secretary of Agriculture, but it is not explained on what basis. There
is no point of having people on the board who have no actual organic
There are many both minor and major flaws with this law and with its
subsequent regulations, which could have been avoided if it had been
written by more qualified people. The law was written for corporate
farm operations, not for small-scale farmers. Whenever a law is
passed, it is essential that it is passed for the benefit of the
people concerned. As of now, the law and regulations are mostly an
additional burden in the already difficult life of organic small-scale
RECOMMENDATIONS TO ORGANIC SMALL-SCALE FARMERS AND CONCERNED
CONSUMERS OF PUERTO RICO
The topic of certification is more complex than it may look at first.
However, the few existing organic farmers and restaurants are faced
with the issue, and will have to deal with it at some point.
Here are some thoughts and recommendations that may help to improve
the situation or at least avoid further injustices.
* The history of the barely-existent organic movement in Puerto Rico
has shown a lack of unity and networking. Once the island’s various
small organic organizations and farms cooperate and unite, they will
become a potent force—not just to legally defend themselves, but also
to seriously increase their organic food production.
* As of now, only farmers who produce less than $5,000 worth of
organic produce annually, are not required to get certified but are
still allowed to market their products as “organic.” It is obvious
that this cap is inappropriate. Which farmer (or person in general)
can live on a gross income of $5,000 a year? You can ask legislators
to change that amount to at least $12,000 per year.
* Once united, you can demand subsidies for certification fees and a
decrease of bureaucratic and unnecessary paper work. Certification
fees should be waived for people who grow less than $12,000 worth of
produce yearly. While large corporations make considerable profit with
organic products, small-scale farmers generally do not make more
profit than conventional farmers because their expenses are much
* Help advocate for alternative certification processes. There are
many well-functional models already established worldwide, including
the inspection protocol currently used in Puerto Rico.
* If you do not want to deal with the certification process at all,
change your labels or advertisement to: “produced without pesticides”
or “produced without synthetic chemicals”, etc.
* Since it is most likely a hopeless endeavor to reclaim the term
“organic”, it seems best to coin a new, alternative term that
describes products based on the original meaning of the term
“organic.” Once the small-scale farmers agree upon that term, it is
important to legally protect it so that only small-scale farmers with
diversified food crop production can have the right to use it.
Inspection and certification fees should under no circumstances exceed
* Create a board with organically (in the true sense of the word)
trained people in order to promote organic agriculture more
effectively and also to respond faster to misinterpretations, unfair
attacks or further distortions of the work and reputation of people
who grow truly organic food.
* Stay updated. There are many fantastic websites that explain all
related issues in depth.
From my own perspective, the timing of legislating organic
certification in Puerto Rico is premature, counter-productive and
distractive from the real problems we have. Puerto Rico’s agriculture
has been facing serious problems for many years already: we are losing
farmable land on a daily basis; the number of farms and farmers is
steadily decreasing; the percentage of local food production is one of
the lowest globally; farming as a profession is in danger of
It would be wiser to instead focus on improving and re-designing
Puerto Rico’s agriculture: to move toward a sustainable, diversified
agricultural future and tap into the enormous agrarian potential this
island actually has. This move requires full financial and educational
support by the government, and not be – as currently proposed by the
government – another burden the small-scale farmers will have to carry
I feel badly for customers who think that they buy a good product
whenever they buy something that is “USDA certified organic.” Instead
of supporting true organic farming, those customers are often
supporting corporate agriculture that has no interest in crop
diversification and an organic, sustainable lifestyle. Their only
interest is profits. They have already managed to push small-scale
organic farmers out of the bigger picture by taking over the organic
market. Do we really want to support International corporate giants
like Dole, Walmart or Costco? (Don’t be surprised if McDonalds or KFC
will be next). Or would we rather support small, local farming
communities, many of which lack the resources to obtain organic
certification? It took corporate agribusiness less than a decade to
push small-scale farmers aside, and it will not take long before they
will crush them completely. There are already talks about some of
these corporations buying up large areas of land in Puerto Rico.
Organic heirloom seeds are already getting scarce, and the first
original organic seed companies are already bought up by larger
corporations. (“Seeds of Change,” one of the original organic seed
companies in the U.S., is now controlled by M&M/Mars; other organic
producers are being bought up by Coca Cola, General Mills, Heinz and
similar corporate giants). It does not take much imagination to
foresee what will be next.
As far as the organic certification issue itself goes, I can just hope
that it will be dealt with in a more sensitive and intelligent way
than it has been so far. Our small-scale farmers need a new, revised
law with specifications that actually benefit them and their
consumers. They have worked hard to deserve this protection, and if
there is any justice in the system, they should get it.
© Sadhu Govardhan,