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Submission to the House of Commons Agriculture Committee Enquiry Into Organic Farming

NOAH represents the manufacturers of animal medicines in the UK. NOAH’s 34 corporate members supply approximately 95% of all the animal medicines sold in the UK, and an even larger share of those sold for use on farm. Thus we inevitably regard ourselves as part of the Animal Welfare sector, taking a particular interest in the livestock sector, which currently takes about 50% by value of the animal medicines sold in the UK.

The British countryside is the product of 10,000 years of farming, and current conventional farming techniques produce affordable, high quality food whilst also minimising the negative impact on the environment. Conventional farming methods were developed as a way to solve the problems of earlier farming generations, but now many of these practices may be rejected in favour of ‘organic’ production.

While we have no objection to any farmer choosing to farm in a particular way (laws and standards permitting) we are most concerned that some proponents of organic farming tend to promote themselves by attacking the conventional 97% of farmers – accusing them of abusing animals, poisoning consumers and the environment.

Organic farming is widely perceived to be a ‘Good Thing’ and it may be predicted that the majority of those responding to your enquiry will be supporters of ‘Alternative’ agriculture who will urge that organic farming should be given greater political and financial support. We beg to differ, and to suggest that in four important ways those promoting organic farming have the potential to do enormous damage – indeed much damage may have been done already:

  1. Public confidence in farming and in the process of regulation as laid down by Parliament has been undermined.
  2. Animal health and welfare could be jeopardised by restrictions on medicine usage
  3. Misleading the public with claims that organic food is ‘healthier’, tastes better, is better for the environment.
  4. Sustainability and the ability to feed future generations.

(Some of the information in this submission is based on quotes from research – more details can be found in Appendix 1).

1. Public Confidence

The last decade, or more, has been notable for a change in public attitude to farmers and farming – farmers are no longer seen as providers of the food we need to survive, but as rapists of the countryside – destroying the environment, poisoning wildlife and people, abusing their animals – and all for ‘profit’. It is no coincidence that this is the message, the ‘knocking copy,’ which has been used by organic proponents such as the Soil Association to promote their method of farming, (the fact that organic farmers also make a profit is seldom mentioned, although for many of the system’s newest recruits it is a major attraction).

Organic organisations have been particularly harsh in their criticism of agricultural inputs: agrochemicals, fertilisers and animal medicine. Such criticism ignores the stringent controls required under EU and UK law, and, in the process, public distrust of science and of government regulation has also grown.

For over thirty years Animal Medicines have been regulated, under laws first laid down by the Callaghan Government’s Medicines Act 1968. This law, and its subsequent updating by UK and EU law, requires a Medicine to be of high quality, effective and safe to animals, users, the environment and the consumer. Equivalent laws apply to crop chemicals. However, organic organisations prefer to pick and choose which products may be used – by implication rejecting the systems of public protection laid down by parliament and the expertise of the officials and scientists appointed, under law, to administer them.

The simple message of organic organisations is that only they know best, and in so doing they happily and consciously denigrate the work and ethics of the vast majority of decent farmers and government employees.

The current crisis of confidence in farming and Regulation is clear evidence of the success of organic publicists.

2. Animal Health and Welfare

Veterinary treatment in organic systems raises some serious animal welfare concerns.

Firstly the use of unregulated homeopathic and herbal remedies, as opposed to strictly regulated conventional animal medicines, raises questions over the safety and efficacy of the product and its likely effects on the animal and the consumer of the animal treated. Unlike regulated animal medicines, there is no system for setting withdrawal periods for unlicensed homeopathic, herbal or other ‘alternative’ remedies.

The requirement in EU and UK Organic regulation to automatically double withdrawal periods for animal medicines is illogical, unscientific and a potential threat to animal welfare. MRLs and withdrawal periods for licensed medicines are based on rigorous, independent, international scientific standards incorporating massive safety factors. There is no logic to a ‘blanket’ doubling which takes no account of the properties of the individual product. Such additional delay could prompt a farmer to withhold treatment of an animal near to market (or to cheat).

The organic insistence on using medicines therapeutically (as opposed to preventative treatments), means that the animal has to get sick and suffer before it is treated, whereas preventative medicines would have prevented the suffering from happening at all. While symptoms develop there is also an increased risk of the sick animal passing infection to its fellows, further increasing suffering and increasing the total volume of medicine used. (See Appendix 1 (8.8)).

The banning of genetic modification in any form by the Soil Association raises serious concerns over the availability of medicines to treat animals. Many veterinary medicines today have biotechnology somewhere in their parentage – if not in the active ingredient, then in the excipients. The use of biotechnology in veterinary medicines allows improvements to existing products, for example, vaccines, produced with the techniques of biotechnology, which can replace chemical treatments for internal and external parasites, offer considerable opportunities for environmental and operator safety and the reduction of residues. By banning GMO’s in any form farmers and vets are being denied the benefits of modern medicine developed through biotechnology.

The EU, however recognises the importance of genetic modification in the production of veterinary medicines and therefore has excluded animal medicines from the ban on GMs in their regulations.

3. Misleading the public

Organic proponents claim that organic food is healthier, tastes better and is better for the environment. (Appendix 1 [1]) A MORI survey for the Soil Association (June 1999) showed that consumers buy organic food because they believe it to be healthier, free of chemicals, better tasting, GM free and better for the environment and animal welfare and that half of those did so because they believed it to be safe and healthy.

There is no conclusive evidence to support these claims, the organic movement has been further misleading the public by claiming an exclusivity of virtue on these areas.

Scientific evidence suggests that organic food is no more nutritious or better tasting than conventionally produced food and variations depend more on other factors such as soil type and freshness of the produce. (Appendix 1 [2][5])

The safety of organic food is also questionable – recently there have been concerns over the use of animal manure which can lead to increased risk of E. coli 0157. Where chemical methods are not used to treat pests and diseases, plants under attack produce their own toxins which may themselves be harmful to humans. (Appendix 1 [3])

The safety of unlicensed and untested herbal and homeopathic remedies, listed for organic farming use, is questionable as they do not comply with EU or UK animal medicine legislation which is designed to protect consumers, animal users and the environment.

While in general fewer agrochemicals are used in organic farming some forms of pesticide are used and over 30 additives are allowed.

Imported organic food (70% of organic food in the UK) may not be GM free as the standards of organic produce vary from country to country. (Appendix 1 [6.1])

Not only can the claims not be applied to all organic farms, but equally, many conventional farms can show the same benefits, but unburdened by dogma.

Claims that organic farming is better for the environment than conventional farming is not necessarily true. While birds and wildlife are a valued adjunct to organic farming, the use of similar management techniques on conventional farms can lead to the same benefits. The more extensive methods of organic farming means it requires more land to produce a given amount of food than a conventional farm. Thus, to institute organic farming countrywide to provide the required amounts of food, a large amount of wilderness, hedges and woodland would be have to be utilised. This questions the sustainability of organic farming. (Appendix [7])

4. Sustainability

The fundamental principles of sustainability are, we believe, clear, and may be summed up as the careful use of all resources, and in particular of non-renewable resources; for agriculture this includes both on-farm resources (such as the land itself) and purchased inputs such as fossil fuels, mineral fertilisers and equipment, as well as the latest technology. Farming must be able to sustain itself, to plan and invest for the future, to change and improve outmoded and outworn equipment, products and practices. This can only occur if British agriculture is allowed to remain efficient and profitable.

The use of animal medicines in agriculture not only reduces suffering, and prolongs useful life, but healthy animals invariably produce more efficiently and perform better, so utilising less feed and other resources.

For organic farming to remain sustainable it must also be profitable. Organic livestock production requires organic inputs, notably fodder and feed grains. Producers of such organic crops themselves expect higher premia – can organic livestock producers continue to produce profitably as produce prices drop, approaching those for conventional farming, if their input costs rise?

Organic produce prices cannot avoid the law of supply and demand – as organic production increases, prices must fall – supermarkets have declared their intention to supply Organic food at equivalent prices to conventional farming. These lower prices will inevitably be passed back to organic producers.

Thus organic producers are increasingly being caught in a pincer – on the one hand steady escalation of standards by organic organisations, for example by increasing the proportion of organic inputs (which cost more to produce) on the other hand, increased supplies and supermarket buying powers will reduce prices received – the net result is likely to be that those who have converted to organic production for commercial rather than philosophical reasons are likely to be disappointed.

It must also be recognised that today’s organic farms, both livestock and arable, benefit from the eradication and control, by conventional means of many pests and diseases over many years. They also benefit from being surrounded by a ‘cordon sanitaire’ of clean, conventional farms. If the organically farmed area was to spread, would existing controls break down and the artificiality of organic disease control methods be exposed?

Thus we believe that the assertion that organic farming is “sustainable” should be seriously questioned.

Research

Organic supporters frequently call for special funding and emphasis to be given to “organic” research. Such demands would appear to be based on a number of misconceptions.

  1. Much of MAFF’s research is into “generic” activities which could apply equally to conventional and organic production.
  2. Similarly, commercial research into agricultural equipment, conventional breeding of plants and animals, animal feed etc. is equally applicable to both sectors.
  3. Research into animal disease carried out by universities and other quasi-official institutions is applicable to both, as is most of the commercial research carried out by animal medicine companies.
  4. MAFF research into animal medicines is predominantly into methods of public protection, such as residue testing, which is again of general benefit. Furthermore, much of this is paid for by levies on industry rather than from the taxpayer.
  5. We believe, however, that there is a case for more research to be devoted to an open-minded investigation of some of the claims made by organic farming, in order to ensure proper protection of the public, both as purchasers and consumers.

Assurance Schemes

In the Committee’s call for evidence, comment is invited on assurance schemes - such schemes are increasing in all sectors of farming and we particularly welcome the launch of the British farm standard, backed as it is by strict and independently enforced rules.

It could be argued that through such schemes conventional farming provides most of the elements of ‘Public Good’ for which the organic movement has tried to claim exclusivity - Animal welfare, environmental protection, food safety. Assurance schemes should, we believe, acknowledge and build on the legal controls and codes which already exist - Medicine and pesticide licensing, welfare and performance codes - such as the Code of Practice for the Responsible use of Medicines on farm - launched by Nick Brown last year, and the RUMA (Responsible Use of Medicines in Agriculture Alliance) Antibiotic guidelines.

We applaud the increasing maturity of Farm and Food Assurance Schemes; gone are the early problems such as claiming meat to be “hormone free” (which is biologically impossible, and also ignored the fact that the use of Growth Promoting hormones has been illegal throughout the EU since 1986)

We also welcome the ending of competitive and often meaningless claims that food from a particular scheme is “healthier” or from “happier animals.”

Sadly, the organic sector continue to employ such negative marketing methods, which are currently the subject of a complaint to the Advertising Standards Authority.

Conclusion

Under the circumstances outlined above, we cannot agree with those who argue for additional funding for organic farming. We believe that public support for agriculture should be applied equally to all forms of farming, and farm inputs, acceptable under the law.

We find it a peculiar contradiction of the concept of “joined-up government” that one part of MAFF is giving special support to organic farming which, by statement and implication, denigrates the work of other parts of MAFF which scientifically licence as “safe, effective and of high quality” animal medicines, agrochemicals and other farm inputs.

The continuing and unjustified attacks by organic farming organisations on the vast majority of farmers who use conventional methods is particularly reprehensible.

In continuing their support for efficient, safe and sustainable agricultural systems, the member companies of NOAH do not seek to restrict the farming activities of any particular sector; they do however support rigorous and fair assessments made as evidence based decisions with respect to veterinary medicine’s role in agriculture.

APPENDIX 1

Research on Organic Farming

In the United Kingdom, demand for organic food is growing at over 40 per cent a year. (3)

1. Consumer attitudes towards organic food

1.1 A MORI survey for the Soil Association (June 1999) showed that consumers buy organic food because they believe it to be healthier, free of chemicals, better tasting, GM free, better for the environment and better for animal welfare (13)

1.2 The MORI survey showed that over half of those who bought organic food, did so ‘because they believed it to be safe and healthy. This attitude is, presumably, based on the perception that hazards in foods derive from agrochemical additives, whereas microbes, not chemicals, are the major source of foodborne illnesses’ (16)

1.3 These attitudes have been based on the information available to consumers, some of which is very misleading.

Examples include:

1.4 ‘Organic food is produced from safe, sustainable farming systems, producing healthy crops and livestock without damage to the environment.’ (24)

1.5 ‘The best reason for buying organic food is simply that it tastes extremely good, but undoubtedly there are also sound health reasons for doing so.’(24)

1.6 ‘Organic food is produced without artificial fertilisers, chemicals, pesticides or genetic modification. This natural method of farming helps enrich the soil, minimises pollution and supports the environment.’ (24)

1.7 ‘Food produced by organic methods is nutritious, healthy and safe. Organic farming relies principally on the application of animal manures, the rotation of crops, and in our case the growing of clover to provide the nitrogen for its accompanying grasses. No artificial fertilisers, insecticides or herbicides are ever used. This encourages the establishment and well being of both flora and fauna. We rely on homeopathic medicines for ourselves and our stock, no antibiotics or other drugs are used routinely.’(14)

1.8 However there is no conclusive evidence to support many of these claims. There are a range of positive and negative factors to organic farming, as there are with conventional farming. In organic farming positive factors have been heavily promoted, but the negative factors have been ignored.

2. Is organic food healthier than conventionally produced food?

2.1 The MORI survey (13) showed that over half of those who bought organic food, did so because they thought it was safe and healthy.

2.2 As far as nutrition is concerned, the evidence suggests there is little difference between the two types of food:

2.3 ‘Although there is some evidence of differences between organic and conventionally produced foods, there is not great deal of evidence that these differences represent differences in food quality....The significance of any such differences for health depends upon the proportion of the diet derived from the particular product and, indeed, the other constituents of the diet.’ (11)

2.4 ‘There is no evidence whatever to indicate that chemically fertilised plants are less nutritious than non-fertilised.’ (25)

2.5 ‘Organic foods are certainly not more nutritious. Experiments conducted for many years have found no difference in the nutrient content of organically grown crops and those grown under standard agricultural conditions.’ (2)

2.6 ‘There is no scientific evidence at this time to suggest that organically produced foods are more nutritious’ (21)

2.7 ‘Jeanne Goldberg PhD, RD, an associate professor and director of the Center on Nutrition Communication at Tufts University in Medford, Massachusetts says “Nutritionally speaking, there is absolutely no evidence that organic is better, you’re not going to get any more vitamins and minerals in a peach or strawberry grown with manure than you will in one grown with commercial fertilisers”’ (10)

2.8 ‘We have not found consistent and valid reports of differences in the mineral contents of organic and conventional foods. An early report (4) of differences in mineral content between vegetables grown on widely differing soil types has commonly been misquoted as evidence for the benefits of organic production. There are many factors, environmental and cultural, that influence the nutritional composition of produce and that are not unique to either cultural system’ (16)

2.9 ‘Investigations both in Europe and in the US have failed to find any difference between organic food and other food in terms of all the major constituents, minerals and vitamins.’ (27)

2.10 However, one study has actually shown processed organic products to be less healthy than their conventionally produced equivalents:

2.11 A Sunday Times study has revealed that compared with ordinary products, many processed organic foods contain higher levels of fat, sugar and salt - all of which can cause heart problems (5)

3. How safe is of organic food?

3.1 ‘There is no conclusive evidence that organically produced food is safer or less safe than that produced conventionally.’ (11)

3.2 However, there have been particular aspects of organic farming and food that have raised concerns over safety:

3.3 Prof Tony Trewevas of Edinburgh University’s Department of Cell and Molecular Biology was quoted as saying “Organic food is considerably less safe than we are led to believe because it depends on animal waste for its production which means a higher risk of infection of organisms such as E-coli 0157” He said that fresh lettuce, cabbage and parsley from ‘organic’ sources posed a potentially serious public health risk and went on to say: “It is just a matter of time before we see the appearance of mycotoxins in our food chain from so-called organic farming.” He also said microbial spoilage of organic food was a recognised problem and that there were no current plans to monitor the long-term effects of present day organic food.(15)

3.4 Prof Alan Gray, Acting Chairman of ACRE (Advisory Committee on Releases to the Environment) said “It was a myth that organic food was safer. You are 30 times more likely to poison yourself with organic produce because it allows Bt (the bacterium Bacillus thruringiensis) to spread directly. When ingested the bacterium produces endotoxins which attack the walls of insects’ guts. In mammals they can cause death from toxic shock.(15)

3.5 The use of farmyard manure as a fertiliser gives rise to concerns about the possible contamination of agricultural produce with pathogens (especially E. coli 0157) and the possible contamination of ground and surface water. The UK Royal Commission on Environmental Pollution in its 19th report on the Sustainable Use of Soil (1996) reviewed the use of organic materials in agriculture, including their safety. It concluded that there is a potential risk to human and animal health from pathogens in animal wastes.(15)

3.6 ‘In October of 1992, public health officials investigated several cases of bloody diarrhoea in a small town in Maine; one of the patients...died of kidney failure. The cause? Escherichia coli 0157:H7, better known as plain E. Coli... the source of the E. Coli was a fresh vegetable from an organic garden. 3 other separate cases were traced to organic lettuces, probably contaminated by E. Coli infected cow manure. In the US over 100 million tons of manure are produced per year and less than 7% is composted.’ (19)

3.7 ‘Two outbreaks of E coli 0157 in the US were traced to organic strawberries and lettuce. In Aberdeen, home-made organic goats’ cheese initiated an E coli outbreak among children; in Germany an outbreak of Citrobacter that killed one child and damaged nine others was traced to organic parsley treated with pig manure.’ (27)

3.8 ‘A study at the University of Illinois has shown that consumers eating organic produce are eight times more likely to contract E. Coli’ than those who eat conventional produce. (26)(1)

3.9 ‘Organic farmers preferably apply cow or pig manure when this is available. It can be infected with the dangerous bacterium E coli 0157 disease organism that lives happily in the guts of cattle. Infection in human beings kills, or leaves victims without functioning kidneys.’ (27)

3.10 ‘Organic farming often uses manure to grow fruit and vegetables. Manure is a natural habitat for bacteria like Escherichia coli 0157 and salmonella. Even if this food is cleaned properly, the bacteria can infect the tissue of the plant, making the risk of contracting these diseases far higher.’ (3)

3.11 ‘Citrobacter freundii lives in pigs’ guts and is also potentially lethal. If manure is pasteurised, or if you properly cook contaminated food, then the organism is killed. The problem is to guarantee that this is done.’ (27)

3.12 ‘Consumers of organic food are also more likely to be attacked by a relatively new, more virulent strain of the infamous salmonella bacteria’(1)

3.13 ‘Without fungicides to prevent infection, plants respond by producing toxins of their own’ (26)

3.14 ‘Organic and “natural” food consumers also face increased risk of illness from toxins produced by fungi - and some of these toxins are carcinogenic. The U.S. Food and Drug Administration (FDA) regularly tests samples of various foods for such dangers, and it routinely finds high levels of these natural toxins in organically grown produce. It found, for instance, that organic crops have higher rates of infestation by aflatoxin, one of the most virulent carcinogens known to man.’ (1)

3.15 ‘The use of effective fungicides has reduced the risk from mycotoxins in normal food, but not necessarily in organic food. Constant exposure to mycotoxin carcinogens can be expected to have long-term effects, detectable only by continual monitoring. However, there are no current plans to carry out this monitoring’ (27)

3.16 ‘Organic farmers are allowed to spray crops with bacterial spores to act as a general-purpose insecticide. But earlier this year [1999] these spores were found to cause serious, often fatal, lung infections in mice, and to infect wounds and damage human cells in culture.’ (27)

3.17 ‘Plants react vigorously when attacked by disease organisms and synthesise many chemicals that are carcinogenic. Thus organic cider from apples has much higher patulins levels, and celery has higher levels of psoralen which, without careful harvesting, can cause serious skin burns.’ (27)

3.18 ‘The most enduring myth about food is probably that organic food is devoid of carcinogenic compounds because it is grown without synthetic chemicals. Plants have natural toxins to protect themselves. These natural pesticides, like those produced synthetically, can cause tumours in experimental rats at very high doses.’ (3)

3.19 ‘Toxicologists such as Ames and Gold (1999) attest that everyday foodstuffs like orange juice, nutmeg and coffee have far higher levels of natural toxins than synthetic pesticides. The combination in both is insignificant in health terms. Our bodies are adept at dealing with all toxins, regardless of origin. Nearly all pesticides we ingest are natural. Hence, it is considered folly by many toxicologists to worry about synthetic pesticides as a cause of cancer.’(3)

Concerns over the use of synthetic pesticides appear to be unfounded:

3.20 ‘Death caused by either natural or synthetic pesticide residues in food has never been proven. Deaths from pesticides are tragically almost all suicides, or are caused by high-dose occupational exposures. Even natural and essential substances like Vitamin A can kill at high doses’ (3)

3.21 Director W. M. Fifield of the Florida Experiment Station has said: “Not a single instance has been called to our attention where the use of chemicals in production or protection of our state’s crops or livestock has resulted in harmful effects on humans who have consumed them.”’ (25)

4. Are organic foods free of chemicals?

4.1 While in general fewer agrochemicals are used in organic farming some forms of pesticide are used and although these tend to be based on ‘natural’ products this does not mean they are safer than the highly regulated and tested synthetic pesticides.

4.2 Over 30 additives are allowed in organic production, and the washing of fruit and vegetables in sodium hyperchloride is permitted (15)

4.3 People who believe that chemicals used in farming are detrimental to health may be interested to know that ‘every day, each of us eats a quarter of a teaspoonful of carcinogens; 99.99 per cent of these are made naturally by all plants - whether organic, GM or intensively farmed - to inhibit disease organisms and deter consumption by animals and insects.’ (27)

4.4 ‘Pesticide residues are lower in organic food - but not absent. Organic farmers are allowed to use pesticides, but apply them more sparingly and tend not to use the broad-spectrum pesticides - although pyrethrum (a common fly-killer spray) is permitted, because it is found naturally in some plants. Regulations vary from country to country, but antibiotics such as streptomycin are acceptable if they are derived from fermentation.’ (27)

4.5 ‘Organic farmers use sulphur as a weak pesticide. But sulphur contains lead, a known danger. What is not known is how much of the lead is transferred to the food we eat.’ (27)

5. Does organic food taste better?

5.1 Organic produce is often quoted as being tastier than conventionally produced food. This can often be as a result of organic produce being fresher as it has a much shorter shelf life and is therefore not stored for as long as some conventionally produced food.

Direct comparisons between organic and conventionally produced foods show neither type of produce as being better tasting.

5.2 ‘The results in the scientific literature show no consistent pattern for sensory quality between organically and conventially grown produce.’ (9)

5.3 ‘In the early 1990’s Israeli researchers made 460 assessments of 9 different fruits and vegetables and found no significant difference in quality between ‘organic’ and conventially grown samples. (2)

5.4 As part of a survey by the University of California on the differences between organic and conventially grown tomatoes, ‘researchers picked 40 people to do a taste test. Ten people said that the organic tomatoes had better flavour and texture, ten people said that the conventionally grown tomatoes were better and twenty people could not tell the difference.’ cited in (17)

5.5 In the US the USDA has labelling requirements which prevent producers making claims that organic foods are better or even different to conventional foods. (2)

5.6 ‘Some reports on qualitative differences, such as flavour in potatoes, can be attributed to differences in dry matter concentration and can be associated with the growing conditions, principally the supplies of water and nitrogen. There, the preferred conditions are as easily provided in conventional culture as in any other’ (16)

6. The use of biotechnology and genetically modified organisms (GMOs)

6.1 There is much variation between standards in each country, some such as the Soil Association in the UK will not allow GM products in their certified produce while other such as the EU permit GM products. (15) As the MORI survey in 1999 suggests, many people buy organic produce because they believe it to be GM free, however this is only the case in some organic produce. Consumers need to be aware of these variations.

6.2 For those concerned about the use of GM products, the findings of a recent US report has concluded that there is no distinction between plants bred using biotechnology and those produced through traditional crossbreeding (12)

6.3 It must also be remembered that modern crop varieties have been adapted by the use of biotechnology. ‘Organic farmers can and do use modern crop varieties, since they have disease resistance and good yields. However these varieties acquired their genes from different species by difficult laboratory procedures; for example, rice obtained genes from sorghum wheat. These are not natural plants and they don’t survive in fields unless continually cultivated.’ (27)

6.4 ‘For over 70 years, plant breeding and selection for resistance to diseases has been seen as an important means for agricultural progress. This strategy has had some successes but in many cases, for example rice blast in rice and late blight of potato, disease resistance in the crop has been relatively short-lived and the disease organism has mutated or been selected to overcome that resistance. If durable forms of resistance to any of the major diseases could be introduced into otherwise acceptable varieties by genetic modification, the saving in use of agrochemicals would be immense.’ (16)

7. Is organic farming better for the environment?

Claims that organic farming is better for the environment as it is more ‘natural’ are not necessarily true.

7.1 CWS Farms Group has been experimenting with organic farming since 1989, with much success. However, their Project Manager made the point “The perception that organic farming is per se better for the environment because it relies on natural processes does not always hold true. Natural processes are variable and outside the grower’s control. This can cause problems. The natural breakdown of mineral nitrogen, for example, can occur at the wrong time for the plants, increasing the chances of nitrate leaching. Wildlife likes the ‘unkempt’ bits and organic farms are not necessarily likely to have more untidy areas than conventional farms.”(15)

7.2 There is some concern that the use of farmyard manure may be getting into ground and surface water (15)

7.3 ‘The use of farmyard manure adds humus to the soil, which aids structure, and encourages earthworms and other minor invertebrates. It may also add an excess of phosphates which, although essential plant nutrients, can also cause pollution of water courses. By contrast, some concern was expressed that phosphorus might be being removed at a greater rate than it is replaced in organic systems.’ (11)

7.4 (In Korea and Japan) ‘The overuse of organic fertiliser by some organic farmers has caused some severe problems since they apply too much organic fertilizer compared to the need of crops.’ This could lead to a ‘potential risk for NO3 leaching’ (23)

7.5 ‘Water leached from organic farms has been reported to contain less nitrate than the EC nitrate limit of 50mg/litre although, in MAFF projects NT1313 and OF01410, the limit was sometimes exceeded. Nitrate leaching in the two systems [organic and conventional] was said to be highly variable’ (16)

7.6 The BTO (British Trust for Ornithology) amongst their evidence given to the House of Lords, noted that “some aspects of organic farming may not be beneficial to bird populations, for example disturbance caused by mechanical weeding, and the early cutting of clover-based leys.” (11)

7.7 ‘Organic farming is claimed to be better for the countryside. For example, birds and other wildlife are a valued part of organic farming. It is a matter of record that less intensive application of conventional methods achieves the same results. Conventional farms can be, and often are, managed in ways that provide the benefits to wildlife claimed by the organic movement’ (16)

7.8 ‘If very large organic farms were to become common, it would remain to be seen whether they brought the same benefits for biodiversity as smaller organic units.’ (11)

7.9 The Institute of Arable Crops Research (IACR) at Rothamsted said that “any farming system, whether it be conventional, integrated or organic, can achieve the environmental benefits that organic farming aims to achieve.” (11)

7.10 ‘To institute organic farming countrywide would mean ploughing up wilderness, hedges and woodland to make up the shortfall compared to intensive farming’ (27)

8. Medicines and animal welfare

8.1 ‘Evidence for increased disease resistance, productivity, or fertility of animals feeding on organically grown fodder is largely anecdotal.’ (9)

Veterinary treatment in organic systems raises some serious animal welfare concerns:

8.2 EU regulations state ‘when animals become sick or injured, they should be treated immediately by giving preference to phytotherapeutic (herbal) or homeopathic medicinal products and by limiting to a strict minimum the use of chemically-synthesised allopathic medicinal products in order to guarantee the integrity of organic production for consumers it should be possible to take restrictive measures such as doubling the withdrawal period after use of chemically synthesised allopathic medicinal products’ (8)

8.3 SSPCA has raised concerns over - New guidelines advising farmers to use homeopathic remedies rather than conventional (18)

8.4 ‘Some of the standards set down for the management of animal health, while the motives may be well intended, could in fact jeopardise the health and welfare of animals or put human health at risk.’ (20)

8.5 Firstly the use of unregulated homeopathic remedies as opposed to strictly regulated conventional animal medicines, raises questions over the safety and efficacy of the product and its likely effects on the animal and the consumer of the animal treated. Unlike regulated animal medicines, homeopathic remedies do not have withdrawal periods.

8.6 The requirement to automatically double withdrawal periods is illogical, unscientific and a potential threat to animal welfare. MRLs and withdrawal periods for licensed medicines are based on rigorous, independent, international scientific standards incorporating massive safety factors. There is no logic to a ‘blanket’ doubling which takes no account of the properties of the individual product. Such additional delay could prompt a farmer to withhold treatment of an animal near to market (or to cheat).

8.7 The organic method of using medicines therapeutically as opposed to preventative treatments, means that the animal has to get sick and suffer before it is treated, whereas preventative medicines would have prevented the suffering from happening at all. While symptoms develop there is also an increased risk of the sick animal passing infection to its fellows, further increasing suffering and increasing the total volume of medicine used.

8.8 There has been some criticism of the organic restrictions on medicine usage by farmers. A Scottish farmer recently was denied organic certification for his sheep because he was using an 8:1 anti-clostridial vaccine instead of a 4:1. The 8:1 vaccine was recommended by his vet as being the best for his sheep to protect unborn lambs against lamb dysentry. Had he followed the organic rules and changed to the 4:1 vaccine his animals might have been subjected to suffering and death. (6)

9. Imported Organic Food

9.1 It is important to remember that whilst organic farming in the UK is increasing with the help of government funding, it is not increasing at a rate high enough to meet consumer demand for organic produce.

9.2 This means that about 70% of organic food is imported from continental Europe and US sources. (16)

9.3 With such a variety of sources regulating standards becomes difficult. MAFF’s role in regulating the quality of imports depends on trust and imports are not Soil Association Accredited. Therefore, there could be great variations in standards. (15)

9.4 The importing of such a large percentage of organic food also presents environmental concerns. As Rosemary Stanton, an Australian Nutritionist speaking about organic food in Australia says, “It's ridiculous to buy organic food that is flown out here in planes using massive amounts of fossil fuels”(7) The imports into the UK must also have environmental costs in their methods of transport into the country.

References:

(1) Avery, D.T. (1998) The Hidden Dangers in Organic Food [Online]

(2) Barrett, M.D. (Date unknown) Organic Foods: Will Certification Protect Consumers? [Online]

(3) Bate, R (2000) Organic Myths: The Retreat From Science, Biotechnology and Development Monitor, 1 March. [Online]

(4) Bear, F. E. (1948) Variations in mineral compositions of vegetables, Soil Science Society of America Proceedings 13, 380-384

(5) Bevan, S (1999) Warning: organic food can seriously damage your health, 12 September, Sunday Times

(6) Christie, J (2000) Letter to Farming News - Red tape makes mockery of hard-fought ‘organic’ status, Farming News, May 11.

(7) Dixon, A (1999) Wealth Warning on Health Foods, The Sun Herald, 5 September [Online]

(8) EC (1999) Council Regulation (EC) No 1804/1999 of 19 July 1999 supplementing Regulation (EEC) No 2092/91 on organic production of agricultural products and indications referring thereto on agricultural products and foodstuffs to include livestock production.

(9) Finesilver, T, Johns, T and Hill S.B. (date unknown) Comparison of Food Quality of Organically Versus Conventionally Grown Plant Foods, Ecological Agriculture Projects [Online]

(10) Holman, J.R. (Date unknown) Phys. Trick or Treat? What Organic Really Means, [Online]

(11) House of Lords European Communities Sixteenth Report 20 July 1999

(12) House Subcommittee on Basic Research, (2000) Seeds of Opportunity: An Assessment of the Benefits, Safety, and Oversight of Plant Genomics and Agricultural Biotechnology.

(13) IGD Organic Food Conference, 2 November 1999

(14) J Sainsbury web site http://www.sainsburys.co.uk

(15) Kidd M, & Lewis E, (1999) Organic Foods - Consumer Concerns, The Consumer Panel Secretariat, JFSSG.

(16) MacKerron, D.K.L, Duncan, J.M, Hillman, J.R, Mackay, G.R, Robinson, D.J, Trudgill, D.L, Wheatley, R.J (2000) Organic Farming: Science and Belief, Excerpted from the 1998-99 Annual Report, Scottish Crop Research Institute, 1 February [Online]

(17) Mael, S (1997) Agroecology Group Project, Organic Farming [Online]

(18) McLaren, C (2000) Organic Guidelines Raise Welfare Worry, Farming News, 4 May.

(19) Nelson, H. ( Date unknown) The contamination of Organic Produce by Human Pathogens in Animal Manures, Ecological Agriculture Projects [Online]

(20) NOAH (1990) Position Paper on Organic Farming

(21) Organic Trade Association (Date unknown) Frequently Asked Questions: Is Organic Food Better for You? [Online]

(22) Penbryn Organic Farmhouse Cheese web site http://www.webaware.co.uk/bestofwales/penbryn

(23) Sohn, S.M. (1996) Nitrate and Overuse of Organic Fertiliser S1, IFOAM Book of Abstracts

(24) Soil Association web site http://soilassociation.org

(25) Throckmorton, R.I. (Date unknown) The Organic Farming Myth, Kansas State College, [Online]

(26) Trewavas, A. (1999) Organic Safety Scare, BAA Grapevine

(27) Trewavas, A (1999) Is Organic Food Really Safe? Institute of Cell and Molecular Biology, University of Edinburgh, 30 July. [Online]