Evaluation of the DEMETER Certification of Biodynamic Agriculture : The Farm Standard
For many, DEMETER certification is synonymous with trust and a guarantee that food has been grown according the world’s most sustainable and spiritual farming practices. Others believe that DEMETER is responsible for protecting the integrity of Rudolf Steiner’s biodynamic agriculture. But has DEMETER earned our trust or do we simply have faith in its dependability? A comprehensive independent evaluation, perhaps a first of its kind, of the US DEMETER Biodynamic Farm Standard was performed to assess its technical content, intelligibility, and capacity to effectively discriminate conventional farming practices from those that exemplify the principles of biodynamic agriculture. The evaluation revealed that, 1) the standard contains several incongruities, 2) exemption clauses remove to a large degree the obligation of applicants to conform to the requirements that represent the most distinctive features of biodynamic agriculture, 3) relying on the USDA National Organic Program and the National List of Allowed and Prohibited Substances may not be in the best interest of biodynamic certification, 4) the organizational structure and set-up of the certification scheme may lead to potential conflicts of interest, and 5) marketing claims tend to overstate the benefits of DEMETER certification which can mislead consumers and jeopardize the biodynamic movement as a whole. Recommendations towards best practices have been provided in hopes that these shortcomings can be eliminated. Other elements and components, such as the standard-setting process, the reliability of the auditing program, the handling of interpretations, transparency, and the dependability of Demeter-International’s equivalency arrangements, for example, also need to be assessed before we can replace our faith with trustworthy assurances.
DEMETER ASSOCIATION INC. [from now on referred to as DEMETER-USA] uses the Biodynamic Farm Standard (Feb 2014) to evaluate and certify farm operations for the purpose of allowing their products to carry the certification marks “Biodynamic®” and/or “Demeter®”. This standard forms the legal foundation and agricultural framework for the Biodynamic® practice in the United States. DEMETER-USA is the American chapter of Demeter-International, one of 17 national Demeter organizations that certify biodynamic farms, traders and processors all over the world. All national organizations use the same Demeter-International standards as a reference; however member countries develop their own national documents with regional specifications and additions.
DEMETER-USA is a nonprofit public benefit corporation (Oregon- RegNo: 710253-90) which is organized and operates for charitable purposes -501(c)3 of the IRC- and the only certification body for biodynamic farms, processors and products in the United States. The President of the corporation is Katrina Frey and the Registered Agent is James Fullmer (1). As of 2008, there are 123 Demeter Certified biodynamic farms and processors in the U.S., representing over 10,000 acres under Biodynamic cultivation (2).
According to DEMETER-USA,
“Biodynamic certification is growing at 15% per year here in the US, adding to the ranks of more than 4,500 Biodynamic producers worldwide. What is particularly exciting is that the Biodynamic standard is being positioned as the promise of organic delivered, a standard that not only reflects the best example of ecological farming, but also delivers the purest products” (3).
This evaluation was conducted independently of external influences. It was not sponsored or commissioned by any farming enterprise, business, industry, corporation, association, government, organization, or university. Nor did I receive any funding, remuneration or favors. I have never worked for DEMETER-USA, the USDA-NOP, or any of their members or licensees. Nor do I seek or have been refused biodynamic certification. My agenda was set by my own curiosity and wish to be of service to the Demeter organization, consumers and/or farmers who may be too busy, unqualified or unaware of the best practices that diligent certification bodies must follow to assure and maintain their integrity and credibility. Moreover, as a conscious consumer I am rather uncomfortable of having to rely on faith when purchasing certified products, especially if I’m required to pay a premium. I’ve worked in the environmental certification trade long enough to know that, unfortunately, the consumer has the responsibility to inform him/herself, rather than trusting marketing claims and/or eco-labels, even those overseen by independent, third-party certification organizations.
For this evaluation, I have chosen to focus mostly on the technical aspects pertaining to the Biodynamic Farm Standard. I have assessed its intelligibility, applicability, and capacity to exemplify the principles of Steiner’s biodynamic agriculture. Other more general aspects, such the accuracy of marketing claims and areas of potential conflicts of interest have also been partially investigated.
If I were not an enthusiast of Steiner’s work and biodynamic agriculture, I would not have donated my expertise to such an exacting and time-consuming responsibility. I do this for spiritual reasons.
Now it is a fact that in real life, total errors are not so harmful as half-or quarter-truths. Total errors are soon seen through, whereas half- and quarter-truths mislead people. They live with them, these partial truths become a pan of life and cause the most horrible devastation . Rudolf Steiner (4)
Editorial Errors and Technical Difficulties
I have found several editorial errors in the standard (e.g. mismatches between headings used in the table of content (TOC) and those in the document, TOC page numbers don’t match those in the document, sentence fragments, inconsistent formatting, unclear references, words easily confused, poor use of language, impracticable requirements, etc.). For example:
- Section 1.B.2 of the TOC indicates “Compost”, but in the document the section is labeled “Composting”.
- Section 1.B.5 of the TOC indicates “5. Livestock”, but in the document there is no such section, instead we find “ Fertility materials needing special consideration”.
- On page 11 we find, “The full compliment if the Biodynamic preparations 500- 507 must be used”, when it should have said, “The full complement of…”.
- On page 11 we find, “If in work is done when there is water in the stream in stream sediment control and containment measures to prevent excessive sediment and construction debris from entering the water way”.
This sentence is confusing and contains no actionable requirement. It could easily be replaced with, “If in-stream work is done when there is water in the stream, sediment control measures shall be taken to prevent and contain excessive sediment and construction debris from entering the water way and flowing downstream”.
- On page 14 we find: “Biodynamic compost must not present a health risk due to pathogens that may be present in feed stock materials. The carbon to nitrogen ratio of the ingredients must be in the range of 25-40 to 1. Producers using an in-vessel or static aerated pile system must maintain the composting materials at a temperature above 131°F for 3 days. Producers using a windrow system must maintain the composting materials at a temperature above 131 °F for 15 days, during which time, the materials must be turned a minimum of five times. While there may be instances that arise where such a windrow system needs to be used (such as piles that become over saturated with water for example) as a general rule excessive turning of the compost pile should be avoided. A properly built compost pile should have the Carbon to Nitrogen ratio, porosity, and moisture content to allow the pile to decompose properly without excessive turning. Temperatures reached by the Biodynamic compost should not exceed 150 F”.
In the example above it is not unreasonable to assume that the elements associated to the verbal forms “must” and “must not” are mandatory requirement, and those that precede or follow “should” and “should not” are optional; they are not needed for certification. If this is the case, conforming to the mandatory requirements will require a clear demonstration from the applicant that:
- the carbon to nitrogen ratio of the ingredients are in the range of 25-40 to 1,
- the composting materials in-vessel or static aerated pile system was maintained at a temperature above 131 °F for 3 days,
- the composting materials in the windrow system was maintained at a temperature above 131 °F for 15 days,
- the compost pile was turned at least five times.
It is unclear what verifiers the auditor will require to assess conformity to these requirements. Technically, the applicant should provide laboratory test results showing the carbon to nitrogen ratios, values compiled from data loggers that have monitored continuous temperature, and records that indicate the dates when the compost piles were turned. It seems very unlikely that the typical small biodynamic farm has the capacity to demonstrate compliance to such costly requirements.
The Biodynamic Farm Standard contains too many editorial errors, poorly articulated requirements, and incongruities to be fully disclosed in this evaluation. I found it very difficult to distinguish what was required (i.e. mandatory) for certification from what given as factual information. Moreover, at times when I thought I’d found a mandatory clause, the wording of the requirement was such that it appeared to be impracticable or at least that demonstrating conformity seemed highly unrealistic.
Verbal Forms for the Expression of Provisions
The Biodynamic Farm Standard of DEMETER-USA uses the following verbal forms of expression of provisions:
|need to||are, is||should strive|
|should not||that could||is recommended that|
|is prohibited||needs to be considered||requires that|
|can take place||takes into consideration||may need to|
|must be||are considered||attempt to|
|is forbidden||are required to be||will be|
|cannot be||can be||must have|
The use of such a wide range of expressions throughout the standard causes confusion. It is difficult to identify the mandatory requirements. Verbal forms of the expression of provisions must always be chosen appropriately to avoid confusion so that both the applicant and auditor can agree on what it actually required for certification. Such clarity is essential to assure consistency, a desired feature of a certification program.
According to ISO/IEC Directives, Part 2 (5),
“A clear distinction shall be made between requirements, statements and recommendations […]. In order to be able to claim compliance with a document, the user needs to be able to identify the requirements he/she is obliged to satisfy. The user also needs to be able to distinguish these requirements from other provisions where there is a certain freedom of choice.”
ISO/IEC recommends that,
- Requirements are expressions in the content of a document conveying criteria to be fulfilled if compliance with the document is to be claimed and from which no deviation is permitted.
- Recommendation are expressions in the content of a document conveying that among several possibilities one is recommended as particularly suitable, without mentioning or excluding others, or that a certain course of action is preferred but not necessarily required, or that (in the negative form) a certain possibility or course of action is deprecated but not prohibited .
- Statements are expressions in the content of a document conveying information.
The following verbal forms of expression of provisions are recommended:
- Requirements: SHALL, SHALL NOT – Do not use “must” as an alternative for “shall”. (This will avoid any confusion between the requirements of a document and external statutory obligations.). Do not use “may not” instead of “shall not” to express a prohibition;
- Recommendations: SHOULD, SHOULD NOT;
- Permissions: MAY, MAY NOT – Do not use “possible” or “impossible” in this context. Do not use “can” instead of “may” in this context;
- Possibility: CAN, CANNOT.
Numbering of Requirements
As currently written the standard often has more than one requirement inserted inside a single paragraph. Additionally, a paragraph often contains both normative and informative clauses. Using such a structure, or lack of, makes it very confusing, difficult to verify compliance, and document and communicate the non-conformities to the applicant. I recommend rewriting the entire document so that requirements are numbered appropriately.
For example, the following is found in the Biodynamic Farm Standard:
1. Biological diversity
A Demeter certified farm must have a minimum of 10% of its total effective land base- clearly documented in a calculated acreage figure- set aside as a biodiversity reserve. This preserves wildlife diversity, endangered species habitat, and provides an overall reserve of diverse life forms to inoculate and inhabit the farm organism.
Environmentally beneficial grazing [in compliance with Section IE.5] and low impact wild harvest can take place but each situation will be handled on a case-by-case basis. In situations where there is no potential biodiversity reserve occurring naturally, areas will need to be created.
For all botanical species established (natural or planted) at a minimum it needs to be allowed to develop through the flowering stage to be counted towards the 10%. Some examples include insectory plantings, hedgerows, flowering cover crops, perennial plantings along fence lines and roadways, and wildlife corridors.
The clearance of virgin forest for agricultural usage is forbidden. Other conservation areas of high ecological value must also be protected.
Tillable acreage cannot be planted only to a monoculture. Botanical species diversity needs to be maintained via the crop rotation strategies utilized.
In annual crop rotations a given harvested commodity cannot be planted in the same field for more than 2 years in succession. Close attention needs to be paid to the nutrient export associated with each harvested commodity. The crop should not return to a given field until there has been adequate time to return exported nutrients to the soil in a manner consistent with these standards.
Bare tillage year round is prohibited. Land base needs to maintain adequate green cover. Soil must be protected from soil erosion and soil structure degradation during periods of the year when it is vulnerable. Adequate crop residue and, at a minimum, volunteer vegetative cover must protect any and all fields of cultivation during these periods (for example winter months, rainy seasons, etc).
The provisions written above may be replaced with a numbered system with the appropriate verbal form of expressions of provisions, such as:
1.1.1 Biological diversity
126.96.36.199 The applicant shall have a minimum of 10% of its total effective land base- clearly documented in a calculated acreage figure- set aside as a biodiversity reserve.
Environmentally beneficial grazing [in compliance with Section 1.5.5] and low impact wild harvest can take place but each situation will be handled on a case-by-case basis. In situations where there is no potential biodiversity reserve occurring naturally, areas will need to be created.
188.8.131.52 The clearance of virgin forest for agricultural usage is forbidden. Other conservation areas of high ecological value shall also be protected.
184.108.40.206 Tillable acreage shall not be planted only to a monoculture.
220.127.116.11 The applicant shall utilize crop rotation strategies to maintain botanical species diversity.
In annual crop rotations a given harvested commodity cannot be planted in the same field for more than two years in succession.
18.104.22.168 Tilled land shall not be left bare during vulnerable periods of the year.
In order to protect soil from soil erosion and soil structure degradation during periods of the year when it is vulnerable, the land base needs to maintain adequate green cover. At a minimum, an adequate crop residue,, a planted or naturally occurring vegetative cover must protect any and all fields of cultivation during these periods (for example winter months, rainy seasons, etc.).
The promotion of mutual understanding usually necessitates the definition of terms used in the technical requirements, of symbols and signs, and the establishment of sampling methods and test methods, concerning each technical requirement specified in the document (ISO/IEC Directives, Part 2). I recommend DEMETER-USA adds a glossary its Standard.
GENERAL CONSIDERATIONS AND DISCUSSION
This section contains general considerations and various important topics of discussion that have emerged while evaluating the Biodynamic Farm Standard and DEMETER-USA’s certification program.
Relationship to the USDA National Organic Program (NOP)
The National Organic Program (NOP) regulates all organic crops, livestock, and agricultural products certified to the United States Department of Agriculture (USDA) organic standards. The Organic Foods Production Act (OFPA) of 1990 requires the Secretary of Agriculture to establish a National List of Allowed and Prohibited Substances. According to the USDA, “The National List of Allowed and Prohibited Substances identifies the synthetic substances that may be used and the nonsynthetic (natural) substances that may not be used in organic crop and livestock production. It also identifies a limited number of non-organic substances that may be used in or on processed organic products” (6).
The Biodynamic Farm Standard specifies that, “Pesticide tolerance levels permitted for Demeter certified production are as noted in the USDA National Organic Program” and “we rely on OMRI/ the NOP National List but with the following notable exceptions (Appendix B of the Standard):
- Gelatin Prohibited.
- Plant hormones Prohibited – such as Gibberellic acid applied to manipulate size of table grapes.
- Stylet oils Regulated- If product used is approved for use in NOP organic production, mineral oil is allowed for perennial tree and vine crops only.
- Chilean nitrate, Prohibited.
- Copper products Regulated- Limited to maximum 3# Cu/ac/year, and if possible, 1#/application based on Demeter International Standards.
- Synthetic amino acids Prohibited- such as DL Methionine in poultry feed.
- Manure from intensive livestock operations.
- Antibiotics Prohibited- such as Streptomycin and Tetracycline for fire blight control in apples and pears.
- Approved Phosphorus and Potassium Salt fertilizers can only be used when there are documented P and K deficiencies.
It is worth noting that the exceptions made in Appendix B are not necessarily more stringent than the requirements found in the NOP National List. For example:
- In the DEMETER-USA Farm Standard, mineral oil is allowed for perennial tree and vine crops, while in the National List mineral oil is only allowed for topical use and as a lubricant.
- In the DEMETER-USA Farm Standard, copper products are allowed and limited to maximum 3# Cu/ac/year (i.e. every year), while in the National List copper use is limited to one application per field during any 24-month period (i.e. every two years) and application rates are limited to those which do not increase baseline soil test values for copper. Additionally, the National List specifies that copper-based materials shall not be used as herbicides.
Currently, the USDA NOP National List allows:
- At least 68 different synthetic substances for use in organic crop production.
- At least 41 different synthetic substances for use in organic livestock production.
- At least 70 different nonagricultural substances as ingredients in or on processed products labeled as “organic” or “made with organic.
- At least 47 different nonorganically produced agricultural products as ingredients in or on processed products labeled as “organic”.
Many nonsynthetic (i.e. natural) materials that are not prohibited by the National List or the Environmental Protection Agency (EPA) can be used with very few restrictions in organic and biodynamic agriculture. But are these “natural” materials necessarily safe? Botanical pesticides and insecticides such as Sabadilla or pyrethroids have been shown to be toxic to amphibians and fish (7), and can interfere with honeybee reproduction, their ability to navigate or regulate temperature, any of which can have an effect on long-term survival of honeybee colonies (8).
Biological control of plant diseases, a “natural” alternative pest management strategy employed in organic and biodynamic agriculture, is a result of many different types of interaction among microorganisms and can occur through different mechanisms, which are generally classified as parasitism/predation, antibiosis, competition, lytic enzymes, and induced resistance (9). However, the introduction of biological control agents into the soil may pose a risk of unforeseen detrimental activities on the soil microbial population (10), and the indigenous nematode fauna (11), which are both essential for nutrient-cycling and soil fertility. It seems rather contradictory to be importing and adding to the soil and crops microbial antagonists when one of the basic tenets of biodynamic agriculture is to create a healthy and diverse microbial soil life by using biodynamic preparations carefully crafted from materials produced on the farm.
Corporations and industries that manufacture or distribute chemical insecticides, pesticides, herbicides, and fertilizers are constantly lobbying (i.e. petitioning) the USDA NOP through its NOSB to determine what will be classified as nonsynthetic (i.e. natural) as opposed to synthetic, and what synthetic materials should be allowed on the National List. In September of 2013 Deputy Administrator McEvoy announced dramatic changes in the approval process for synthetic and non-organic materials allowed on the National List for use in organic food and agriculture. These changes were implemented without consultation of the National Organic Standards Board (NOSB), the organic stakeholders or the public. As a consequence the authority, independence and input of the NOSB were significantly eroded, which in turn affected the manner in which temporary exemptions of certain synthetic chemicals could be permitted for use in organic agriculture (12).
The law stipulates that exempt materials (i.e. synthetic chemicals permitted for use in organic agriculture due to temporary exemptions), would “sunset,” or lose approval to be used in organic farming, after five years unless two-thirds of the members of the National Organic Standards Board voted to keep them on the list. However, materials on the National List are now reviewed by subcommittees and synthetic chemicals may not be removed without the votes of two-thirds of the board, when previously two-thirds of the board was needed to keep them on the list.
The Cornucopia Institute, the nation’s leading organic farming watchdog, has challenged what it calls a “conspiracy” between corporate agribusiness interests and the USDA. This “comfortable relationship” has increasingly facilitated the use of questionable synthetic additives and even dangerous chemicals in organic foods. In a white paper called The Organic Watergate, the Cornucopia Institute charges the USDA with “stacking” the NOSB with agribusiness executives that all too often have “sold out” the interests of organic farmers and consumers; “Long-term abuse of congressional intent by the USDA, which has stacked the board with agribusiness representatives, an illegal practice that has stretched over the past three administrations” (13).
“We’re now in the land of the midnight sun — the sun never sets,” said Mark Kastel (15), one of the plaintiffs of a coalition of grocers, seed growers, consumers, and environmental advocate who have filed a civil action for declaratory and injunctive relief (i.e. a lawsuit) when the USDA violated procedures for federal rule-making when it changed the way synthetic and non-organic substances are approved for use in organic. The plaintiffs seek a declaration that Defendants violated federal laws in developing and promulgating the September 16, 2013, Federal Register notice, National Organic Program – Sunset Process (Sunset Notice),without regard to rulemaking procedures under the Administrative Procedure Act (APA) and standards of the Organic Foods Production Act. Plaintiffs seek invalidation of the September 16, 2013, Sunset Notice and reinstatement of the previous sunset rules and procedures pending APA notice and comment review (16).
There are many other examples that clearly demonstrate how the USDA NOP has become ill-equipped to distinguish practices that remind us of industrial agriculture (i.e. Big Ag farming which includes the use of chemical fertilizers, pesticides and herbicides, hybrid and GMO seeds, etc.) from the purest forms of organic farming (i.e. systems that rely on crop rotation, animal and plant manures as fertilizers, hand weeding and biological pest control, heirloom, etc.). The NOP has moved in a disturbing direction in regards to the functioning and content of its National List, as well as many other key areas (17).
These shenanigans and their consequences were not unforeseen. In 1998 Anne Mendenhall, the past Director of DEMETER-USA, made the following comments in a letter addressed to the USDA-NOP (18):
- Demeter supports the development of organic standards by the organic community, not by USDA.
- We do not believe USDA is qualified to set regulatory standards for the organic community, or that it is free from influence which would seek to degrade organic quality.
- Certifiers are more experienced and knowledgeable in standards setting and less vulnerable to political influence. Therefore let them do the job.
- It is past time for USDA to step back from a job it is not qualified to do before additional monies are squandered in this hapless undertaking.
Similarly in 2000 Fred Kirschenmann, currently a Board Director of DEMETER-USA, wrote: “Creating such an undeviating standard plays fully into the hands of the largest industrial operators. The tragedy of this hijacking of the organic vision […] will provide no incentive for farmers or manufacturers to continually improve the art of organic farming and processing” (19).
More than 15 years ago, both Anne and Fred knew that the USDA was not free from corporate influence which would seek to degrade organic quality. Time has proven them right. It is rather surprising to see how DEMETER-USA has gone from disapproving and distrusting the UDSA NOP to relying on its integrity and capacity to help distinguish the purest forms of biodynamic farming from those that remind us of Big Ag [and now Big Org]. Clearly the few provisions (i.e. modifications and/or exemptions to the USDA NOP guidelines) made in the Biodynamic Farm Standard are not enough to keep the convoluted nature of the NOP in check, and safeguard biodynamic certification and its reputation from suffering the same fate as the organic movement.
Theoretical State Space of DEMETER-USA Certification
According to the Biodynamic® Farm Standard:
“Each farm is considered a unique individuality- with its own beginning point and inherited environmental and social conditions. What is critical is that a farm evolves towards its maximum potential as a self-contained individuality. Some applicants’ farms may enter this program very close to this maximum potential. Others will require an evolution towards it” (p41).
What this means is that there is a range of biodynamic practices occurring within the population of certificate holders of DEMETER-USA. This range is possible because the standard allows for many exceptions to be made to several requirements. Granting exemptions is not uncommon for certification programs that deal with complex systems, such as farming operations, however too much flexibility may mean that the benefits of the standardization are lost.
How many exemptions have been made in the Biodynamic® Farm Standard? What is the range of biodynamic practices within the population of certificate holders of DEMETER-USA? The first question is easy to answer; the second however requires having access to all the audit reports, compiling large amounts of data, and drawing comparisons. The public does not have access to such useful data.
Another way to determine the range of biodynamic practices within the population of certificate holders is to perform a thought experiment in order to define a theoretical state space. The theoretical state space represents the range of all possible outcomes that the standard allows for; as opposed to the realized state space which is a representation of the actual range of certified farms. We can determine the theoretical state space by creating two imaginary farms, FARM A and FARM B. We assume that both these farms are fully compliant to the standard and therefore could technically be certified. FARM A represents the lower boundary of the state space, where exemptions were granted for elements of the standard that allowed for such dispositions. FARM B represents the upper boundary of the state space where all the requirements of the standard were met, without needing to make any exemptions. The next step in this thought experiment is to compare side by side the different farms.
Table 1: Comparison of two fictitious farms, FARM A and FARM B. “YES” means the requirement was met by the farm without having to make an exception, and “NO” represents a case where an exemption was needed to allow certification.
|DEMETER-USA REQUIREMENT||FARM A||FARM B||EXEMPTION CLAUSE IN THE STANDARD|
|10% of total effective land base was set aside as a biodiversity reserve (i.e. no harvesting).||NO||YES||Beneficial grazing and low impact wild harvest can take place but each situation is handled on a case-by-case basis.|
|Fertility materials (e.g. compost, bulk manures, feedstock, Municipal “green waste”, nitrogen, phosphorus, meals, ash, trace minerals, etc.) were not imported to the farm.||NO||YES||Import is allowed after the techniques recommended in the standard were utilized to their maximum potential, or deemed inapplicable. Allowance for imported fertility is handled on a case-by-case basis.|
|Pest control materials were not imported to the farm.||NO||YES||Import is allowed after the techniques recommended in the standard were utilized to their maximum potential, or deemed inapplicable.|
|Weed control materials were not imported to the farm.||NO||YES||Import is allowed only after the techniques recommended in the standard were utilized to their maximum potential, or deemed inapplicable.|
|Livestock – minimally a cow – is present on the farm.||NO||YES||DEMETER-USA allows exemptions for not having livestock and having livestock on the farm that are not managed fully to the DEMETER-USA Standard.|
|Attempts were made to use materials [as compost ingredients] that have not been contaminated with prohibited materials such as prohibited pesticides, GMO’s, heavy metals, wormers and antibiotics, hormones, persistent pesticides.||NO||YES||In the event this is not possible, product testing may be required to show that the finished product is not contaminated.|
|Off-farm manure sources comes from certified organic livestock production.||NO||YES||If this is not possible and conventional livestock manure is used, the materials used in the conventional livestock production (i.e. wormers, hormones, GMO feed, antibiotics, persistent pesticides) must be documented.|
|Phosphorus and Potassium Salt fertilizers were not used on the farm.||NO||YES||Approved Phosphorus and Potassium Salt fertilizers can be used when there are document P and K deficiencies.|
|Biodynamic Preparations were made on the farm.||NO||YES||As much as possible the Preparations should be made on the farm.|
|Biodynamic Preparations were used on the farm.||NO||YES||A farm in transition to Biodynamic is expected to make steady progress in introducing their use.|
|Soaps, diatomaceous earth, Bordeaux mixes were not used for pest management.||NO||YES||They are permitted for use on the farm in consultation with Demeter.|
|Biocides were not used on the farm.||NO||YES||Only biocides that are not selective to the pest species should be avoided.|
|Sulfur was not used on the farm for pest management.||NO||YES||Sulfur should be used only as needed, not according to a schedule.|
|Copper was not used on the farm for pest management.||NO||YES||Copper products are limited to a maximum of 3# Cu/ac/year and, if possible, 1#/application.|
|Prohibited measures for pest management were not used on the farm.||NO||YES||In case of severe attack by pests or disease in fields or during storage, which cannot be controlled by approved measures and where prohibited measures are unavoidable, a report must be made to a DEMETER-USA representative.|
|Petroleum-based mulching material was not used on the farm.||NO||YES||Petroleum-based mulching material must be removed before it can decompose and/or become embedded in the soil.|
|Crops were not grown under high voltage power lines that emit significant EMF levels.||NO||YES||In order to address these negative impacts the areas should receive extra applications of the full “compliment” (sic) of the Biodynamic preparations.|
|Irrigation water is free of chemical contamination.||NO||YES||Water may require periodic testing if there are obvious potential sources of measurable contamination. If the source is chlorinated municipal water, it is recommended that the water be aerated.|
|Livestock are not being grazed in sensitive ecosystems||NO||YES||Not allowed unless grazing benefits such systems. These situations will be approached on a case-by-case basis.|
|Livestock living on Demeter farms are certified according to the Demeter standard.||NO||YES||Demeter will allow exemptions not requiring livestock on Demeter farms to be certified to the Demeter standard.|
|Seeds, transplants and propagation material come from Biodynamic sources and produced on the farm.||NO||YES||If imported seed is necessary, preference should be given to open pollinated seed varieties. Hybrid varieties are prohibited, with the exception of Corn (Zea Mays).|
|Potting soil and growing media originate from the farm’s own compost.||NO||YES||Potting soil and growing media should, if possible, originate from the farm.|
|Less than 10% of the herd per year was imported from outside the farm.||NO||YES||An exemption allowing up to 40% imported animals is permitted.|
|Animals were reproduced from natural insemination.||NO||YES||Natural insemination is strongly recommended (i.e. not mandatory).|
|For poultry production 100% of the feed is Demeter certified.||NO||YES||An exemption to allow 50% of the feed to come from certified organic production may be granted based on a documented search documenting Demeter certified feed is not available.|
|Dehorning of the farm’s own stock was not performed.||NO||YES||Dehorning of the farm’s own stock is not permitted, except in an emergency, and for sales of breeding stock. In well-justified cases, an exemption may be approved but must be reviewed annually.|
|Tail docking of lambs has not been carried out systematically.||NO||YES||An exemption to dock tails is possible if the intention is to improve health, welfare or hygiene of the sheep.|
|Since Biodynamic farming principally views the farm as a self-contained organism the entire farm has been certified.||NO||YES||If any crops or land belonging economically to a farm cannot be farmed according to the Farm Standard because of serious technical considerations, then exceptions of particular fields, animals or products need the written consent of Demeter.|
As we can see in Table 1, the distance between the lower (FARM A) and upper boundaries (FARM B) is considerably wide. In fact, it would not be unreasonable to argue that FARM A and FARM B represent two completely different farming operations. Due to multiple exemptions, FARM A is a completely open-system (i.e. not a farm organism according to Steiner), does not have livestock (not even a cow), uses prohibited toxic materials, kills pests with sulfur and copper, uses phosphorus and potassium salt fertilizers, does not make or use biodynamic preparations, grows crops with petroleum-based mulching, imports seeds, transplants and propagation material from off the farm, etc. Having said that, in reality such a farm is unlikely to apply for DEMETER certification, but that’s beside the point. The point is that if such a farm would apply, it could technically be certified.
FARM B is a completely closed-system, (i.e. a farm organism), and respects all the principles of biodynamic agriculture. FARM B epitomizes Steiner’s spiritual-ecological farming. All the other DEMETER-USA certified farms are somewhere between FARM A and FARM B, as illustrated by the simple linear state space shown in Figure 1.
Figure 1: State space of certified biodynamic farms.
This simple thought experiments illustrates that the current version of the Biodynamic Farm Standard is ill-equipped to fulfil its intended scope: “The Demeter Biodynamic Farm Standard is a comprehensive organic farming method that requires the creation and management of a closed system minimally dependent on imported materials, and instead meets its needs from the living dynamics of the farm itself” (19).
Inescapably the certification process involves making interpretations. This is because,
“There is a space between codified standards and practice…the everyday activities of inspectors and certification officers therefore are to interpret actual farming practices in the context of the standards, i.e. the extent to which practices are allowed according to the codified standards. But also, they interpret the standards in the context of possible practice, i.e. the extent to which the rules codified by the standards can be practically enacted by an individual licensee” (20).
The inherent uncertainty in the certification process that emerges from the epistemic object can be minimized in the context of the standardized certification process by coordinating how standards are interpreted by directing how inspectors and certification officers relate to and certify licensees. According to Van der Kamp,
“Like epistemic objects, the object of the certification process is not directly accessible but can only be described by partial instantiations that fail to render it in its entirety – and with each instantiation the object changes. They display a systemic absence of knowledge that warrants further investigation; especially the inspection report constitutes a multilayered, partial object that frequently prompts a chain of questioning on behalf of the certification officer, which could, in principle, go on indefinitely” (20).
Since DEMETER-USA’s interpretations are not made available to the public, assuming it has written documentation of their interpretations and not simply relying on ad-hoc decisions made by auditors and its “Evaluation Circle” (21), I could not determine their relevance and how they guarantee that the intent of the requirements are being met through the auditing process, and by the licensees. An evaluation of the DEMETER-USA’s interpretations to the standard is warranted, especially since this evaluation has revealed many formatting errors, poor use of language and provisions that appear to be impracticable.
Accreditation, Standard-Setting, and Certification
Demeter-International (DI) is a non-profit organization and the association of Demeter certifiers. Currently 17 national Demeter certification bodies (e.g. DEMETER-USA) and the International Certification Office (ICO) certify biodynamic farms, traders and processors all over the world. It is the task of the DI’s Accreditation Council (AC) to safeguard conformity to the International Demeter Standards and harmonization of all national certification schemes. The AC aims to work in line with ISO/EIC 17011 (22). According to ISO/EIC 17011, a system to accredit certification bodies, conformity assessment services should provide confidence in the certification body’s competency and ability to perform their tasks. In other words, it is the responsibility of DI to provide impartial verification of DEMETER-USA’s competence – that its program is impartial and free from conflict of interest.
It is generally understood that third party certification means that an independent review and assessment of a system has been made to determine if it meets a given standard. In principle, the third party has no financial interest or benefit from the claim, making the third party determination of compliance independent, impartial or free from conflict of interest.
However, if the standard-setting and certification activities are managed by the same body, this can cause conflicts of interest. The standard-setting body would like to see high implementation rates of its standard, or have a bias for or against certain types of producers, which can influence certification decisions (23). This is why diligent organizations set up certification schemes so that the standard-setting body who set the rules are not the same as the certification body who is responsible for auditing and issuing certificates. Moreover, to provide additional assurances, certification bodies are typically accredited and quality control performed by independent third-party organizations. In some instances even these accreditation organizations are verified by another independent third-party.
In the situation pertaining to the Biodynamic Farm Standard:
- Demeter-International writes the generic base standard;
- DEMETER-USA modifies the generic base standard;
- Stellar Certification Services, INC., a subsidiary of DEMETER-USA, performs audits to the standard to applicants seeking certification;
- An Evaluation Circle (EC) recommend or not certification.
- DEMETER-USA notifies the applicant of the certification decision.
- Once every three to five years, Demeter-International’s Accreditation Council carries out an audit to assess DEMETER-USA’s documentation and procedures.
In this setup, there is an apparent independence between the standard-setting and certification bodies. However, DEMTER-USA and Stellar Certification Services, INC. are not truly independent despite being two different legal entities. In practice, they share the same staff (24); the Certification Director of DEMTER-USA is the Executive Director of Stellar Certification Services, INC. (25), and the Co-Director of DEMETER-USA is the Board President of Stellar Certification Services, INC. (26). In addition, the body that accredits and performs quality control (i.e. Demeter-International) is not an independent third-party. While this organizational structure is not illegal or unprecedented, it certainly increases the risk for conflicts of interest (16; 27; 28).
Due to a lack of transparency, the process by which Demeter-International has set its baseline standards, or how DEMETER-USA has made modifications to create its own national version could not be determined. Was the Biodynamic Farm Standard created according to best practices (29)? Did DEMETER-USA utilize a consensus-based, balanced multi-stakeholder revision process, including a public comment period, in its decision-making when it added the exemptions in the standard? Has Demeter-International accredited Stellar Certification Services INC. (STEL) , and does it perform regular quality control checks to make STEL acts as a competent auditing body? Unfortunately, these questions cannot be answered. We, the public, must trust that DEMETER-USA is operating according to Demeter-International’s policies and procedures [which we know very little about], that they are not lacking, and that they were created to assure best practices in all aspects of the certification scheme. Demeter-International is known to lack transparency in several other areas (30).
The act of misleading (i.e. lying to) consumers regarding the environmental practices of a company or the environmental benefits of a product or service is called greenwashing (31). When greenwashing occurs, “well-intentioned consumers may be misled into purchases that do not deliver on their environmental promise […] and competitive pressure from illegitimate environmental claims takes market share away from products that offer more legitimate benefits, thus slowing the penetration of real environmental innovation in the marketplace” (31).
Food producers and packagers are often guilty of greenwashing by making false or misleading claims on their product labels to appeal to the environmentally conscious consumer. Greenwashing is an insidious unethical marketing practice used in eco-capitalism (a.k.a. green capitalism) where it is believed that capital exists in nature on which all wealth depends, and therefore, market-based systems should be used to resolve environmental problems. In 2009, a research study found that over 98% of products surveyed in North America committed at least one of six sins of greenwashing (31).
While in the past greenwashing was strictly the domain of product advertisement, now it also affects a wider range of activities, including environmental reporting, event sponsorship, educational materials, environment accounting, etc. There is a common belief that the solution to avoid greenwashing is to pursue environmental certification. It is held that independent, third-party certification based on stringent standards and verification requirements ensures truthful and credible messaging to help customers make healthy and sustainable product choices. However, in this day and age corruption is likely to occur in almost any sphere of social and economic activity, including third-party certification. Certification bodies are not immune to greenwashing or puffery as they too rely on marketing to help sell their product or grow their market. As Anatole France said, “It is human nature to think wisely and to act in an absurd fashion.”
As we have already seen, DEMETER-USA claims that, “Biodynamic farming is free of synthetic pesticides and fertilizers in the same manner as certified organic farming” (32). However, the Biodynamic Farm Standard relies heavily on the NOP’s National List of Allowed and Prohibited Substances which allows for the use of synthetic and non-organic substances in organic crop and livestock production. As mentioned earlier, the Appendix B of the Biodynamic Farm Standard excludes, or modifies, some of the substances allowed in the National List, but this does not preclude DEMETER-USA certified operations from using synthetic substances, such as mineral oil and copper products, for example.
The Biodynamic Farm Standard also mentions that certified organic livestock manures are “one of a farmers most valuable fertilizers”; however an exemption clause specifies that, “If this is not possible and conventional livestock manure is used, the materials used in the conventional livestock production (i.e. wormers, hormones, GMO feed, antibiotics, persistent pesticides) must be documented”. The Standard also stipulates that,
“Care should be taken with regard in the choice of sources used as compost ingredients. Attempt to use materials that have not been contaminated with prohibited materials such as prohibited pesticides, GMO’s, heavy metals, wormers and antibiotics. In the event this is not possible product testing may be required to show that the finished product is not contaminated with materials suspected to be in the ingredient source”.
The accommodating guidelines mentioned above, with their exemption clauses, are not strong guarantees that various synthetic substances won’t find their way on certified biodynamic farms or products. Clauses such as, chemical or GMO analyses “may be required” do not constitute a major tool for verification in certification schemes, because (33),
- Many modern pesticides are difficult to detect at all after use, and others are so persistent that even if residues are detected, that is not evidence of the producer’s having violated the standards.
- Chemical analysis and GMO analysis are very expensive tools.
- There can be contamination of organic products from previous land use.
- There are environmental pollutants which may inadvertently come in contact with organic products, not necessarily leading to a loss of certification.
- Most organic standards have no thresholds established for content of undesirable substances.
The USDA NOP allows the use of the following synthetic fertilizers and pesticides: Elemental sulfur, Copper products, Ethyl alcohol, Calcium lignosulfonate, Ethoxyquin, Formic Acid, Calcium hydroxide, Inerts, Iodine, Sodium hydroxide, Sucrose succtanoate Ester, Suffocating oils, Sulfuric acid, Boric acid, Boron products, Citic acid, Cobalt, Epsom salts, ferrous compounds, iron sulfate, Lignin sulfonates, Magnesium sulfate, Manganese products, Molybdic oxide, Phosphoric acid, Potassium hydroxide, Sodium molybdate, Synthetic vitamins, and Zinc products.
For all of the reasons mentioned above, DEMETER-USA cannot guarantee that certified products are free of synthetic pesticides and fertilizers. Making the claim that “Biodynamic farming is free of synthetic pesticides and fertilizers in the same manner as certified organic farming” is downright misleading, and this is called the Sin of Fibbing (31).
Another example of greenwashing can be found in DEMETER-USA’s marketing advertisement called ORGANIC vs. BIODYNAMIC® (34). Here it is written, “Biodynamic® is farm focused and requires that the whole farm be certified.” However, in section 6.5 “Exemptions to whole-farm certification,” the standard stipulates, “If any crops or land belonging economically to a farm cannot be farmed according to the Farm Standard because of serious technical considerations, then exceptions of particular fields, animals or products need the written consent of Demeter.” Therefore, it is also misleading to advertise that the standard requires that the whole-farm be certified when in reality it is not a mandatory requirement.
Marketing can play an important role in educating the consumers about the value of biodynamic agriculture. However, marketers must resist the urge to make claims that can mislead consumers. In all appearances, most of DEMETER-USA marketing claims advertise the best possible outcomes that the Biodynamic Farm Standard will allow for, while failing to mention the exemption clauses that remove to a large degree the obligation of applicants to conform to the requirements that represent the most distinctive features of biodynamic agriculture. This is referred to as the Sin of the Hidden Trade-Off. Such claims are not usually false, but are used to paint a greener picture than a more complete analysis would support, and are consequently misleading (31).
Finally, it should be noted that DEMETER-USA is not only greenwashing, it is inviting its members to commit greenwashing. This is a very uncommon practice for a third–party certification body. In 2015, DEMETER-USA published a Biodynamic Toolkit that, “provides the information and resources you need to be able to simply and directly communicate the features and benefits of Biodynamic, and creates a shared platform of common language for the Bio-Collective” (38). To help its members focus on key selling points a BIODYNAMIC LEXICON was created that gives layers of definition for use, such as, “Biodynamic farmers never use GMOs, synthetic chemicals, fertilizers or pesticides… NO Synthetic Fertilizers; Biodynamic products […] are not just non-GMO, but NO GMO” (38).
The content of this evaluation speaks for itself. Put mildly, the Biodynamic Farm Standard contains many incongruities. A considerable amount of exemptions to the requirements of the standard have been made, allowing farm operations that do not completely exemplify Rudolf Steiner’s biodynamic agriculture to be certified. Farms that do exemplify biodynamic agriculture can also be certified.
DEMETER-USA alleges that, “We will stand for consumers’ rights to know what they are putting in and on their bodies by championing truth in labeling” (35). However, this evaluation has found that DEMETER-USA has committed several sins of greenwashing; misleading consumers by making claims that paint a greener picture than a more complete analysis would support. This conduct is especially damaging when an independent, third-party certification body commits greenwashing, because its mandate is to protect consumers from being deceived by unregulated product advertisement. Additionally, the marketing claims of a certification bodies tend to trickle down the communication and media ladder and are repeated verbatim by their licensees and affiliates, consumer reports, advocates, educators, food distributors, vendors and consumers. This trend may be even more pronounced due to the fact that DEMETER-USA is inviting its members to commit greenwashing by suggesting misleading common “BD Language” (i.e. a lexicon of catch phrases and key selling points) to be used for marking and promotional purposes.
DEMETER-USA has chosen to rely on the USDA NOP for several crucial elements of its certification program. Numerous important organizations and persons, including the former Director of DEMETER-USA and a current Board Member have expressed their concerns regarding the credibility, integrity and ability of the NOP to serve the best interests of organic farmers and consumers. More recently, a coalition of 15 organic food producers and farmer, consumer, environmental, and certification groups have filed a lawsuit against the UDSA alleging that the Sunset Notice (see the Organic Watergate on p15) is a substantive rule that injures organic consumers, farmers, and producers, and impacts the rights of interested persons by weakening the integrity of the National Organic Program and degrading the quality of organically labeled food. Still, DEMTER-USA continues to define itself and the practice of biodynamic agriculture through the USDA NOP.
An analysis of the organizational structure and the certification scheme of DEMETER-USA suggests that there are potential areas of high risk for conflicts of interest. Freedom from conflicts of interest can be secured through the adoption of best practices, and by separating the standard-setting activities from certification responsibilities.
My final recommendations are as follow:
1. That DEMETER-USA fully considers the spiritual costs and immense responsibility that comes with holding the legal ownership of consumer goods that claim to represent the practice of biodynamic agriculture, and the consequences of expediting a market that requires making more than a few compromises (i.e. exemptions in the standard) to many of the fundamental principles of Rudolf Steiner’s spiritual-ecological approach to agriculture.
2. That DEMETER-USA:
- Performs a revision of the entire content of the Biodynamic Farm Standard by using best practices, such as those proposed by the ISEAL ALLIANCE (29), for example.
- Reassesses the value of its relationship with the USDA NOP, especially for determining what synthetic or non-organic chemicals are currently allowed in Biodynamic® farming.
- Determines whether the operations it has certified exemplify the objectives of its program.
- Establishes strict marketing guidelines to avoid greenwashing.
- Formalize and documents its interpretations, and make them available to the public.
- Creates mechanisms to prevent potential conflicts of interest between standard-setting and certification activities.
- Works at being more transparent.
Given the findings of this evaluation, assessments of DEMETER-USA’s standard-setting and auditing processes, areas of potential conflicts of interest, equivalency arrangements, the accountability of Demeter-International, and the Biodynamic Processing Standard are also needed. Because Biodynamic® wines play an important role in DEMETER’s marketing strategy, membership, and their increasing popularity in the consumer market, special attention should be given to the soundness of DEMETER’s Wine Standards. Ironically, Rudolf Steiner argued that,
Wine was that which separated man from everything spiritual. He who takes wine cannot arrive at the spiritual” (36) and, “In future, people will be able to say in the most literal sense that it was the task of alcohol to pull man down into the material world so far that he would become selfish, and that alcohol would lead him to demand the use of his self for his own purpose, so that it would no longer serve the whole nation (37)
This evaluation may appear to be rather harsh in many regards. Criticism can be valuable despite the initial discomfort that it may cause; it is a useful feedback mechanism that can provide positive and productive motivation for change, and ultimately make a product or service stronger. Once the UDSA-NOP deception is fully exposed, many consumers will become cynical and question the integrity of all certification programs and doubt the authenticity of all food labels. Some certifiers and producers will resort to making even more outlandish marketing claims in hopes of securing the faith of the remaining ill-informed and credulous consumers, while others will elect to work on their integrity, optimistic that in the end virtue will be rewarded by people seeking spiritual solutions.
This assessment was produced from a consumer for another, from a biodynamic enthusiast for another, from a certification expert for another, and from a spiritual being seeking the harmony of all truths for another. Perhaps in its wake, this evaluation will inspire people to exact positive change.
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(25) Stellar Certification Services (SCS) BL/T –100 Terms of Agreement 02_14 TERMS OF AGREEMENT http://www.demeter-usa.org/forms/general_info_for_all_applicants/New%20Applicant%20Packet/SCS%20Terms%20of%20Agreement.pdf
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(37) Steiner, R.1908. Gospel of John Lectures 23rd May. A cycle of twelve lectures given at Hamburg, May 18–31, 1908. Translated from shorthand reports unrevised by the lecturer, from the German edition published with the title, Das Johannes-Evangelium (Vol. 103 in the Bibliographic Survey, 1961). Translated by Maud B. Monges. Copyright 1940 by Anthroposophic Press, Inc.
(38) DEMETER-USA: The Biodynamic Collective – 2015 ToolKit. http://www.demeter-usa.org/downloads/Demeter-Tool-Kit.pdf
 Stellar Certification Services INC.is an accredited certifying agent to the USDA National Organic Program. This accreditation does not pertain to biodynamic agriculture.
 The FTC defines puffery as a “term frequently used to denote the exaggerations reasonably to be expected of a seller as to the degree of quality of his product, the truth or falsity of which cannot be precisely determined.”