Composters Beware - BBA is Watching

Helena, MT

Did any of you read the recent article in Dave's newsletter by Mr. Rodman about the FDA imposing new regs this year on pathogens in manure composting? If not, you may want to do so. I have my own views on this subject which I would be glad to share with you if any of you are interested.

Milton, MA(Zone 6a)

This one?

Helena, MT

That one.

Anne Arundel,, MD(Zone 7b)

I read it when it ran. As I recall, this has to do with commercial farming. I am OK with trying to ensure that no one sells me food with "fresh manure" on it.
mraider, what are your thoughts?

Milton, MA(Zone 6a)


Everett, WA(Zone 8a)

I don't think I should post links to competing web sites, but I can copy-paste my own posts.

Probably my reaction to the act comes down to whether I expect government regulations to accomplish anything WRT huge corporations that already pay less than minimum wage for to migrants to poop in their fields and pick crops with the same hands.

Whether it will tend to (or was designed to) put small growers and organic growers out of business.

Or whether it will just be a layer of bureaucracy that assures profit goes only to those who can deal with mega-paperwork.

= = = = =

Speaking of manure, all the E. coli food poisoning cases a few years back got the "Food Safety and Modernization Act" passed. I asked my legislator not to support it, or at least make it not apply to small market growers, but she was gung-ho for safety and modernization.

She didn't think it was a way for agribusiness to put pressure on small growers who didn't know how to comply with FDA paperwork.

Funny how fast gardening and farming get into politics!

FSMA might be overkill, but what do I know? Sorry these are not newbie level quotations! If I were you, I would till in a few inches in early spring, and just not harvest for the first few weeks or month, and/or wash leafy things carefully. Like, being somewhat more careful than gardeners have been for the last 5,000 years with good results.

Or just plain not worry about it. I wish other home gardeners with manure experience would chime in!

The FSMA includes some standards about manure, but you were already probably not going to drop horse patties among lettuce plants, hit it with a hard water spray, and then eat the lettuce the same day.

Food Safety Modernization Act of 2010 (H.R. 2751) Biological Soil Amendments: Subpart F

Currently, within the U.S., composting of animal manure is not specifically regulated by any federal agency with respect to the safety of its use in the broad production of all produce. Instead, state and local regulations in some cases provide oversight, but this varies in scope and complexity

"Establishes requirements for determining the status of a biological soil amendment of animal origin as treated or untreated, and for their handling, conveying, and storing (proposed §§ 112.51, 112.52);
Prohibits the use of human waste for growing covered produce except in compliance with EPA regulations for such uses, or equivalent regulatory requirements (proposed § 112.53);
Establishes requirements for treatment of biological soil amendments of animal origin with scientifically valid, controlled, physical and/or chemical processes or composting processes that meet or exceed specific microbial standards (proposed §§ 112.54 and 112.55);"

"Establishes application requirements and minimum application intervals for untreated and treated biological soil amendments of animal origin (proposed § 112.56); and
Requires certain records, including documentation of application and harvest dates relevant to application intervals; documentation from suppliers of treated biological soil amendments of animal origin, and scientific data or information relied on to support any permitted alternatives to requirements (proposed § 112.60)."

Thumbnail by RickCorey_WA
Helena, MT

I do believe Corey got it. Although it appears at first that this is aimed at Big Ag, it's not. I don't know where Mr. Rodman got his information, but if his statements are in any way close to what is going on here we should be concerned. Although, like Sally says, it first appears that this is meant for Big Ag., it's not. Big Ag uses chemical fertilizers and not manure. On closer review of Mr. Rodman's article It appears to me that this is nothing more than a diversionary tactic to draw attention away from the real problem.

Big Ag has been polluting our food, land and waters for years with their chemical use practices. These more recently reported problems with food poisonings across the country from pathogens in our food is not coming from food grown by organic farmers, but from improper hygiene practices of farm workers who are harvesting foods for Big Ag.

However, from the sounds of it the FDA like the USDA is just another log arm of BBA trying to enforce more regulations on the sustainable gardening community with a twisted version of the EPA 40CFR Part 503 regs for land applying municipal wastes (Biosolids) to agricultural land.

The idea that pathogen run off from improper composting practices into waterways and ground water as reported in Mr. Rodman’s article is simply ludicrous. Also lunacy is the idea that pasteurization or thermophylic composting is the only acceptable way to prevent this non-problem. If anything incomplete hot composting is more apt to retain pathogens especially in the northern half of the country where the required temperatures are impossible to retain throughout a hot compost pile.

A far better way of dealing with pathogens in the composting of fresh manures is the use of compost worms or vermicomposting. But really, how many organic farmers are using un-composted fresh manure in their gardening practices.

Anne Arundel,, MD(Zone 7b)

THe core of this , as with most anything these days, is that the powers that be must find 'hobgoblins' to save us from, to give them something to do and a budget to do it with. Invisible pathogens on food s a good scary one.

Everett, WA(Zone 8a)

The part of the FSMA I would agree with (if I trusted the system to withstand the pressures of campaign finance, which I don't) would be the supposed in tent to make it easier (possible) to trace E. coli and other pathogens in lettuce back to the company that saved 10 cents per ton of produce, and gave 1,000 people the runs.

That seems worthwhile for huge conglomerates. Identify them, penalize them, sue them,l and inspect more often. Instead of sequestering funds for inspectors.

The remediation process that I envision for local organic producers and marketers is: one person gets sick, the whole country stops buying from that farm for a year or three. And the enforcement method is already in place: local producers aren't stupid enough to poison local customers who can read the name of their farm on their truck or crate.

To some extent it comes down to "who do you trust?"

(If you're a fan of the Crusade TV SF series, I would add "And who do you serve?"
Lobbyists, or customers.)

Milton, MA(Zone 6a)

"Except in compliance with EPA regulations for such uses?" I didn't know it was allowed to use human poop anywhere?

Anne Arundel,, MD(Zone 7b)

I guess that would be referring to processed sewage output----there has been experimenting with in this are for decades, here and there.

Milton, MA(Zone 6a)

Ugh. I'm not sure I wanted to think about that. Nightsoil, as long as they keep it in Japan, is ok.

Everett, WA(Zone 8a)

>> I didn't know it was allowed to use human poop anywhere?

Actually, sewage treatment plants treat it, turn it into sludge, compost and treat it further, test it for pathogens and heavy metals etc, then dry it.

Then it's called "biosolids" (Class A or B) and gets used in agriculture and composting. Both Class A and B are licensed to be spread on crop land in specified ways by licensed farmers. Class A is approved for home garden use.

And biosolids are sold or given to composting companies like Cedar Grove. It's as wide-spread as sewage treatment plants. They already HAVE to make sludge non-hazardous, because it has to go somewhere. And once it is non-hazardous, might as well use it as fertilizer.

Let's just hope that sequestration doesn't de-fund the inspectors that do the testing!

Bon apetit!

This message was edited Mar 6, 2013 1:16 PM

Milton, MA(Zone 6a)

"And once it is non-hazardous, might as well use it as fertilizer." Ok, makes sense.

Helena, MT

Corey has it right again. Class A sludge is commonly used in commercially solid fertilizers if you care to read the label. Percentages vary but it is still there. Remember Milorganite, from Milwaukee’s finest sewers? This product was marketed back in the 70’s and within a year more than fifty brands o the same thing were sold in California alone. That same decade the EPA started their 40 CFR Part 503 program for land application of Biosolids which allowed the approved sewage sludges to be applied to crops such as corn, wheat, milor, soybeans, etc. EPA listed about half a hundred priority pollutants along with ten heavy metals and Fecal Coliform testing among their criteria for Class B sludge testing which had to be met in order to apply sludge to those crops. If that makes you comfortable, then fine. However, as I have stated before there are far more chemicals in wastewater sludge than you may realized, and regardless of the Class, A or B, I personally would never use this material in my garden. Using materials containing Biosolids on your lawn, trees, shrubs, and flowers is fine.

So, if the FDA is planning on using some twisted version of this type of regulation for approving animal waste composing, watch out. It will not be aimed at Big Ag, and more than likely will be just another hoop for the Certified Organic Farmer to jump through.

Milton, MA(Zone 6a)

My cousins used to be Certified Organic but they finally decided it wasn't worth the paperwork and hoop-jumping. Now their produce is certified 'ecoganic."

Charlotte, NC(Zone 7b)

Dead, Lifeless Food

I am so glad I know how to raise "real" food!

Anne Arundel,, MD(Zone 7b)

One link in the article leads to a Michael Pollen piece about Joel Salatin, the "ultra sustainable " (if I can describe it in a short phrase) farmer- same farm Pollen talks about in detail in his book. Very interesting guy/ place (Polyface Farms) .

Everett, WA(Zone 8a)

>> EPA listed about half a hundred priority pollutants along with ten heavy metals and Fecal Coliform testing among their criteria for Class B sludge testing

Thanks, I didn't know it was that broadly based.

I'm not very concerned about how inclusive or tight the legal standards are (and I understand that many reasonable people ARE more concerned than I am).

I'm more concerned that large corporations may be able to evade the regulators, and that Congress will (and has) defunded many kinds of federal inspectors.

Sewage treatment plant engineers, I trust, as long as their bosses and municipalities give them the funds and equipment needed to perform the required tests and regulators oversee the process.

(I understand that many reasonable people have either more or less trust than I do for engineers, managers and government representatives.)

Everett, WA(Zone 8a)

Thanks for that link, HoneybeeNC, even if it does mean that, yes, FSMA is as bad as I feared.

>> Since then, farms with less than half a million dollars in annual sales have been exempted from the legislation.

>> only keep 10 to 15 percent of that in profits. That means it could cost farmers making as little as $50,000 a year as much as $10,000 annually to comply with the new rules. That’s a fifth of their income eaten up by regulation.

>> In addition to pasteurizing juices and other processed and packaged foods, the agency would like all “fresh” fruits and vegetables to be irradiated.

Anne Arundel,, MD(Zone 7b)

>> In addition to pasteurizing juices and other processed and packaged foods, the agency would like all “fresh” fruits and vegetables to be irradiated.""

Seriously people---how many tons of food is eaten annually versus how many outbreaks? So what percentage of food carries pathogens? And for this we irradiate everything? How did we survive for all these centuries- not even modern refrigeration till the last hundred or so...

Everett, WA(Zone 8a)

I could very easily believe that our immune systems NEED regular challenges to stay functional. Maybe many cancers and auto-immune diseases result from immune atrophy due to "clean living", meaning "over-clean and and unnatural living".

That is pure and unfounded speculation, just my guess. I don't claim any support for it.

However, it is documented that some Yale dietary researchers went to China to try to figure out why peasant farmers in some regions were perfectly healthy despite diets that "should" have resulted in several severe vitamin deficiencies.

They observed and concluded that, yes, all that rice and so little else SHOULD have caused all kinds of severe deficiencies. So they went home and fed a bunch of Yale undergrads the extact same diet, and those undergrads promptly came down with all the deficiencies predicted.

They finally figured out the difference: in China, food prep left tiny traces of soil on the food. The soil bacteria and yeast they were ingesting provided the vitamins needed for health.

Clean the food "to death" and yes, the people would die also.

Enterprise, AL(Zone 8b)

It appears that we should all play in the dirt(garden) more!

Milton, MA(Zone 6a)

Rick, I was introduced to that theory 30+ years ago, when I was diagnosed with mononucleosis as a teenager. My grandfather (who would have been a great link-clicker) looked into it, probably amounting to reading all the back issues of Scientific American he could find. Anyway, he discovered that

a.people all over the world test positive for antibodies to the virus (i forget what it 's called) but very few people experience symptoms,'s considered a disease in 'developed' countries, where due to 'improved sanitation' folks don't get exposed to it until early adulthood.

c.if you catch this virus as a two-year old, you get the sniffles for a few days and thereafter have a positive titre for whatever-the-heck it is

d.if you make it to adulthood without encountering this virus, you might get mono. Which might be serious.

What I don't understand is how *I* fell into the category of unexposed, as I recall my childhood as being fairly grubby, eating stuff of of trees and out of fields w/o washing, gathering wild berries etc. Didn't feel terribly sanitary. I also don't understand why this is NEWS, as I knew it 30 years ago. OF COURSE you shouldn't wipe yourself down with alcohol every minute, OF COURSE there are good bacteria as well as bad bacteria, and if you've ever taken antibiotics and eaten yogurt to repopulate your gut, you understand this theory. I just hope it doesn't put the organic or "eco-ganic" farmers I know out of business.

Milton, MA(Zone 6a)


Everett, WA(Zone 8a)

Carrie, I think that many :"childhood" diseases work similarly. 99.9+% of kids recover in a few days, but 70% of unexposed Native Americans or Hawaiians die. (I wonder if there isn't some genetic basis to immunity where your B-cells start out primed with the antigens that killed off 70% of your ancestral generations. Can they be activated or selected for in a multi-generational way?

Children do have strong immune systems, or they used to before Sani-Wipes and Lysol spray on every surface they touch. If we live in a bubble, we're probably much more vulnerable when the bubble pops.

I also gather that recent generations need to be reminded that "play" ideally means "play OUTSIDE". I thought I was hallucinating the first time I saw a TV ad urging kids to play OUTside "an hour a day", and offering web sites to TEACH them how to play.

I guess their parents think they'll be abducted by Mongols or struck by lightning. Compared to the risks of obesity and heart disease, give me Mongols any day!

Did I exit the wrong door on some bus and now I'm in Bizarro-Universe?

Anne Arundel,, MD(Zone 7b)

I'd love to stray far afield of the original thread but let me say that I feel its modern overintensive farming/ agriculture/ animal raising METHODS that are putting more dangerous bacteria around our food, more so than what's in the field. Or used to be in the field before the modern era of chemical fertilizers and X-icides. Now, whether we can still feed six plus billion people a year, without these methods/ chemicals.... not sure. Maybe you can only feed 5 billion safely, and trying to get to six billion you would have some number succumbing to diseases caused by over-harvesting of the system (earth)

Fascinating link seedfork.

Madras, OR

I use hot composted manures from a stock yard that feeds organic alfalfa. It is steaming hot when it gets here, it sits for a year, then is composted with a variety of leaves, grass, straw, and kitchen refuse. So by the time it gets to the garden, it is 18 months old. For things that need feeding along, I use a granular commercial organic feed, to side dress plants. I never put fresh manure in the garden during the garden season.

I often will put some on the beds in the fall once they are empty and turn it under.

I would not recommend treated sewage. While is is bacteria free in most cases, it also contains any medication excreted from peoples bodies, and if it has not broken down completely, not sure about what you might be getting. We do know that treated sewage water when allowed to seep back into rivers, can case sexual malformations in fish due to the presences of hormones. So I am assuming that its half life is quite long. Other medications may have similar presences.

Milton, MA(Zone 6a)

Nancy, I would be happy to smell, anoint myself with, eat, ingest, balm, etc, products from YOUR garden. The ones who manufacture my veggies--I'm not so sure.

Everett, WA(Zone 8a)

>> I use hot composted manures from a stock yard that feeds organic alfalfa. It is steaming hot when it gets here, it sits for a year, then is composted with a variety of leaves, grass, straw, and kitchen refuse.

I was curious about why you use two-step composting.

If you mixed the grass and straw as soon as the hot (literally hot) manure arrived, might you not kill a few more weed seeds or soil pathogens (from your grass and straw) by putting them through "extra hot" composting?

Or are you more concerned about the manure than the yard trimmings, and deliberately WANT to give the manure extra "finishing time" (like 18 months instead of 12)?

Or maybe you don't want the yard waste to be "over-cooked", and start to waste (burn up or leach out) some of the organic matter and minerals by composting for 18 months instead of six?

Just curious and hoping to learn from your experience and reasons.

Burnt Chimney, VA(Zone 7a)

I'm a novice, but I think I know the answer to that, besides the undigested seeds that have passed thru the animal's gestation system. The "hot" poop may burn the tender plants. I know that mulch must sit for a long while, until it's 'heat' has passed. The heat buildup from fresh mulch can even start fires. But like I said, I'm a wee novice, I am. Definitely!

Everett, WA(Zone 8a)

I never knew the hot manure needed a whole 12 months to cool down to room temperature! I would have guessed 2-4 months.

And you're probably right that a cow has more weed seeds in her belly than yard waste does.

Burnt Chimney, VA(Zone 7a)

Oh, I know that part (seeds) from ugly, first-hand experience, sad to say! Year before last, before my husband's health declined, we had a local farmer bring us horse manure & till it into the garden. (When his health went down, the garden was sadly ignored - never a good thing!) Because of neglect, I STILL have what I call cowshiznit plants come up in the garden, big, ugly, thorny thick-stalked plants with (hate to say it ) rather pretty white flowers that appear. Not a clue what they're really called. You see them in any pasture you pass, and they're beasts to get rid of! Live & learn, what can I say? Yuck!

This message was edited Mar 15, 2013 10:41 AM

Enterprise, AL(Zone 8b)

That sounds like some type of thisle.

Charlotte, NC(Zone 7b)

I thought thistles had pinky/purpled flowers.

Burnt Chimney, VA(Zone 7a)

Woohoo, I searched Bing for images of weeds in a cow pasture, and found not only two pictures (one in flowering stage, and one in ... ? ... seed pod stage, maybe? One of the images said something about "jimson weed." But anyway, here's my cowpoo weeds, beastly monsters -
They've got some wicked constitution to themselves.

Thumbnail by sparklinBarb Thumbnail by sparklinBarb
Charlotte, NC(Zone 7b)

Barb - you have my sympathy with this dreadful weed. I looked it up:

It's extremely poisonous!

Good luck with your attempts at removing it from your garden.

Burnt Chimney, VA(Zone 7a)

:o) Thank you, Honey. At this point, I'm not at all adverse to calling in a bomb squad. That's ok, we all need challenges in our life!

Anne Arundel,, MD(Zone 7b)

I swear I almost suggested Jimsonweed... We had a new development going in behind us several years ago. Former woods and horse fields that were not particularly well maintained. At one stage they leveled the ground but left it lie. Acre of solid jimsonweed the next summer!!! It was UN BE lievable. There must have been loads of dormant seeds there from the occasional plants in the field.
Just keep after seedlings like you do with any other weeds.

Burnt Chimney, VA(Zone 7a)

LOL Aren't they gross, Sally? I was looking at allll the pods last evening from the deck. I'm getting out there today between church and this evening's bible study & building a bonfire, if the wind will permit!

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