News from the review of the Canadian Organic Standards
Biodiversity and animal welfare on the agenda
by Janet Wallace
In mid-September 2024, the Technical Committee on Organic Agriculture (TC) of the Canadian General Standards Board (CGSB) met to discuss proposed changes to the Canadian Organic Standards (COS).
During the five-hour online meeting, Working Group chairs presented various recommendations to improve the standards. The TC had three choices - to accept, reject or resubmit the recommendation to the Working Group (WG) if it needed clarification or background information. A draft containing all the recommended modifications to the standards will be made available for public review in the spring of 2025.
In this article, we present several petitions currently being discussed by the Technical Committee.
Crop production
Protecting native ecosystems
A clause was added to the 2020 standards to promote biodiversity. Specifically, 5.2.4 requires that organic farmers take measures to “promote and protect ecosystem health” by, for example, providing habitat for pollinators or wildlife. A note to the clause recommends (but does not require) that “existing native prairie, parkland, or wetland habitats should be maintained and enhanced whenever possible.”
A desire to strengthen this clause has led to a proposal that “a site supporting a native ecosystem cannot be certified for organic production as provided for under this regulation for a period of 10 years from the date of conversion.” The petitioner explained that “organic producers are tempted to cultivate native prairie due to ease of transition (no history of use of prohibited substances), immediate soil fertility benefits, and likely lower weed pressure. …Much of this conversion is done by opportunistic, economically driven organic producers and it should be stopped.”
To “disincentivize this practice,” the Crop Working Group recommended a 60-month wait between land clearing and harvesting an organic crop. The time period includes one to two years for the clearing process plus a three-year transition from a prohibited practice (clearing of native ecosystem).
Several caveats will be added so that this clause would not affect:
the maintenance, management or revitalization of existing agricultural land;
operations with less than a total of 15 hectares in cultivation after clearing has occurred;
producers of native plants, such as wild blueberries;
land that was cleared previously (e.g., old farmland that has grown up in alders and white spruce).
Fence posts back to the table
Currently, organic farmers can’t use treated fence posts for new installations (although recycling treated fence posts is permitted as outlined in Clause 5.2.3). In 2023, when SaskOrganics asked organic operators about what changes they would like to see in the standards, “fence posts treated with prohibited substances were identified as an item for review because alternatives to pressure treated fence posts are in many cases significantly more expensive and often not as efficient to install.”
SaskOrganics requested that the standards review consider “all types of farms, especially large-scale crop or livestock operations on the Prairies” and consider allowing treated fence posts when there is an acceptable distance from organic crops and for perimeter fencing for livestock operations (perimeter fencing).
The Crop WG is proposing to allow new installations of treated fence posts only for perimeter fencing but with the stipulation that “treated posts shall not come in contact with the organic crop (including roots) or organic livestock.”
Crop rotation better defined
Crop rotation is a key tool used by organic farmers to control pests and weeds, support diverse and abundant soil life, and provide fertility. However the crop rotation requirements of the standards are vague and begin with the caveat “where appropriate.” Unfortunately, it appears that various certifying bodies interpret (and enforce) Clause 5.4.2 in different ways. The Crop WG has recommended the following clarification (note underlined words are additions whereas strikethrough indicates deletions):
5.4.2 Where appropriate, the soilSoil fertility and biological activity shall be maintained or increased, through:
a) crop rotations or sequences that are as varied as possible and include diversified including:
1) plough-down crops, legumes, catch crops and deep-rooting plants; 2) cover crops to prevent erosion; or 3) the same annual cash crop species planned for more than two years in a row;
b) incorporation of plant and animal matter in compliance with this standard and with Table 4.2 (Column 1) of CAN/CGSB-32.311, including the following:
1) composted animal and plant matter;
2) non-composted plant matter, specifically legumes, plough-down crops or deep-rooting plants within the framework of an appropriate multiyear a multi-crop rotation plan; and
3) unprocessed animal manure, including liquid manure and slurry, subject to the requirements of 5.5.1.
c) where appropriate, perennial cropping systems employ techniques such as alley cropping, intercropping.
Maple products
The Maple Working Group (WG) addressed several petitions including:
Defoaming products when evaporating sap
The WG recommends specifying “Only plant-based organic defoaming products are permitted, e.g., organic vegetable oils with no allergenic potential,” in addition to wood from Pennsylvania or striped maple (Acer pennsylvanicum) from the organic operation.
Biodiversity in the maple forest
The standards specify that organic sugar bushes must contain more than just sugar maples in 7.2.9.1. While debating the maximum allowable percentage of maple trees in a stand, the working group balanced the value of biodiversity with the potential competitive effect of non-maple trees. They also considered the challenges of non-organic producers who currently have pure maple stands but want to transition to organic production. Although transition may take three years, it can take much longer for trees to reach maturity.
The recommendation from the WG states that “Operators shall encourage a diversity of plant species in the sugar bush, particularly companion species to tapped maple trees. Companion species shall be encouraged by aiming for a minimum percentage of 20% of all trees in the sugar bush. Undergrowth and brush must be protected. Partial cutting of this vegetation is authorized for the creation of paths to facilitate movement. Gap cutting is permitted if the overabundance of native understory vegetation prevents the establishment of maple regeneration.”
While evaluating the proposed changes, the TC considered many factors, including the following.
Does the proposed change meet the principles of organic agriculture? The principles of health, ecology, care and fairness are outlined in 0.2 of the standards.
How does the proposed change affect other lifeforms, such as beneficial organisms? While discussing proposed additions to the Crop Permitted Substances List, the TC raised the question of how a new substance might affect bees and other insects.
Do we need to update the standard in the context of climate change? Organic farmers are facing ever-increasing challenges beyond just increasing temperatures, such as
- more intense storms and temperature fluctuations;
- new pests and more intense pest pressure;
- heavy rains and flooding (which can inhibit a farmer’s ability to control weeds by
cultivation);
- more frequent and prolonged drought (which can limit the availability of organic forage
for livestock).
Livestock production
Monitoring livestock
Monitoring livestock frequently is important for animal welfare. Consequently, the Livestock Working Group decided to add a requirement for monitoring livestock health and living conditions; the details vary depending on species and type of operation. For example, on large cattle ranches, it may be impractical for a rancher to check all animals daily even with a drone. The WG recommends adding text below along with additional details on how frequently animals on pasture need to be monitored
" 6.1.7 Organic livestock shall be monitored for health, welfare and proper function of housing, feeding, watering and fencing systems at the frequency required in the applicable Code of Practice (see 2.4) or an equivalent or superseding welfare program.
a) Where the Code of Practice or equivalent programs do not regularly require daily checks, at minimum all confined livestock (not on pasture or extensive rangeland) or livestock reliant on a mechanical feed or water source shall be monitored at least once daily.
b) Individuals responsible for monitoring livestock shall be trained and competent. "
Outdoor access for pigs... everyday
Currently, Clause 6.15.2 requires that pigs (other than sows with nursing piglets) “have access to outdoor exercise areas.” The clause adds that "Outdoor access can be temporarily restricted as stated in 6.7.2,” such as inclement weather, conditions that could jeopardize livestock health or conditions that could compromise soil, water or plant quality. Unfortunately, the clause doesn’t specify how often pigs should be allowed outside.
The Livestock WG is proposing that 6.15.2 requires that pigs “have daily access to outdoor exercise areas.” The same caveats apply.
A diversified diet for pigs and poultry
Clause 6.4.3 l) requires that operators provide poultry and pigs with “vegetable matter other than grain.” Many operators have questioned what type of vegetable matter would suffice. There were also questions about whether the vegetable matter had dietary advantages or was a form of environmental enrichment (in which case the clause should be moved to living conditions).
It turns out that vegetable matter, particularly roughage, provides many benefits. It supports a healthy gut biome (intestinal microorganisms) in pigs and poultry. As well, fibre provides a sense of satiation. Basically, the pigs and chickens feel ‘full,’ not hungry, and this reduces the frequency of aggressive behaviours such as feather picking. In addition, vegetable matter enriches the environment by giving livestock something to manipulate, whether it is hay or vegetables, but environmental enrichment is addressed specifically in other clauses.
The Livestock WG proposed to clarify 6.4.3 l) so it requires that poultry and pigs “have daily access to organic plant material vegetable matter other than grain; (i.e. the cereals, pulses and oilseeds normally found in the concentrate portion of a ration). Acceptable sources include but are not limited to pasture, hay, straw, alfalfa pellets, corn cobs, vegetables or fruit."
Companions for dairy calves
The Livestock WG decided to add a requirement that dairy calves should be housed in pairs or groups whenever possible. Cows are herd animals and calves benefit from social interaction. Research shows that calves in pairs or groups engage more in play and other healthy behaviours compared to calves kept individually in hutches. This increase in activity improves bone and muscle growth, and is associated with less unhealthy behaviour (e.g., abnormal licking of objects). Just allowing calves to see each other or touch heads provides some benefits compared to complete isolation, but not nearly as much as if they have “full-body social contact with their companion.”
The new requirement in 6.12.5 has caveats however.
The requirement only applies to “calves that are healthy, thriving, and compatible in age, size, and drinking speed” to avoid unhealthy competition between calves of different ages. If calves can’t be paired up, they can be temporarily housed in individual pens and hutches but these must be designed and located so that each calf has physical contact with other calves.
Calves that are sick may be housed individually temporarily to avoid spreading disease.
Dairy farms that currently use individual calf hutches have up until December 2027 to update their infrastructure.
....Next steps
Keep checking InfoBio, the monthly newsletter of the Organic Federation of Canada! Discussions on the proposed modifications to the Canadian Organic Standfards will continue at the 2.5-day in-person meeting of the Technical Committee that will be held in Gatineau, QC, on November 20-22..
In the spring of 2025, all the proposed changes to the Canadian Organic Standards will be published and available for public comment.
Modernizing Organic Production Systems
The webinar about the review of the Canadian Organic Standards is online!
Don't miss out on this valuable opportunity to learn from the experts and gain a deeper understanding of the changes shaping the future of Canadian organic standards!
Created by COTA as an Organic Month event, and featuring Janet Wallace (writer, editor), Tristan Banwell (organic livestock producer), Rochelle Eisen (organic inspector and Working Group Chair), Joel Aitken (Working group participant) and Nicole Boudreau (manager of the review), this webinar describes how the review is managed, and how organic practices are updated and transcribed into clear and applicable organic standards.
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Need to review the highlights of the review? A list of articles is available on the OFC website
Should the Canadian Organic Standards (COS) should contain social justice requirements? The results of the survey
The use of guano in organic production systems – good or bad? Guano: organic fertilizer or trigger for war and pandemic’s? Click here
Reducing the impact of agriculture and improving resilience to climate change - Click here
A diversified menu: from insect care to struvite, parallel production to sprout inhibitors - click here
The recipe for a successful standards revision?
Competent people, an active commitment, patience and an adequate budget! Click here
Yo-yo organics?Alternating between organic and conventional - a variety of opinions - Click here
OFC needs your support!
Supporting the revision of organic standards
Canada's best investment in sustainable food production
The Canadian Organic Standards (COS) are being rejuvenate. This update of the COS allows the organic industry to keep abreast of innovations and best practices in sustainable and resilient agriculture.
The review also ensures that the Canadian Standards are in line with the standards of our trading partners on international markets and maintains consumer confidence in Canadian organic produce.
The beauty of the exercise is that the industry actively participates in the revision work in several ways:
submitting proposals for changes to the standards;
participating in task forces and working groups;
delegating representatives to the Technical Committee on Organic Agriculture to discuss and vote on proposed changes;
providing feedback when the draft of the revised standards is launched during the Canadian General Standards Board’s public comment period.
The budget for the review is made up of a contribution from Agriculture and Agri-Food Canada and matching funds from the industry. The Organic Federation of Canada (OFC) does not have stable, recurring revenues to cover the matching funds required to complete the standards’ revision. That's why OFC needs for your support.
Contributing to the financing of the standards revision
is your best business decision.
The budget of the review - $ 677, 000
AAFC's contribution - $ 502,000 Industry matching funding required by AAFC - $ 175,000
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