Food – Organic

Saxton Freymann ©Play With Your Food LLC. Used by permission

Did You Know?

  • An overview of 343 peer-reviewed studies showed organic plant-based foods contained a 19 to 51% increase in antioxidants (depending on the chemical) that reduced heart disease, neurodegenerative disease, and certain types of cancer. It also found the toxic metal cadmium (found in phosphate fertilizers) was 48% lower, while pesticide levels in conventional food increased 400%.
  • Another overview of 41 studies showed organic crops contained 27% more Vitamin C, 31% more iron, 29% more magnesium, and 14% more phosphorus, while toxic nitrates were 15% lower.
Organic Food

Purchasing food that is labeled organic is a main way that American consumers can not only avoid ingesting toxins, but also enhance the nutritional value of their food.  Organic food employs natural materials and processes to the greatest extent possible, and only falls back on pesticides and additives when other methods have failed.  Even then, the pesticides and additives are the least-toxic chemicals available.

For several decades, organic food was ridiculed by critics as an ineffective, impractical, countercultural reaction to industrial agriculture.  This has not stopped growing consumer acceptance.  In 2016, 82% of Americans would admit to purchasing organic food and beverages.1  An estimated 15% of produce sales and 6% of all food sales were organic, amounting to $52.5 billion in sales.2

Following is a brief description of the damage that our industrial agriculture system has created, and how organic agriculture can change it to be more sustainable.


Soil: Erosion and loss of nutrients from agriculture is one of the world’s most pressing dilemmas.  Without an adequate topsoil base, agricultural production sufficient to feed humankind could not occur.

Under natural conditions, topsoil that can support crops is created at the rate of about one inch every 500 years. 3 Due to erosion and degradation from nutrient and soil microorganism depletion, the U.S. has lost over 50% of its topsoil.4  In 2015, U.S. cropland eroded at a rate of 4.62 tons per year, while natural soil formation occurred at a rate of only about 0.5 tons per year.5   And while the U.S. loses soil almost 10 times faster than it is produced, China and India are losing it at a rate 30 or 40 times faster.6  By one estimate, the world only has about 60 years of topsoil left.7

The bottom line is that the world’s soils will produce substantially less food while demanding more water, fertilizers, and pesticides for the food that the deteriorating soil can still support.  Meanwhile, the world’s population is predicted to soar 47%, from 7.7 billion in 2019 to 10.9 billion by 2100.8

For industrial agriculture, soil is viewed as a kind of chemical sponge to which fertilizers are applied through intensive ploughing.  Because of this, soil loses much of its: 1) carbon content; 2) nutrient value; 3) beneficial microorganisms; 4) ability to hold water; and 5) ability to support plant life without continued chemical and mineral inputs.  Often the soil lays bare and unprotected after harvest, making the cropland more vulnerable to erosion from wind and precipitation.  It is also common to burn or remove crop residues that could prevent some of this erosion or be used as a natural fertilizer.  And it is common practice to plant the same crop for years at a time on the same land, simultaneously draining it of the nutrients the particular crop requires while allowing pests of the particular crop a better chance to establish themselves.

In contrast, organic agriculture fertilizes and builds soil quantity and quality with plant compost, manure, plant and crop waste (a.k.a. “green manure”), cover crops that simultaneously boost nitrogen and nutrient content while protecting from soil erosion, and crop rotation which can balance nutrients from different crops in different years. Crop rotation also makes it more difficult for pests to proliferate, since pests for one plant may not thrive on a different crop.

In the process of building the soil, several other beneficial things occur.  One of these is greenhouse gas reductions, because organic agriculture adds carbon to the soil.

How much carbon can be stored in the soil will vary with crop, soil type, and climate.  However, one analysis based on data from California estimated that if all of the state’s cropland was farmed organically (instead of the 4% of cropland that was organic in 2017), the state’s annual net emissions would decrease by 36.4 million metric tons of carbon dioxide equivalent gases, about 9% of the state’s 2017 total greenhouse emissions.9

Soils high in organic matter are also better at retaining water.  While 40% of rainwater falling on dry, uncovered soils is lost due to runoff, soils on organic farms can retain 90% of their weight in water.   

Fertilizers: America used over 23 million tons of commercial crop fertilizers (nitrogen, phosphate, and potash) in 2014.10

As much as 1% of U.S. energy in that year was used to manufacture and utilize them, most of it in the manufacture of nitrogen.11  Some of the nitrogen embedded in agricultural fertilizers is released into the atmosphere in the form of nitrogen oxides (NOx).  Since NOx is a powerful greenhouse gas with a global warming effect 298 times the intensity of carbon dioxide, 4% of U.S. man-made greenhouse gas emissions were from fertilizers.12

NOX is also a major air pollutant, combining with Volatile Organic Compounds in the presence of sunlight in the atmosphere to form ozone that can aggravate heart and lung disease.  About 17% of U.S. nitrogen dioxide emissions in 2017 came from synthetic fertilizers.14  A 2018 study of the state of California estimated that between 20 and 51% of total state NOX air emissions came from synthetic fertilizers.15 

Excessive levels of nitrogen can also severely pollute water.  Agricultural fertilizer and manure run-off in food-producing regions of the U.S. have contaminated drinking water with high levels of nitrates.  This has been statistically associated with increased levels of cancer, premature births, and birth defects.  A 2019 meta-analysis of studies of nitrate pollution in the U.S. estimated that almost 13,000 increased cases of cancer, as well as 4,700 preterm or low-birth weight babies occur annually due to the pollution.16  A 2013 study proved that mothers who consumed elevated levels of nitrates compared to a reference group of low-nitrate consumers were 80 to 100% more likely to have children with certain birth defects.17

Major “dead zones” line the Gulf and Eastern Coasts of the U.S., and have encroached on large parts of the U.S. Pacific Coast as well.  In these areas, nitrogen and phosphorus fertilizers carried by rivers into the oceans cause excessive algae growth.  When the algae die, the decomposition process removes oxygen from the water, causing most or all sea life to die.

The largest American example is the Gulf Coast dead zone surrounding the mouth of the Mississippi River.  This dead zone grows seasonally as fertilizers from the Midwest Grain Belt run-off into the River and eventually make their way to the Gulf.  Its record size (in 2017) was 8,776 square miles, about the area of New Hampshire.18  About half of the nitrogen water pollution comes from crop fertilizer run-off and Combined Animal Feeding Operations.19

These commercial fertilizers are prohibited in organic food production.

Depiction of Gulf of Mexico dead zone

NASA Goddard Space Flight Center

Sewage Sludge: About 7.2 million tons of human sewage solids from wastewater treatment plants are created every year in the U.S.20  Theoretically this would seem like an ideal fertilizer.  However, this sludge is contaminated with Persistent Biologic Toxins, including Pharmacy and Personal Care Products, perfluorocarbons (a.k.a. Teflon™ and associated chemicals), PBDE flame retardants, alkylphenol surfactants, dioxins, and furans.  These toxins make up about 0.1% of total sludge volume.21  In addition, some sludge can retain harmful bacteria and viruses that were not removed by the treatment process.  In some cases, it can also contain concerning levels of heavy metals.  About 50% of sewage sludge in the U.S. is applied to land as a fertilizer.22   

However, sewage sludge may not be used in organic production.

Saxton Freymann ©Play With Your Food LLC. Used by permission

Pesticides: In 2012, 899 million pounds of pesticides were used for agriculture in the U.S.23  There are 900 approved products, and these are just the active ingredients.  They do not include the solvents, adjuvants (toxicity enhancers), and “inert” ingredients that in some cases can be as or more harmful than the pesticide itself.  These products can be carcinogenic, neurotoxic, acutely toxic, cause developmental and reproductive harm, respiratory distress, and endocrine disruption.  Some of these pesticides are used after the plants are harvested as chemical “dessicants” to dry moisture from the plant and make plants easier to process.

Organic agriculture currently only allows about 25 pesticide ingredients, which are the least toxic that could be found, and used only when other pest eradication methods are insufficient.

Seeds: Conventional seeds are often coated with a (neonicotinoid) pesticide, which is toxic to pollinators and beneficial insects, which in turn support birds.  All of these animals serve as natural pest control on organic farms.  In 2011, about 5 million pounds of poisonous seed coatings were used.24  In 2015, between 79 and 100% of corn seed and 34 and 44% of soybean seeds had this coating.25  In the soil, this pesticide breaks down slowly, so it can theoretically be active for years.

Toxic seed coatings are prohibited.  Organic seeds are preferred.  GE seeds are prohibited. 

Pesticide Buffers and Wildlife Promotion: If a neighboring farm or tract is treated with pesticides, organic farms are usually required to maintain a buffer to protect from pesticide drift via air or water.  Though there is no set size, buffers are often 25 to 30 feet in width.26

These buffers can take the form of hedgerows, wind breaks, field borders, and stream/river buffers.  When these buffer strips are planted with the appropriate grasses, forbs (flowering herbs), shrubs, and trees, they provide habitat and food for pollinators (bees, butterflies, birds), as well as beneficial insects and natural predators that can assist in non-toxic pest management.  At the same time, they serve as a barrier to wind and water erosion, dust, weed migration, and noise.  They prevent run-off of sediment and organic material.  They mitigate temperature extremes for wildlife and livestock.  They are also sometimes used to grow saleable crops or timber, though buffer food crops cannot be labeled organic.

In contrast, buffers are not required for conventional farms.

Mikhail Melnikov/

Genetically Engineered (GE) Crops: About 60% of food and fiber acreage grown in the U.S. in 2017 was genetically engineered.27  This includes most or all domestic canola, corn, cotton, soy, and sugar beets, and small percentages of apples, papayas, potatoes, and yellow squash.

GE foods carry a host of health and environmental problems, including harm to consumers from the altered nutritional structure of the plant and increased pesticide residues on food, increased resistance of insects and weeds to the GE pesticides bred into food, and disruption of ecosystems by GE plants that have unintentionally become invasive species.  (A complete article on this subject begins on page 27.)

GE products are prohibited in organic food, both fresh and processed, including feed for organically raised livestock.

Irradiated Food: Exposing food directly to gamma radiation kills pathogens and fungi that can cause harm to consumers.  In imported produce, it can also eliminate the spread of insects and parasites that arrive from other countries.

However, the ionizing radiation destroys important nutrients (Vitamins A, B, C, E, beta-carotene, enzymes) and can also create “unique radiolytic products” (including benzene and formaldehyde) on and in food that may adversely affect the long-term health of consumers.28  And killing bacteria has problems as well as benefits, as they sometimes create foul odor that signals food spoilage, an important safety warning that may be lost with irradiated food.

Irradiation cannot kill all bacteria, nor can it stop pathogens from evolving to survive time-limited doses of irradiation.  (Treating food for longer periods of time may increase nutrient destruction and radiolytic products, while creating bad flavor.)  It can also become a technological crutch to compensate for not using better sanitary practices in the first place.

A number of generic foods are approved for irradiation in the U.S., including spices, tea, beef, pork, poultry, eggs, shellfish, crustaceans (e.g., shrimp), fruit, and vegetables (in particular, lettuce and spinach).  However, the process is generally used in niche markets and applications at this time.  Irradiated food must be labeled with a “radura” symbol like the one shown here, though spices, manufactured food, and food served in restaurants, do not require this label.

Irradiation of organic food, both fresh and processed, is prohibited.

Livestock: Almost all conventionally raised animals are raised in Concentrated Animal Feeding Operations, deprived of exercise, fresh air, sunlight, and sometimes even clean drinking water.  They are usually fed GE grain, and usually given hormones and antibiotics to boost growth.  In 2018, U.S. livestock consumed 13.3 million pounds of antibiotics to promote growth or prevent or treat diseases that, to a great degree, were avoidable with better hygiene.29

In contrast, organically raised livestock are required to be raised with access to exercise, fresh air, sunlight, and clean drinking water.  GE feed is prohibited.  Ruminants are required to graze on pasture at least a third of the year.  Only 22 drugs are approved for use in organic animal raising, and only for treating illness, not as growth boosters.  Growth hormones are prohibited.

While organic meat (cattle, hogs, poultry) in the U.S. is barely a niche market, organic dairy consumption is at least noticeable.  In 2016, less than 0.3% of meat came from animals that were organically raised, but about 2% of milk and 5% of eggs were organically produced.30

Processed Foods: Experts estimate that as many as 10,000 chemicals can be used in the manufacture of conventional processed food.  These include preservatives, colorings, emulsifiers, texturizers, leavening agents, flavorings, and transfats.

In contrast, only 40 synthetic chemicals can be used in organic food processing, and cannot be used as preservatives, colorings, or flavorings.31

Consumers who seek out organic processed food need to be conscious of the definitions.

Organic – In multi-ingredient products, at least 95% of ingredients, excluding salt and water, are certified organic.

Made with Organic – In multi-ingredient products, at least 70% of ingredients are certified organic.

Organic Ingredients – If less than 70% of a multi-ingredient product is certified as organic, the product may not be labeled as Organic or Made with Organic, but the ingredient list can designate specific ingredients that are organic.

Environmental Food Rating Information

Cornucopia Institute Organic Scorecards
(Cereals, Soyfoods, Snack Bars, Hexane-Free Foods)

Ratings of commercial products based on environmental and social standards, as well as transparency.

Environmental Working Group Food Scores

Database of over 80,000 food products rated on a scale of 1 to 10 for nutrition, additives and contaminants such as pesticides, preservatives, antibiotics, and processing.  Products include animal, plant, and baby food.

Environmental Working Group Guide to Pesticides in Produce™

Ratings of best and worst fruits and vegetables based on average measured pesticide residues.  Annual update/revisions come out every spring.  This list can be used for consumers on a tight budget to selectively buy organic food, avoiding produce with the worst residues.

At stores, look for the organic seal on the product or packaging.  When buying produce, there is usually a sign next to the price that states if the item is organic.  Also, if the item has a “9” at the start of a 5-digit PLU code decal, it designates organic.  (A 4-digit code means the produce is conventional.)

Image: Saxton Freymann ©Play With Your Food LLC. Used by permission

John Dolley

Nutritional Quality

One of the most important aspects of organic food is its nutritional quality compared to conventional food.  This has been documented through numerous scientific studies.

One of the most influential and comprehensive of these is a meta-analysis of 343 peer reviewed publications conducted by European scientists in 2014.32   It showed a pattern of increased antioxidants in organic plant-based foods (between 19 and 51% increase depending on the chemical) that were linked to reduced incidence of heart disease, neurodegenerative disease, and certain types of cancer.  The same review determined that the appearance of the toxic metal cadmium (often found in phosphate fertilizers) was 48% lower in organic food, and pesticide residues were 4 times higher in conventional food.

Another influential meta-analysis of 41 studies of plant-based foods by an American scientist showed organic crops contained significantly higher levels of Vitamin C (27%), iron (31%), magnesium (29%), and phosphorus (14%), as well as significantly less (toxic) nitrates (15%) than conventional plant-based foods.33

These two analyses partially conflict with a somewhat controversial 2012 meta-analysis by scientists at Stanford.34  However, even this paper that shed doubt on enhanced nutritional quality pointed out that children consuming organic food had lower levels of pesticide in their blood, and consumers of organic chicken and pork were less likely to be exposed to antibiotic resistant bacteria.

Regarding organic animal food products, a meta-analysis of 263 studies released in 2016 showed the following.35

• Organic meat and milk contained about 50% more beneficial omega-3 fats than conventional animal food.

• Organic meat had slightly lower levels of unhealthy saturated fat.

• Organic milk had 40% more conjugated linoleic acid (CLA) shown to reduce cancer risks, and slightly higher levels of Vitamin E, beta-carotene, and iron.

• Organic meat also had a lower Omega-6 to Omega-3 ratio.

• Organic milk had a 74% lower level of iodine, which could be good or bad, depending on the level people receive from other sources.

In the case of ruminants, some of the nutritional differences stemmed from a grass-fed diet.

The Gold Standard? Or Brass?

For all the good things one can say about the wholesomeness and environmental benefits of organic food, there are several weaknesses.

Premium Price for a Premium Product: The most apparent one is cost – organic carries a premium over conventional food.  How much this premium is depends on the type of food and the store where it is sold.  A national survey from 2015 pegged the increase at 47%, while a more recent survey using different methodology gauged it at only 7.5%.36  In general terms, the premium for produce has been less than the increased cost of animal food products.

This premium has gone down marketedly since the 1990s, due in some part to economies of scale as more organic food has been produced.  However, cost is still a deterrent, especially to people with low- and moderate-incomes.  And the premium may never completely go away.  It usually takes more labor to produce organic food, and there is an added cost for certification.

Counterfeit: A second downside is that the organic premium has enticed unscrupulous farmers, input suppliers, and food brokers into a new type of crime: counterfeit organic food.  Compounding the predictable motive of greed is that the organic market in the U.S. has expanded so much that the regulatory system that monitors the standards has lacked enough staff to do its job well.

Between the beginning of 2011 and mid-April of 2020, the U.S. Department of Agriculture logged 136 fraudulent organic certificates used to make false claims that food was inspected.37  These may have been created without knowledge of the operator or certifying agent.

Though it is a rarity and not the norm, some organic standard violators face prison time.

• In 2015, a New Jersey man was sentenced to 40 months for falsely labeling supplements as organic.38

• In late 2018, 3 Nebraska farmers pleaded guilty to selling at least $2.5 million each in counterfeit organic corn and soybeans between 2010 and 2017 through an accomplice grain dealer.39

• In 2019, a Missouri farmer was convicted for selling $2.2 million in counterfeit grain to the same brokerage.  The broker himself was convicted after admitting to at least $142.43 million in largely fraudulent grain sales.40

Counterfeit organics not only swindle consumers, but also hurt organic farmers, who cannot compete to produce real organic food against a fake product that is less expensive to grow.

Defenders of organic standards would point to these incidents as examples of how the enforcement system is working.  However, it also shows its vulnerabilities.

Imported Fraud: Not all justice is fair. Just as in conventional food, imports of organic food are more suspect of violations than domestic.

Of the 136 fraudulent organic certificates logged by the U.S. Department of Agriculture, almost 90% of these were of foreign origin.  In the U.S., if someone knowingly sells counterfeit organic, not only can they lose their reputation, they can also be fined as much as $18,000 per incident.41  In rare instances, they are even jailed.  However, such sanctions occurring in a foreign country asked to enforce American food laws are not going to be likely or frequent, particularly if the foreign country will not even enforce its own laws.

As example, in 2016-17, 3 shipments of conventional corn and soybeans exported from Turkey were “grain washed” to portray them as organic, yielding millions of extra dollars in profit above the profit they would have already made.42 When alerted, the U.S. Department of Agriculture, responsible for enforcing domestic organic standards, began an investigation.  The agency ultimately revoked the organic designation of 2 import companies, but no foreign people or companies were known to be fined or jailed.

In 2017, a U.S. Department of Agriculture Inspector General audit placed a magnifying glass over the problem.43  It proved that organic standards were not being verified, and hence enforced, because of the lack of inspection staff.  It further found that if the imported crop has evidence of diseases or pests at U.S. ports of entry, it was often treated with chemical pesticides prohibited for use in organics.

Standard Gamesmanship: Another criticism of organic food is that some organic standards themselves are not well defined, leading to uneven enforcement.  As studies have shown, organic programs have been successful in reducing pesticides in food and increasing its nutrition levels.  However, there are people who helped start the organic movement who are dissatisfied with its direction.  They feel that as organic sales have grown, larger producers have made it more difficult for family farmers (one time the backbone of the movement) to compete.  They also feel some of the environmental safeguards are being compromised.

An example of this is the organic milk production mandate that cows be grazed at least a third of the year.  Grass, as opposed to grain, is the natural diet of bovines.  Cows raised on grass are generally healthier.  When pastured, they get more exercise, more sunlight and fresh air, and are less exposed to accumulated manure that causes disease, odors, and ammonia emissions in Concentrated Animal Feeding Operations.

The dairy products produced from grass-fed animals are also healthier, higher in beneficial fatty acids, and possibly lower in high cholesterol fatty acids.  However, circumstantial evidence shows that not all dairy cows are being grazed according to standards.44  This decreases the nutritional and environmental value that organic consumers have come to expect.  It also makes it more difficult for conscientious dairy farmers that do not take economic shortcuts to compete.  It takes more land per cow to properly graze them, and grazed cows produce less milk than animals that are primarily grain fed.

Another example is egg production. A henhouse with 100,000 chickens with a tiny screened porch is not the same as pasture-raised chickens given access to fresh air and exercise by foraging on open ground.45  And again, the large operation’s resemblance to Concentrated Animal Feeding Operations makes it difficult for small farmers who pasture-raise hens to compete.

Of Foxes and Hen Houses

Federal organic standard enforcement is compromised for two main reasons.  First, there have not been enough staff to enforce standards in the growing market.

Second, federal staff do not directly inspect organic operations.  Instead, farmers are required to hire third-party inspectors, who usually announce their inspections in advance.  Testing for pesticides is not common.  While many of these third-party inspectors have a high level of integrity, some are more permissive than others.  A farmer that thinks an inspector is too strict on standards can simply shop around and find another.

Theoretically, the federal program can inspect the inspectors to make sure they are not being too lenient, but again, there has not been enough staff to accomplish much in this direction.

The federal budget that passed in late 2018 has increased the funding and tools necessary for more enforcement of organic standards, including organic imports.46  Several watchdog organizations that have been repeatedly critical of the U.S. organic inspections seem encouraged by this turn.47

Another key strategy to confront quality challenges to the U.S. organic system is to create other certification systems that go beyond what the federal inspection program ensures.  The strategy will allow non-profit organizations to press for solutions and reforms that the federal organic program will either not undertake, or is only pursuing at a slow pace.

Some of these alternative rating programs already exist.  There are at least 5 organizations that certify animal food for qualities beyond what federal organic standards call for.  These include the diet of animals (e.g., grass-fed cattle, organic feed), access to the outdoors and proper exercise, and humane treatment.  (See page 39 for more information.)

The Rodale Institute, one of the founders of modern organic agriculture, began to pilot its “Regenerative Organic Certification” in 2018, which deals not only with improving the standard for animal raising, but for organic plant food as well.   Though the Rodale program uses federal organic standards as a prerequisite, it goes much deeper. It sets intensive requirements for:

• Environment (e.g., optimal soil carbon capture, tilling only once every 3 years, no deforestation);

• Animal welfare (e.g., prohibition of Concentrated Animal Feeding Operations, prohibition of mutilation such as debeaking, use of humane slaughter practices); and

• Economic fairness to farmers, ranchers, and workers (e.g., living wages and collective bargaining for workers).

Similar to the federal program, the Rodale program requires annual inspections, and it can take several years to complete the process.

1 “New state data shows organic now in the kitchens of over 80 percent of U.S. households,” (press release), Washington, DC: Organic Trade Association, March 2017.

2 2019 Organic Industry Survey, Washington, DC: Organic Trade Association, May 2019.

3 The State and Future of U.S. Soils (draft), Washington, DC: U.S. National Science and  Technology Council, Committee on Environment, Natural Resources, and Sustainability, December 2016, p. 4.

4 Hopkinson, Jenny, “Can American soil be brought back to life?” Politico, September 13, 2017.

5 Erosion in 2015 from Summary Report: 2015 National Resources Inventory, Washington, DC: U.S. Department of Agriculture, Natural Resources Conservation Service, 2018, Chart 2-8.

Reformation rates from op. cit. The State and Future of U.S. Soils, p. 7.

6 Lang, Susan, “’Slow, Insidious’ Soil Erosion Threatens Human Health and Welfare as Well as the Environment, Cornell Study Asserts,” Cornell Chronicle, March 20, 2006.

7 Crawford, John, “What If the World’s Soil Runs Out?” Time, December 14, 2012.

8 “World Population Prospects 2019.” New York, NY: United Nations Department of Economic and Social Affairs, Population Dynamics, accessed April 8, 2020.

9 Emission reductions from Benador, Laetitia, et al.,  Roadmap to an Organic California, Santa Cruz, CA: California Certified Organic Farmers, 2019, p. 36.

Total state emissions from California Greenhouse Gas Emission Inventory: 2000 – 2017, Sacramento, CA: California Air Resources Board, 2019 Edition, p. 1.

10 Quantities of fertilizer from “Fertilizer Use and Price,” Washington, DC: United States Department of Agriculture, Economic Research Service, Table 1.

11 Fertilizer use from Ibid.

Energy use for various fertilizers Perry, Bob, “Embedded Energy: Measuring the Health and Sustainability of Landscapes,” Novato, CA: University of California-Marin, Agriculture and Natural Resources, November 18, 2011, Slide 18.

Total U.S. Energy use of 98.3 Quads from “Primary Energy Overview,” Washington, DC: U.S. Energy Information Administration, Table 1.1.

12 Inventory of U.S. Greenhouse Gas Emissions and Sinks, 1990-2017, U.S. Environmental Protection Agency, EPA 430-R-19-001, Chart ES-1.

13 “National Organic Program,” Code of Federal Regulations, Washington DC: Government Publishing Office, Title 7, Subtitle B, Chapter 1, Part 205, accessed April 8, 2020.

Roseboro, Ken, “Debunking “alternate facts” about pesticides used in organic farming,” The Organic & Non-GMO Report, February 22, 2017.

14 op. cit. Inventory of U.S. Greenhouse Gas Emissions and Sinks, 1990-2017, Chart ES-1 and Table 5-17.

15 Almaraz, Maya, et. al., “Agriculture is a major source of NOx pollution in California,” Science Advances, Vol. 4, No. 1, January 31, 2018, p. 5.

16 Temkin, Alexis and Sydney Evans, “Nitrate in U.S. Tap Water May Cause More Than 12,500 Cancers a Year,” Washington, DC: Environmental Working Group, June 11, 2019.

17 “Prenatal Nitrate Intake from Drinking Water and Selected Birth Defects in Offspring of Participants in the National Birth Defects Prevention Study,” Environmental Health Perspectives, V.121, No. 9, September 2013, pp. 1083–1089.

18 “Northern Gulf of Mexico Hypoxic Zone,” Washington, DC: U.S. Environmental Protection Agency, Mississippi River/Gulf of Mexico Hypoxia Task Force, accessed April 12, 2020.

19 “The Challenge of Tracking Nutrient Pollution 2,300 Miles.” Reston, VA: U.S. Geological Survey, March 6, 2017.

20 Venkatesan, Arjun, et al., “United States National Sewage Sludge Repository at Arizona State University – A New Resource and Research Tool for Environmental Scientists, Engineers, and Epidemiologists,” Environmental Science and Pollution Research, V. 22, No. 3, February 2015, p. 1576.

21 Ibid., p. 1584.

22 Ibid.

23 Atwood, Donald and Claire Paisley-Jones, Pesticides Industry Sales and Usage, 2008-2012 Market Estimates, Washington, DC: U.S. Environmental Protection Agency, Biological and Economic Analysis Division Office of Pesticide Programs, Office of Chemical Safety and Pollution Prevention, 2017, p. 12, Table 3.2.

24 Gurian-Sherman, Doug, “Hidden Costs of Toxic Seed Coatings,” Washington, DC: Center for Food Safety, June 2015.

25 Douglas, Margaret and John Tooker, “Large-Scale Deployment of Seed Treatments Has Driven Rapid Increase in Use of Neonicotinoid Insecticides and Preemptive Pest Management in U.S. Field Crops,” Environmental Science & Technology, V. 49, Issue 8, March 2015, pp. 5088-5097.

26 Dufour, Rex, et al., Conservation Buffers in Organic Systems, California Implementation Guide, National Center for Appropriate Technology, Butte, MT: March 2014, p. 3.

27 “2017 acreage data as of December 1, 2017,” Crop Acreage Data, Washington, DC: U.S. Department of Agriculture, Farm Service Agency, accessed December 17, 2017.


Non-food/fiber crops such as grass, tobacco, conservation reserve, and Christmas trees removed.

GE alfalfa acres from “Pocket K No. 16: Biotech Crop Highlights in 2018.” Ithaca, NY: International Service for the Acquisition of Agri-Biotech Applications, December 2018.

Percentages of GMO corn, cotton, and soy from “Genetically engineered varieties of corn, upland cotton, and soybeans, by State and for the United States, 2000-19,“Adoption of Genetically Engineered Crops in the U.S., Washington, DC: U.S. Department of Agriculture, Economic Research Service, updated September 18, 2019.  Online at

Sugar beet and canola percentages from Global Status of Commercialized Biotech/GM Crops in 2017, Brief 53, Ithaca, NY: International Service for the Acquisition of Agri-Biotech Applications, 2017, p. 12.

28 “What’s Wrong With Food Irradiation,” Finland, MN: Organic Consumers Association, February 2002.

29 2018 Summary Report On Antimicrobials Sold or Distributed for Use in Food-Producing Animals, Rockville, MD: U.S. Food and Drug Adminstration, Center for Veterinary Medicine, December 2019.

30 Organic animal food production for 2016 from Certified Organic Survey, 2016 Summary, Washington, DC: U.S. Department of Agriculture, National Agricultural Statistics Service, September 2017, Tables 17 & 18.

This compares total production to Note 2, Animal Food chapter, and 2017 Agricultural Statistics Annual, Washington, DC: U.S. Department of Agriculture, National Agricultural Statistics Service, 2018, Table 8.4 (dairy production for 2016).

31 op. cit. “National Organic Program,” Section 205.605 (b).

32 Baranski, Marcin, et al., “Higher antioxidant and lower cadmium concentrations and lower incidence of pesticide residues in organically grown crops: a systematic literature review and meta-analyses,” British Journal of Nutrition, V. 112, September 14, 2014, pp. 794–811.

33 Worthington, Virginia, “Nutritional Quality of Organic Versus Conventional Fruits, Vegetables, and Grains,” The Journal of Alternative and Complementary Medicine,” V. 7, No. 2, April 2001, pp. 161–173.

34 Mestel, Rosie , “Lots of chatter, anger over Stanford organic food study,” Los Angeles Times, September 12, 2012.

35 Houldcroft, Louella, “New Study finds clear differences between organic and non-organic milk and meat,” Science News, February 15, 2016.

36 “The cost of organic food,” Consumer Reports, March 19, 2015.

“Good news if you buy organic food — it’s getting cheaper,” Associated Press, Jan 24, 2019.

37 “Fraudulent Organic Certificates,” Washington, DC: U.S. Department of Agriculture, Agricultural Marketing Service, accessed April 15, 2020.

38 “Owner Of Dietary Supplement Company Sentenced To 40 Months In Prison For Multimillion-Dollar Scheme To Adulterate Dietary Supplements,” (press release), United States Department of Justice, District of New Jersey, September 9, 2015.

39 Foley, Ryan, “3 farmers to plead guilty in organic grain fraud scheme,” Associated Press, October. 11, 2018.

40 Mehaffey, Trish , “Another Missouri man charged in fake organic grain scheme,” Cedar Raids Gazette, May 1, 2019.

41 op. cit. “Fraudulent Organic Certificates.”

42 Whoriskey , Peter,  “The labels said ‘organic.’ But these massive imports of corn and soybeans weren’t,” Washington Post, May 12, 2017.

43 Whoriskey , Peter,  “Bogus ‘organic’ foods reach the U.S. because of lax enforcement at ports, inspectors say,” Washington Post, September 18, 2017.

44 Whoriskey, Peter, “Why your ‘organic’ milk may not be organic,” Washington Post, May 1, 2017.   

45 Whoriskey, Peter, “Why the hell am I paying more for this?” Major egg operation houses “USDA Organic” hens at three per square foot,” Washington Post, July 13, 2017.

46 Whoriskey, Peter, “USDA officials said they were guarding against organic food fraud. Congress decided they need help,” Washington Post, December 20, 2018.

47 Whoriskey, Peter , “Organic food fraud leads Congress to weigh bill doubling USDA oversight,” Washington Post, December 21, 2017.

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