Letters to the FDA: Manure and Compost Are Essential Elements of a Safe, Resilient Food System

Alpacas on a ranch in Bellvue, CO

Alpacas on a ranch in Bellvue, CO

The mission of the sustainable agriculture movement is to create a diverse, localized, resilient food system that supports and sustains the natural environment. To accomplish this, agriculture needs to reduce its reliance on fossil fuels. Many farmers are choosing to replace petroleum-based, energy intensive synthetic fertilizers with organic fertilizers like compost and manure. The proposed Food Safety Modernization Act (FSMA) regulations will discourage producers from using these valuable, renewable fertilizers.

Plants require 17 essential nutrients for proper growth and functioning. Nitrogen, phosphorus, and potassium are the most important and widely applied of these nutrients. Nitrogen fertilizer production requires an enormous amount of energy, primarily obtained from the burning of fossil fuels. Both phosphorus and potassium are mined; phosphorus from phosphate rock and potassium from ancient seabeds. The extraction and production of these two nutrients require immense amounts of energy and create significant environmental pollution. While the world’s potassium supply in relatively unlimited, the phosphorus supply is likely to peak before 2040, creating phosphorus-induced food shortages (Massachusetts Institute of Technology, 2012). Excess nutrients leached from fields cause major environmental and health problems including blue baby syndrome and algal blooms. Choosing manures and composts over these mined and manufactured fertilizers reduces fossil fuel consumption and environmental pollution and slows consumption of the world’s limited supply of natural resources.

Along with conserving resources and reducing pollution, farmers who use organic fertilizers recognize significant soil improvements. Manure helps build structure, increase organic matter, improve water infiltration, and support microbial communities. Organic farmers rely heavily on manures and composts and could not exist without them.

The use of manure also turns a waste product from animal industry into a valuable fertilizer. Manure is an expensive and difficult waste product for livestock producers to dispose of. Farmers who purchase and incoporate manure into their systems are helping properly dispose of an inconvenient waste product, while recycling precious nutrients. To avoid the environmental and economic costs of manure transport, many farmers integrate their crop and livestock systems by rotating animals through their harvested crop fields. Pigs and chickens are commonly used to till and incorporate crop residue and their nutrient rich manure. Some viticulturalists use sheep to weed their grape vines. More and more farmers are experimenting with crop-livestock integration as a way to reduce off-farm inputs and diversify risk and income. The FSMA regulations will prevent farmers from utilizing manure and implementing more sustainable and resilient crop-livestock systems.

Students learning to compost at Colorado State University

Students learning to compost at Colorado State University

Despite the many benefits of manure, the FMSA proposes regulations that will discourage producers from utilizing these fertilizers. The FSMA require a nine-month period between manure application and harvest. In order to continue using manure, farmers in temperate climates would have to add a fallow year into their rotations, taking valuable land out of production and decreasing revenue. After nine months of sitting in the field, most of the valuable nitrogen in the manure would have volatilized into the atmosphere, adding even more economic stress to the farm. The Organic Standards Board (OSB) currently requires organic farmers to wait three months before harvesting a crop from a manure-fertilized field. The OSB requirements are well researched, scientifically based and supported by agricultural producers, unlike the FSMA rules. The FDA should support these existing rules and require a three-month manure application period.

In addition to its extreme manure regulations, the FSMA will also require farmers to wait four months after applying compost before they can harvest. The OSB does not require any application-harvest window because proper composting should kill any unwanted organisms. As with the manure regulations, the FDA should remain in line with the existing organic regulations and not require a post application latent period.

The environmental, economic, and societal risks of discouraging the use of manure and compost are much greater than the food safety risks. The real threat to food safety is industrial, fossil fuel dependent food production, not soil and organic fertilizers. In order to create a safe, resilient food system, farmers must be able to utilize these valuable, recycled products without costly and unfounded regulations.

Please refer to the links below for more information on the FSMA. Thanks for reading!

Helpful FSMA Links







To submit your comments to the FDA, visit this website: http://www.regulations.gov/#!docketDetail;D=FDA-2011-N-0921 for electronic and mail-in submission options.


Massachusetts Institute of Technology. (2012). Phosphorus: Supply and Demand. Retrieved October 30, 2013, from Mission 2016: The Future of Strategic Natural Resources: http://web.mit.edu/12.000/www/m2016/finalwebsite/problems/phosphorus.htm


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