Tag: pesticides

Residue Testing for a Global Supply Chain

The article below appears in the Fall 2025, “OMRI Materials Review” newsletter sent out by OMRI to subscribers. I thought this article was interesting since it concerns pesticide residues – a hot topic in Texas Organic Agriculture! It is reprinted with permission by OMRI.

By Doug Currier

The work to modernize residue testing in USDA organic production could impact input material review.

Residue Testing for a Global Supply Chain (RTGSC) is an ongoing discussion being led by National Organic Standards Board (NOSB) with input from public stakeholders and the National Organic Program (NOP). It is well established that organic production is based on organic system plans that, if followed, ensure adherence to the organic standards. Testing to detect residues of both prohibited substances and excluded methods is seen as an important measure of the success of those system plans, or whether those plans were followed at all. This type of testing is required within the USDA organic standard1, but for the testing to remain “relevant” and “impactful,” changes to the USDA standard and guidance documents are being considered. This is the aim of RTGSC.

Before we consider some of these changes, it is helpful to become clear on the sources of these residues and the possible reasons they may appear in organic systems. The 2013 “Pesticide Rule”2 3 established the current residue testing requirements to ensure that organic system plans prevent commingling and contamination with prohibited substances. Testing has long focused on detecting genetically modified crops to address the commingling issue.

Because of how the “Pesticide Rule” is written, there is a focus on detecting prohibited pesticides as a way to address the contamination issue. Both GMO and pesticide residues can come from neighboring non‑organic farms through “drift” or can occur when cleanout procedures used between processing non‑organic and organic commodities are ineffective. These two examples can be referred to as “organic control points” in a production system where the risk of contamination is high. There are many facets to the strategies used to detect contamination in organic production systems—far too many to examine in this article.

The NOSB Spring 2025 meeting materials call for an in-depth description of these issues. Before we move on to the changes being discussed to modernize the current approach to testing and detection, it can be helpful to acknowledge that the “Pesticide Rule” was not necessarily written with fraud detection in mind. Also, input materials themselves can be a source of contaminant residue that are actionable from the perspective of accredited certification bodies (“certifiers”).

Positive results from residue testing impact organic growers in several ways, with perhaps the most significant being the inability to sell produce as organic. In our work, we have seen growers lose their ability to sell produce as organic because of positive test results that were traced back not to their farm, but to the input materials, just like with other sources of residues—whether due to unintentional contamination or intentional adulteration. It is therefore promising to see that within the RTGSC conversation is a proposal to redefine the definition of Unavoidable Residual Environmental Contamination (UREC) to one that acknowledges that sometimes no matter how strong the system plan, contamination can occur. This is not to say that the contamination can go unaddressed. But relieving the grower of some responsibility seems to be a step in the right direction. How that contamination is ultimately addressed, and how often, is a separate matter.

A significant focus of RTGSC is to modernize the strategies for testing for contamination in a way that more meaningfully centers on pesticides and GMOs. A “Target List” or consumer‑focused list does good work to identify materials and input materials where extraordinary high levels of heavy metals and harmful organic contaminants may exist.

With that said, the advancements in test methodologies, test sensitivities, and the realization that detection strategies—especially those used to detect fraud—are more sensitive now than ever, suggest that the RTGSC ideas coming from the NOSB for the NOP to consider could change the nature of input material review work: (1) development and adoption of accredited methods for Organic Authenticity Testing as it relates to detecting whether inorganic nitrogen is manufactured from allowed or prohibited sources, and (2) broadening the list of substances for which there is regular testing.

Regarding the former, we are supportive of this long‑needed move towards methods and accreditation. As for the latter, we are mindful that widening the net, through expansion of the substances list and more sensitive testing, could mean for us and the manufacturers with which we work.

There is still much to consider and absorb before changes that move our industry beyond the 2013 “Pesticide Rule.” Achieving RTGSC’s goal of keeping testing relevant and impactful will affect nearly everyone. OMRI will continue to monitor these developments closely and share updates as the RTGSC process moves forward.

  1. https://www.ecfr.gov/current/title-7/subtitle-B/chapter-I/subchapter-M/part-205?utm_source=chatgpt.com ↩︎
  2. https://www.ams.usda.gov/sites/default/files/media/NOP-Notice-ResidueTesting.pdf?utm_source=chatgpt.com ↩︎
  3. https://www.federalregister.gov/documents/2012/11/09/2012-27378/national-organic-program-periodic-residue-testing?utm_source=chatgpt.com ↩︎

Poll Says: Dicamba Drift Continues to Impact Organic Crops in West Texas

Soybeans damaged by dicamba drift. Genetic Literacy Project

Overview of Dicamba Drift Issue in 2024

Dicamba, a commonly used herbicide in conventional farming, has long been a point of contention, particularly in regions where organic crops are grown alongside conventional fields. In 2024, the persistence of dicamba drift has become increasingly problematic for organic farmers in West Texas, affecting a range of sensitive crops, particularly cotton and peanuts.

To understand the scale of this issue, I recently conducted a poll targeting 204 organic farmers from Seminole to areas just north of Lubbock. The poll, sent out by email, specifically asked if they had observed dicamba drift on their sensitive crops this year. With a response rate of 27.5% (56 responses), the results are indicative of a widespread concern.

Poll Results: Dicamba Drift on Sensitive Crops

In this poll, farmers were asked a straightforward question: “Have you seen dicamba drift on sensitive crops in 2024?” The results revealed the following breakdown:

  • 50% reported observing dicamba drift on their crops.
  • 44% stated they had not observed drift.
  • 5% mentioned “maybe” they had observed some drift damage.

The responses reflect a troubling level of dicamba exposure, with half of the respondents directly witnessing the impact of drift. While dicamba is designed to target specific weeds, the herbicide’s tendency to volatilize and drift into neighboring fields has made it difficult for organic farmers to avoid its effects, especially in the South Plains.

Impact on Crop Yields

Several farmers shared the tangible impacts dicamba drift has had on their yields. One farmer, who has been practicing organic farming for over three decades, described this year as the “worst dicamba drift in years.” He noted that his soybean yield was cut in half, with probable yield reductions in cotton as well. This problem was bad enough that his comments to me questioned whether it was worth it to keep farming!

The Broader Implications for Organic Farming

The prevalence of dicamba drift has significant ramifications for organic producers in Texas. Yield reductions not only threaten the economic viability of these farmers but also jeopardize their certification status, as organic crops must remain free of prohibited substances. Dicamba drift challenges their ability to meet these requirements, complicating the already demanding task of managing organic systems in a predominantly conventional farming region.

This is just for Awareness

The findings from this poll underscore the need for better management practices to prevent dicamba drift. Organic farmers have invested years into building sustainable systems that meet organic standards, yet their efforts can be undermined by the unintended consequences of a herbicide application on a nearby conventional farm.

Moving forward, it is essential to foster a dialogue between organic and conventional farmers, to find solutions that protect organic crops from unintended herbicide exposure. Additionally, increased awareness and education about the volatility of dicamba and its potential effects on neighboring fields could be critical steps in mitigating drift.

With dicamba products currently off the market, there is growing concern about whether they will be approved for use again in future years. The uncertainty surrounding future approvals adds an additional layer of stress for organic farmers, who are already grappling with the fallout of dicamba drift. Better and more effective safeguards are crucial if dicamba is to return, to ensure that organic farming can continue to thrive without fear of “chemical trespass” on neighboring farms.

What’s Next – FieldWatch offers help

In response to these ongoing challenges posed by any pesticide drift or accidental pesticide application, the Texas Department of Agriculture (TDA) is collaborating with FieldWatch to implement a mapping registry in 2025. This program aims to enhance communication between specialty crop producers, beekeepers, and pesticide applicators, thereby mitigating the risks associated with pesticide drift.

FieldWatch is a non-profit organization that offers free, voluntary mapping tools designed to promote awareness of sensitive sites. By registering their fields, vineyards, orchards and apiaries, producers and beekeepers can inform applicators of locations that require caution during pesticide application. This proactive approach fosters cooperation and helps protect vulnerable crops from unintended exposure.

Texas A&M AgriLife Extension Service will oversee the data management for FieldWatch in Texas, with your Extension Organic Specialist (myself!), serving as the data manager. This collaboration ensures that the registry is maintained with accurate and up-to-date information, facilitating effective communication among all stakeholders.

The introduction of FieldWatch in Texas is a significant step toward protecting organic and specialty crops from pesticide drift. By participating in this registry, farmers can contribute to better use and application of pesticides, ultimately supporting the sustainability of all agriculture in the region.