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USDA’s 2024 Proposed Rule To Amend Crop Practice Standards & Organic Mushroom Production

"Mushrooms are a gateway to understanding the complexity and interconnectedness of nature."  - Paul Stamets

Organic Mushroom Farming

Friday, May 10, 2024, marked the close of the comment period for United States mushroom growers seeking to convert or modify their organic certification processes. Specifically sourcing organic spawn and substrate, mushroom composting requirements, and framing up “crop” and “wild crop” standards in production and management. This Spring, mushroom growers prepared their commentary for Docket Number: AMS-NOP-22-0063, the United States Department of Agriculture - Agricultural Marketing Service (USDA-AMS) to consider as they focus on amending USDA organic regulations for mushroom production and food handling standards. The Organic Farmers Association is a good resource for distilling regulation when it comes to navigating USDA rule changes. 

Foraging and Farming Collage  Mushrooms

USDA’s Comments For Consideration 

The USDA prepared six specific questions for mushroom growers to consider. Farmers helped determine whether the new language created a conflict regarding the production of spawn, handling of substrate, and record-keeping. Mushroom farmers were also faced with weighing in on a change in policy that has been deliberated since the Spring of 1995, a span of 19 years in the making. 

The questions for comment also included requests to share any concerns about the

proposed requirements for compost used in organic mushroom operations.  The USDA focused on requesting thoughts about health and sanitary issues with substrate and spawn preparation that might hinder current methods or cause workflow issues. Considering the proposed changes, the USDA sought commentary for growers to articulate all barriers to production using organically certified spawn for growing organically certified products. The question tasked growers with evaluating how the rule would affect the barriers. 

The USDA also mentioned a surprising statistic that growers are using organic products, and most are selling them as conventional products in the marketplace.  Asking, “Why are certified organic mushroom operations producing significantly more

organic mushrooms than they are selling as certified organic? What could be

included in this rule to help ensure that mushrooms that are produced organically can be sold as organic?” 

Enoki Mushrooms

Organic Mushroom Production & Crop Practice Standards 

As of 2023, less than 15% of mushroom growers are certified organic, while there are just over 500 small-scale growers in the United States that might economically benefit from registering as certified organic. The USDA’s crop standards and wild crop language are being rewritten to include mushroom production processes and materials requirements.  

The comment period offered farmers the opportunity to organize their thoughts around the impact and positive economic opportunities for organic certification price points. This begs the question: What will materials handling and production look like over the next 2 years? USDA’s section 205.210(b) speaks to mushroom production processes from “tip to tale,” managing spawn creation, fruiting, growing out, harvest, and disposal of substrate. All practices will require record-keeping analytics and management practices that need to be evaluated by producers to ensure the new language works. 

Producers commented on the disposal of spent spawn media, best practices for substrate, and the management of substrate. The USDA made proposals around media and substrate, which allowed composted and uncomposted plant and animal materials, non-agricultural natural

substances, and synthetic substances. The language addresses temperature management for mushroom compost production. This rule proposes that feed stock would be required to reach 131°F for a minimum of 3 days during aerobic decomposition. 

The USDA also proposes 205.210(d) proposed 100% certified organic spawn under continuous organic management.  This article covers some of the areas proposed in the Federal Register. For additional questions, contact Erin Healy, Director, Standards Division, National Organic Program, or call 202-720-3252.

Organic Mushroom Production Road To Certification 

Partnering with an Organic Certification Agent early is crucial to a producer's filing success. The three pillars of a farmer's organics toolkit are Cultural, Biological, and Mechanical. The organic certification process takes years to convert, and farmers must prove they can deal with being proactive over a designated period of time, with the oversight of an organic production specialist. Suppose you are a farmer ready to launch a program. In that case, organizations have shared that certifying organic at “Start-Up” can be more feasible than a conversion from conventional to organic status.  

Road-map to Organic Certification

1990 The National Organic Program (NOP) was founded to develop organic regulations. By 2002, they went into effect for the governance of organic crop production, livestock production, handling, processing, and labeling. 

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