Agricultural Ethics and USDA Organic Standards


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By Courtney Quinn and Charles Francis

For millennia people have considered ethical implications of food consumption decisions. Many cultures and religions, including Judaism, Hinduism and Islam, have texts that give dietary guidelines for morally permissible food options. Consideration of ethical food production has also become important. Many 20th-century writings focused on the ethics of food production. In “Silent Spring,” for example, Rachel Carson chastised those who promoted widespread use of chemicals for pest and weed control, documenting their harm to the environment.

As early as the 1940s philosophers were discussing marketing, and more specifically, labeling of food. Early organic advocate Sir Albert Howard noted in 1943, “except in a few cases, food is not marketed according to the way it is grown. The buyer knows nothing of how it was manured.”1

Given ever-expanding food options and a wide range of production methods, governments increasingly have become involved in food labeling. As a result of reporting requirements and development and support of various labeling and certification programs, consumers now rely on numerous labels to aid in food purchases. Of these labeling programs, certified organic is the best known and only federally governed eco-label.

In an article in the June 2011 Prairie Fire, we examined the origins and trajectory of organic farming and food philosophy. We noted that consumers have many ethical considerations when making a food purchase, including but not limited to local farmers’ incomes, local and global environmental impacts and fair wages for farm workers. In this article we take a closer look at the USDA National Organic Program standards to uncover which ethical issues are addressed and which are not in the federal law.

The USDA Organic Label

The United States government began the process of developing and implementing a certification and labeling standard for organic products in 1990. By 2002 final rules allowed qualifying products to use the official USDA “organic” label. These final rules are detailed in the USDA National Organic Program (NOP) and overseen by The National Organic Standards Board (NOSB), which defines organic production as

“an ecological production management system that promotes and enhances biodiversity, biological cycles and soil biological activity. It is based on minimal use of off-farm inputs and on management practices that restore, maintain and enhance ecological harmony.”

Ethical Issues in the USDA Organic Standards

To identify the ethical issues in the NOP standards, we examined the USDA’s final rule along with a “request for comments” document (7 CFR Part 205). The latter document included both the final NOP standards ruling as well as the panel’s considerations of extensive public comments received regarding the board’s initial release of standards. We examined the document for key words and ideas that embody the various ethical concerns of the different organic philosophies. Keywords used included biodiversity, conservation, soil, health, treatment, welfare, conditions, stress, labor, processed, marketing and factory farm, among others.

Environmental: The central ethical consideration of early organic philosophers was healthy soil. This key idea remains in the NOP standards. However, today’s concerns for the environment extend beyond soil. Water, air quality and biodiversity are key ethical issues for consumers. However, consideration of any details related to environmental issues such as water quality or biodiversity are limited in the NOP standards. The use of genetically modified organisms is under constant debate, and currently GMOs are banned from use in organic production. Other than through an implicit support of large-scale organic production, the NOP standards do not directly speak to our dependence on nonrenewable fossil fuels for production, processing, packaging and distribution.

Personal Health: The connection between environmental health and human health was a key tenet of early organic advocates. The IFOAM principle of “health” states, “the health of individuals and communities cannot be separated from the health of ecosystems—healthy soils produce healthy crops that foster the health of animals and people.” Many organizations focus concern on the detrimental effects pesticides have on human health, particularly on children. A report by the Environmental Working Group in 1999 concludes “multiple pesticides known or suspected to cause brain and nervous system damage, cancer, disruption of the endocrine and immune systems, and a host of other toxic effects are ubiquitous in foods children commonly consume at levels that present serious health risks.”2 As reported by Rachel Carson and later confirmed by scientists at University of Wisconsin, we are only beginning to understand the enhanced and potentially dangerous biological activity fostered by a mix of restricted chemicals—including nitrate and pesticide residues—that individually are below the allowed federal levels in drinking water.

Some scholars conclude there is no decisive evidence that organic foods are healthier, or have higher levels of nutrients, than conventional foods.3 Others have found that organic crops contain significantly more vitamin C, iron, magnesium and phosphorus and significantly less nitrate than conventional crops.4 Although the ethical concern of personal health is a primary reason for many who purchase organic food, the NOP standards say explicitly that the USDA organic label does not carry any health claim.

Labor: The NOP standards board consciously rejected including issues of fair labor into the organic standards. Other eco-labels address issues of fair trade and fair labor, but these are not regulated by law. The Fair Trade Certified label helps to ensure that farmers are paid a fair wage for their product. However, this label is most often used on imported products and does not guarantee fair labor practices for migrant workers or other involved in domestic organic production, nor is it legally certified.

Production Scale: One stated purpose of the NOP standards is to allow growth in domestic and international organic markets. By placing economic considerations as a central tenet, the standards reflect the values of large-scale organic producers. Additionally, the NOP standards address farming operations that have both organic and nonorganic production. Rules that allow split-production farms support the concern of many people that large-scale organic agriculture is merely a more environmentally benign option and is not a radical departure from industrial agriculture. These rules are a disappointment to those committed to traditional organic philosophies. During the public comment period, some people advocated that the NOP standards ban factory farms that produce organic-labeled food, yet the board rejected this recommendation.

Animal Welfare: One of the most extensively covered ethical concerns in the NOP standards is animal welfare. Numerous provisions specify living conditions and medical care of animals. However, some of the NOP specifications are sufficiently vague and allow for practices that some may deem ethically intolerable, such as the physical alteration of animals. The original NOP standards did not specify the frequency or duration of pasture grazing, nor did they include any space requirements for animals. This led to a loose interpretation of the term “appropriate for the species” and to “accommodate for” the natural behaviors of animals. To counter claims of inappropriate practices, the NOP instituted a new rule in 2010 that prohibits any continuous total confinement of animals.

So … What Does Organic Really Mean?

Since being implemented in 2002, the NOP standards have brought some positive advances in organic agriculture. Acres under organic production continue to rise and consumers are buying more organic products. However, there are concerns that organic standards neglect traditional organic philosophy by allowing large farms to focus primarily on the economic benefits of an international organic food system. The current system may favor large-scale producers who use environmentally benign practices required by law but do not farm in the spirit of the larger organic movement and principles. For some supporters of organic agriculture, it is not sufficient to label a food product “organic” merely based on its ingredients. Michael Pollan noted “many of the philosophical values embedded in the word ‘organic’ did not survive the federal rule-making process.”5

The bottom line is that consumers are guaranteed that an apple with a USDA Organic Label was produced without use of chemicals and pesticides, and that the farmer had to create and follow a plan to keep soil healthy and protect nearby water. The apple may (or may not) be from a farm nearby, it may (or may not) have been picked by someone earning a fair wage, it may (or may not) have more or better nutrients than a conventional apple and it may (or may not) have come from a large-scale agribusiness.

Alternatives to Organic Federal Labeling

To counter the perceived ethical shortcomings of the NOP standards and the co-opting of the term organic, many farmers and concerned citizens are turning to other avenues for an alternative food system. A return to local food systems is becoming more popular. Eliot Coleman, a long-time organic farmer and activist, is advocating the term “authentic food” as an alternative to organic. The Authentic Food philosophy includes local production and processing, animal welfare, small-scale farms that are always available for customers to visit and the environmentally friendly practices that are currently used in organic agriculture. However, without the backing of a federal rule such as the NOP standards, consumers today have to rely on their personal relationship with a farmer and visits to a farm to guarantee that any particular practices and products are used in production, that animal welfare is a concern for the farmer and that labor is treated fairly.


While no panacea for a sustainable food system, the USDA Organic Standards signal an increase in producer and consumer concern for the effects of agriculture on the environment. Although food labels can aid in consumer decisions, each individual must take responsibility for understanding the ethical issues most important to them and make appropriate purchasing choices. It is essentially up to the consumer to become informed, to know the sources of their food and how it is produced and to understand what ethical elements are addressed in a food label. It is also their responsibility to determine what questions should be directed to the vendors in the local farmers market. By taking these steps toward better education and awareness, consumers can empower themselves to make ethical food decisions.



1. Howard, Albert. “An Agricultural Testament.” New York: Oxford University Press (1943).

2. Hettenbach, Todd, Kenneth A. Cook, Richard Wiles and Christopher Campbell. “How ’bout Them Apples? Pesticides in Children’s Food Ten Years after ALAR.” Environmental Working Group. (1999).

3 Williams, Christine M. “Nutritional Quality of Organic Food: Shades of Grey or Shades of Green?” “Proceedings of the Nutrition Society,” 61 (2002): 19–24.

4. Worthington, Virginia. “Nutritional Quality of Organic versus Conventional Fruits, Vegetables, and Grains.” “The Journal of Alternative and Complementary Medicine,” 7(2) (2001): 161–173.

5. Pollan, Michael. “Behind the Organic-Industrial Complex.” New York Times (2001).

More information on the National Organic Program can be found at or on Wikipedia at


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