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April 25, 2014 

MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD 

FROM: Miles V. McEvoy 

 Deputy Administrator 

 Agricultural Marketing Service 

 National Organic Program (NOP) 

SUBJECT: Assessing Soil Conservation Practices 

The USDA organic regulations at 7 CFR § 205.200 require that production practices on organic 

operations must maintain or improve the natural resources of the operation, including soil and 

water quality. Additionally, these regulations contain the following soil quality provisions for 

cropping and grazing systems: 

 Organic producers must select and implement tillage and cultivation practices that 

maintain or improve the physical, chemical, and biological condition of soil and 

minimize soil erosion (§ 205.203(a)). 

 Organic producers must manage plant and animal materials to maintain or improve soil 

organic matter content, without contamination of crops, soil or water with plant nutrients, 

or pathogens (§ 205.203(c)). 

 Organic producers must use crop rotations, including cover crops to provide erosion 

control, as warranted by site-specific conditions (§ 205.205(d)). 

 Organic ruminant livestock operations must describe their soil fertility and seeding 

systems; and erosion control and protection of natural wetlands and riparian in their 

pasture plans (§ 205.240(c)). 

The National Organic Program (NOP) is aware of concerns regarding use of appropriate soil 

conservation practices on organic farms, for instance prevention of soil erosion, fencing of 

livestock from streams, application of manure on frozen soil, and overgrazing of pasture. The 

NOP is evaluating the compliance aspects of the regulation’s soil conservation provisions. The 

NOP believes that information about how certifying agents, in aggregate, are assessing soil 

management practices may reveal areas that could benefit from targeted training and tools. 

Therefore, the NOP requests that the National Organic Standards Board (NOSB) Certification, 

Accreditation, and Compliance Subcommittee (CACS) develop a discussion document to solicit 

public feedback on specific questions about evaluating soil conservation management on organic 

operations. 

Some questions that CACS could consider in development of a discussion document include: 

 How do certifiers assess whether production practices, identified in an organic system 

plan and/or observed on-site, maintain or improve soil quality? Is visual assessment 
United States Agricultural 1400 Independence Avenue, S.W.

Agricultural Department of Marketing Room 2646‐S, Mail Stop 0268

Marketing Agriculture Service Washington, D.C. 20250‐0268

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sufficient? 

 What tools, other than visual inspection, could aid certifiers in evaluating soil 

management practices, e.g., Revised Universal Soil Loss Equation 2 (RUSLE2) or soil 

organic matter levels? 

 What benchmarks do certifiers have for issuing noncompliances related to soil 

conservation: for instance, visible erosion, overgrazing, evidence of manure application 

on frozen ground, manure or compost stored in flooded areas? Are quantitative 

benchmarks used? 

 What qualifications do certifiers seek among inspectors for evaluating soil management 

practices on-site? 

 What tools do inspectors use (other than soil testing) to evaluate/measure the adequacy of 

soil management during on-site inspections? Is one on-site inspection enough to assess 

erosion if it is done during a single visit? 

 How do certifiers respond if a review/on-site inspection indicates that there is a soil 

management problem? Do certifiers issue notices of noncompliance or note as a finding 

to be reassessed at a later time? 

 How do certifiers respond when complaints are filed about a producer’s soil 

management? 

 Some USDA benefits require producers to be in compliance with Highly Erodible Land 

(HEL) provisions. Are certifiers aware of USDA Natural Resource and Conservation 

Service (NRCS) classification and HEL provisions? Should certifiers verify whether 

production acreage is classified as “highly erodible land” (HEL) and ensure appropriate 

soil management practices for HEL?1 

 Are certifiers aware of USDA NRCS’s tolerable soil loss standards? Should certifiers 

verify whether production acreage has been assessed to meet tolerable and sustainable 

soil loss levels? 

 When NRCS personnel who provide technical assistance on organic operations observe 

soil management risks and problems should the producer be required to communicate this 

information to their certifier 

The NOP has provided some references below that may be useful for the CACS to consider as 

they work on a discussion document. We appreciate the assistance of the CACS in working to 

address this issue. 

                                                            

1

 The USDA Natural Resources Conservation Service defines highly erodible land (HEL) as having soil with an 

erodibility index of 8 or higher. Producers who participate in NRCS or Farm Service Agency programs and have 

highly erodible land need to maintain conservation practices to substantially reduce soil loss. 

http://www.fsa.usda.gov/FSA/newsReleases?area=newsroom&subject=landing&topic=pfs&newstype=prfactsheet&

type=detail&item=pf_20120412_consv_en_helcwc12.html

 
United States Agricultural 1400 Independence Avenue, S.W.

Agricultural Department of Marketing Room 2646‐S, Mail Stop 0268

Marketing Agriculture Service Washington, D.C. 20250‐0268

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References 

Guide for Organic Crop Producers, November 2012, ATTRA/NOP, 

http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5101542

 

Organic System Plan Template for Crop and/or Livestock Production, March 2011, National 

Center for Appropriate Technology, 

https://attra.ncat.org/attra-pub/summaries/summary.php?pub=359

Soil Health Assessment, Natural Resources Conservation Service, 

http://www.nrcs.usda.gov/wps/portal/nrcs/main/soils/health/assessment/

 

RUSLE2 in Organic Systems (webinar), February 2012, the USDA NRCS East and West 

National Technology Support Centers, http://www.forestrywebinars.net/webinars/rusle2-inorganic-systems/