Part C.
Are there fewer pesticide residues on organic foods than on conventionally grown foods? Are there fewer antibiotic and hormone residues in organic meat, eggs and dairy products than in conventional animal products? Is organic food safer to eat?

AFSIC Research Guide
Compiled by:
Mary V. Gold
Alternative Farming Systems Information Center

October 2008

Answer: For the most part, yes.

Issues and References

1. U.S. organic standards do not directly address food safety. However, the regulations mandate that organic food producers and processors meet requirements that have food safety implications. Organic food must also meet the same State and Federal food safety requirements as non-organic foods. [Find out more]
   
   
2. Pesticide residues – traces of chemicals that were applied to food crops in the field, during processing and/or while in storage – are measurably different on organic foods and non-organic foods. Analysis of USDA and other data documenting pesticide residues on fresh vegetables and fruits shows that organic produce carries significantly fewer pesticide residues than conventional produce. Measured residues on most products, both organic and non-organic, do not exceed government-defined thresholds for safe consumption. [Find out more]
   
   
3. Food safety issues related to animal products – meats, eggs and dairy products – are diverse. Direct comparison studies of organic vs. non-organic foods are few, and the current data available are specific to commodity, specific to production practice and/or specific to food safety risk. Organic meat products have been shown to reduce risk for potential exposure to prion-related diseases including mad cow disease and to arsenic residues in chicken meat; and organic livestock practices do not contribute to the growing phenomenon of drug resistant pathogens. In other respects, however, current data show few significant differences with regard to food safety. [Find out more]
   
   
4. Organic regulations ban or severely restrict the use food additives, processing aids (substances used during processing but not added directly to food) and fortifying agents commonly used in non-organic foods including preservatives, artificial sweeteners, colorings and flavorings, and monosodium glutamate (MSG). Materials that handlers and processors may use are defined by the U.S. National Organic Program's List of Allowed and Prohibited Substances. [Find out more]
   
   
5. Organic foods have been scrutinized for food safety risks as well as advantages. Some organic production practices and restrictions imply potential health hazards including bacterial and fungal contamination, and increased "natural toxin" and heavy metal content. Research to date on these issues has not substantiated significant increased dangers associated with organic foods. [Find out more]

*See also related parts of this information series:

Question and answer fact sheets in this Research Guide:

• Should I purchase organic foods? Introduction

• A. Where are background resources? [A-3 sections]

• B. Does organically-grown food contain more or better nutrients – vitamins, minerals and phytonutrients – than conventionally grown food? [B-7 sections]

• C. Are there fewer pesticide residues on organic foods than on conventionally grown foods? Are there fewer antibiotic and hormone residues in organic meat, eggs and dairy products than in conventional animal products? Is organic food safer to eat? [C-5 sections]

• D. Are organic foods more environmentally friendly than non-organic foods? Do organic farming practices have fewer negative impacts on soil resources, water quality and climate change than conventional practices? Are organic farms more sustainable? [D-in progress]

Bibliographies:

• Organically Produced Foods: Nutritive Content. Citations for research publications to 2000 (2000), Full text: http://www.nal.usda.gov/afsic/pubs/srb0802.shtml and citations for research publications, 2000-July 2008 (2008), Full text: http://www.nal.usda.gov/afsic/pubs/srb0003.shtml

• Organically Produced Foods: Food Safety Issues. Citations for research publications, 2000-July 2008 (2008). Full text: http://www.nal.usda.gov/afsic/pubs/srb0803.shtml

• Organic Agriculture's Conservation Focus: Selected Research Publications 2005-2006 (2006). Full text: http://www.nal.usda.gov/afsic/pubs/orgconserv2006.shtml

Also of interest:

• Food Safety Information Center. National Agricultural Library, USDA.
  Homepage: http://foodsafety.nal.usda.gov/nal_display/index.php?info_center=
  16&tax_level=1

• FoodSafety.gov, Gateway to Government Food Safety Information.
  Homepage http://www.foodsafety.gov/

• Food Safety Reading Room. National Agricultural Law Center. Homepage: http://www.nationalaglawcenter.org/readingrooms/foodsafety/

-1-

C. Are there fewer pesticide residues on organic foods than on conventionally grown foods? Are there fewer antibiotic and hormone residues in organic meat, eggs and dairy products than in conventional animal products? Is organic food safer to eat?
Find Out More. Issues and References, number 1.

1. U.S. organic standards do not directly address food safety. However, the regulations mandate that organic food producers and processors meet requirements that have food safety implications. Organic food must also meet the same State and Federal food safety requirements as non-organic foods.

United States Department of Agriculture (USDA) National Organic Program (NOP) oversees all labeling and marketing claims for "certified organic" products sold in the U.S. "The NOP is a marketing program housed within the USDA Agricultural Marketing Service. Neither the OFPA [Organic Food Production Act] nor the NOP regulations address food safety or nutrition." Excerpt: Background Information. USDA, National Organic Program, 2008. Full text: http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELDEV3004443&acct=nopgeninfo

"Though the NOP regulation is a process – rather than product-based standard, there are many provisions that require organic crop and livestock producers and handling operations to reduce food safety risks beyond those required of non-organic producers and handlers… Organic foods must meet the same State and Federal food safety requirements as non-organic foods. In addition, the National Organic Program Final Rule, which took effect October 21, 2002, mandates that organic producers and handlers meet additional requirements which have food safety implications. These requirements can be grouped into the following five categories; 1) records and traceability; 2) crop management; 3) livestock management; 4) product contamination; and 5) residue tolerances." Excerpt, Introduction: Risks of Organic vs. Conventional Foods, by James A. Riddle. Minnesota Institute for Sustainable Agriculture, University of Minnesota, 2004. Full text: http://www.misa.umn.edu/vd/risks.html

See also: Organic Food Safety – Regulatory Requirements, by James A. Riddle. Northeast Organic Farming Association, 2009. Full text: http://www.nofa.org/policy/riddle.php

Consumer surveys reveal that many retail organic food purchases are based on assumptions about food safety.

"Public risk perceptions and demand for safer food are important factors shaping agricultural production practices in the United States. Despite documented food safety concerns, little attempt has been made to elicit consumers' subjective risk judgments for a range of food safety hazards or to identify factors most predictive of perceived food safety risks. In this study, over 700 conventional and organic fresh produce buyers in the Boston area were surveyed for their perceived food safety risks. Survey results showed that consumers perceived relatively high risks associated with the consumption and production of conventionally grown produce compared with other public health hazards. For example, conventional and organic food buyers estimated the median annual fatality rate due to pesticide residues on conventionally grown food to be about 50 per million and 200 per million, respectively, which is similar in magnitude to the annual mortality risk from motor vehicle accidents in the United States. Over 90% of survey respondents also perceived a reduction in pesticide residue risk associated with substituting organically grown produce for conventionally grown produce, and nearly 50% perceived a risk reduction due to natural toxins and microbial pathogens. Multiple regression analyses indicate that only a few factors are consistently predictive of higher risk perceptions, including feelings of distrust toward regulatory agencies and the safety of the food supply. A variety of factors were found to be significant predictors of specific categories of food hazards, suggesting that consumers may view food safety risks as dissimilar from one another. Based on study findings, it is recommended that future agricultural policies and risk communication efforts utilize a comparative risk approach that targets a range of food safety hazards." Abstract: "Perceived Risks of Conventional and Organic Produce: Pesticides, Pathogens, and Natural Toxins," by Pamela R. D. Williams & James K. Hammitt. Risk Analysis 21, no. 2 (2002): pp. 319-330.

Critics point to potential food safety hazards that may be of concern in organic foods. Some points of contention are raised in the article cited below: (See section 5 of this fact sheet for details.)

"Many consumers choose organic produce on the grounds of safety, but there is little evidence that organically produced food is either more or less safe than conventionally produced food. By definition, organic produce will contain much lower levels of agrochemical residues than conventionally produced food, but there is no evidence that permitted levels of agrochemical residues are harmful. In contrast, it can be argued that organically produced food may be less safe than conventional produce. Use of manure rather than chemical fertilisers may cause contamination with pathogenic organisms. The varieties of plants that are most suitable for cultivation without the use of agrochemicals are those that produce large amounts of natural pesticides and other toxins, many of which have been shown to have carcinogenic or mutagenic potential.[18] The message to consumers is that neither 'natural' nor 'organic' means 'safe'." Excerpt: "Naturally Safe?" by D. Bender. Journal of the Science of Food and Agriculture 85, no. 15 (2005): pp. 2511-2513.

Food safety has become a "hot" issue, especially in the arena of the organic vs. conventional foods debate. Marketing claims abound on both sides. Consumers need to ground themselves in food safety basics – where and how food is produced and how it gets to the dinner table – in order to understand and evaluate food safety risks. All parties agree that consuming recommended amounts of fruits and vegetables, either conventionally grown or organically, promotes health and should be encouraged.

"All food has both benefits and drawbacks. That is why the more we understand about food safety in general, and the terminology used to describe it, the better equipped we will be to make appropriate decisions…. Deciding whether a food is safe or hazardous is difficult. It has the potential to be both. Food can never be proven to be entirely safe nor entirely hazardous. It can only be proven to be hazardous to some degree under certain conditions. While demanding completely safe food is unrealistic, it is possible to have food in which potential hazards have been reduced. The United States has one of the safest food supplies in the world. Maintaining a safe food supply is a goal of the majority of food producers, processors, and distributors." Excerpt: Food: How Safe is Safe? by William Schafer. Cooperative Extension Service, Minnesota, 1998. http://www.extension.umn.edu/distribution/nutrition/DJ5524.html

-2-

C. Are there fewer pesticide residues on organic foods than on conventionally grown foods? Are there fewer antibiotic and hormone residues in organic meat, eggs and dairy products than in conventional animal products? Is organic food safer to eat?
Find Out More. Issues and References, number 2.

2. Pesticide residues – traces of chemicals that were applied to food crops in the field, during processing and/or while in storage – are measurably different on organic foods and non-organic foods. Analysis of USDA and other data documenting pesticide residues on fresh vegetables and fruits shows that organic produce carries significantly fewer pesticide residues than conventional produce. Measured residues on most products, both organic and non-organic, do not exceed government-defined thresholds for safe consumption.

U.S. organic production standards prohibit the use of synthetic pesticides in all phases of organic food production and processing. Use of certain natural pesticides is allowed.

U.S. organic standards define synthetic pesticides – insecticides, fungicides and herbicides – as prohibited substances. Prohibited substances may not be applied to organic crops or livestock, and, in fact, may not be applied to land for the 3 years preceding harvest of an organic crop. They are also banned in organic food handling and processing. Relevant sections of the regulatory text include:
Title 7: Agriculture - Part 205 - National Organic Program -
§205.105 Allowed and prohibited substances, methods, and ingredients in organic production and handling §205.202 Land requirements
For full text: Electronic Code of Federal Regulations (e-CFR): http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?type=simple;c=ecfr;cc=ecfr;
sid=4163ddc3518c1ffdc539675aed8efe33;region=DIV1;
q1=national%20organic%20program;rgn=div5;view=text;idno=7;
node=7%3A3.1.1.9.31

For information on exceptions to prohibited substances, both synthetic and non-synthetic, see the National Organic Program's National List of Allowed and Prohibited Substances: http://www.ams.usda.gov/AMSv1.0/
ams.fetchTemplateData.do?template=
TemplateN&navID=NationalListLinkNOPNationalOrganicProgramHome&rightNav1=
NationalListLinkNOPNationalOrganicProgramHome&topNav=&leftNav=
NationalOrganicProgram&page=NOPNationalList&resultType=&acct=nopgeninfo

Selected natural pesticides, which are not without food safety risks, are allowed in organic production. Their use is restricted and must be documented. Surveys show that organic farmers apply fewer of these pesticide products and at lower rates than do most corresponding conventional farmers. Allowed biological pesticides – derived from plants and naturally occurring bacteria and fungi – include Bacillus thuringiensis (Bt), pyrethrum, neem, insecticidal soaps and horticultural oils. Tolerance levels for most biological pesticides have not been set, and data on their residues are very limited at this time.

Analysis of USDA and other data documenting pesticide residues on fresh vegetables and fruits shows that organic produce carries significantly fewer pesticide residues than conventional produce.

"Our analysis shows convincingly that organically grown foods have fewer and generally lower pesticide residues than conventionally grown foods. This pattern was consistent across all three independent data sets [U.S. Department of Agriculture Pesticide Data Program; Consumers' Union; California Department of Pesticide Regulation Marketplace Surveillance Program]. Organic foods typically contain pesticide residues only one-third as often as conventionally grown foods do. Foods marketed with an IPM [Integrated Pest Management] or NDR [No Detectable Residues] claim fall in between organic and conventional foods in both the frequency of residues and residue levels. Organic samples are also far less likely to contain multiple residues than conventional or IPM/NDR foods are." Excerpt, Discussion: "Pesticide Residues in Conventional, Integrated Pest Management (IPM)-Grown and Organic Foods: Insights from Three US Data Sets," by B.P. Baker, C.M. Benbrook, E. Groth III and K.L. Benbrook. Food Additives and Contaminants 19, no. 5 (2002): pp. 427-446.

See also:
Background material at Organic Materials Research Institute (OMRI). Full text: http://www.omri.org/FAC.html

"A Closer Look at the Pesticide Residue Question," by Charles Benbrook. NewFarm, April 2004. Full text: http://www.newfarm.org/depts/gleanings/0504/pesticide.shtml

Synthetic pesticide residues are sometimes found on organic produce. When residues are found in excess of 5 percent of the applicable Environmental Protection Agency (EPA) tolerance level, the organic certifying agency is required by the U.S. National Organic Program to investigate. "Based on 2002 PDP [USDA Pesticide Data Program] testing, it appears that about one-third of the residues found in organic food were the result of incidental environmental contamination, and two-thirds resulted from laboratory or chain of custody error, mislabeling, or fraud." Excerpt: Minimizing Pesticide Dietary Exposure Through the Consumption of Organic Food, by Charles Benbrook. Organic Center, 2004. Full text: http://www.organic-center.org/reportfiles/PESTICIDE_SSR.pdf

Some surveys have also studied residue levels in processed organic food products including baby foods, but the data remain scant, poorly analyzed and/or inconsistent.

Dietary impact of pesticide residues in terms of organic vs. non-organic diets is also being studied. Using urine analysis as a tool, "This study found that children with primarily organic diets had significantly lower organophosphorus pesticide exposure than did children with primarily conventional diets. Dose estimates generated from pesticide metabolite data suggest that organic diets can reduce children's exposure levels from above to below the U.S. EPA's chronic reference doses, thereby shifting exposures from a range of uncertain risk to a range of negligible risk. Consumption of organic produce represents a relatively simple means for parents to reduce their children's exposure to pesticides." Excerpt: "Organophosphorus Pesticide Exposure of Urban and Suburban Preschool Children with Organic and Conventional Diets," by C.L. Curl, R.A. Fenske and K. Elgethun. Environmental Health Perspectives 111, no. 3 (2003): pp. 377-382. Full text: http://www.ehponline.org/members/2003/5754/5754.pdf

See also:

"Organic Diets Significantly Lower Children's Dietary Exposure to Organophosphorus Pesticides," by C. Lu, K. Toepel, R. Irish, R.A. Fenske, D.B. Barr and R. Bravo. Environmental Health Perspectives 114, no. 2 (2006): pp. 260-263. Full text: http://www.ehponline.org/members/2005/8418/8418.pdf

"Children's Exposure to Pesticides: Diet vs. Home Pesticide Use." Healthier Homes and Gardens, February 2008. Northwest Coalition for Alternatives to Pesticides. Full text: http://www.pesticide.org/hhg/OPSpyrethroids.html

Residues on almost all conventionally and organically grown produce sold in the U.S. do not exceed government-defined thresholds for safe consumption.

Both organic and conventional foods sold in the United States, for the most part, carry pesticide residues well below government-determined thresholds. Controversy remains, however, as to how to determine what "safe" levels of pesticide residues are, especially in regard to impacts on children and the unborn, and the effects of collective or multiple pesticide exposure. In 1996, the National Academy of Sciences report Pesticides in the Diets of Infants and Children stated: "The committee found that infants and children differ both qualitatively and quantitatively from adults in their exposure to pesticide residues in foods. Children consume more calories of food per unit of body weight than do adults. But at the same time, infants and children consume far fewer types of foods than do adults. Thus, infants and young children may consume much more of certain foods, especially processed foods, than do adults. And water consumption, both as drinking water and as a food component, is very different between children and adults." Excerpt, Conclusions: Pesticides in the Diets of Infants and Children, National Academy of Sciences, Commission on Life Sciences, 1993. Full text: http://books.nap.edu/catalog.php?record_id=2126

Tolerance levels for pesticide residues on food are established by the U.S. Environmental Protection Agency (EPA). Other Federal and State agencies including the U.S. Department of Agriculture (USDA) and the Food and Drug Administration (FDA) are tasked with enforcement of the standards through surveillance of imported and/or retail food products.
See:
Setting Tolerances for Pesticide Residues in Foods, EPA. Full text:
http://www.epa.gov/pesticides/factsheets/stprf.htm

Pesticides and Food: What You and Your Family Need to Know, EPA. Full text:
http://www.epa.gov/pesticides/food/index.htm

Pesticides and Food: What the Pesticide Residue Limits are on Food, EPA. Full text: http://www.epa.gov/pesticides/food/viewtols.htm

Pesticide Data Program, Agricultural Marketing Service (AMS), USDA. USDA. Full text: http://www.ams.usda.gov/AMSv1.0/ams.fetchTemplateData.do?template=
TemplateC&navID=ScienceandLaboratories&leftNav=ScienceandLaboratories &page=PesticideDataProgram&description=Pesticide%20Data%20Program&acct
=pestcddataprg

Pesticide Data Program: Annual Summary, Calendar Year 2007. USDA, 2008. Full text: http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5074338

Residue Monitoring Reports: FDA Pesticide Program Residue Monitoring: 1993-2007. FDA. Full text: http://www.fda.gov/Food/FoodSafety/FoodContaminantsAdulteration/
Pesticides/ResidueMonitoringReports/default.htm

Compliance Policy Guidance Manual. FDA. Full text: http://www.fda.gov/ora/compliance_ref/cpg/cpgfod/cpg575-100.html

-3-

C. Are there fewer pesticide residues on organic foods than on conventionally grown foods? Are there fewer antibiotic and hormone residues in organic meat, eggs and dairy products than in conventional animal products? Is organic food safer to eat?
Find Out More. Issues and References, number 3.

3. Food safety issues related to animal products – meats, eggs and dairy products – are diverse. Direct comparison studies of organic vs. non-organic foods are few, and the current data available are specific to commodity, specific to production practice and/or specific to food safety risk. Organic meat products do reduce risk for potential exposure to prion-related diseases including mad cow disease and to arsenic residues in chicken meat; and organic livestock practices do not contribute to the growing phenomenon of drug resistant pathogens. In other respects, however, current data show few significant differences with regard to food safety.

Meat and dairy food recalls have become common in the past few years. Conventional livestock production relies on some practices that some have come to question vis a vis safe food – routine use of growth hormones and antibiotics; large-scale, unsanitary operations; questionable animal feed ingredients including rendered animal parts and feces; occasions of feed contamination; and food irradiation. The Food and Drug Administration's recent approval of meat and milk from cloned animals for human consumption, and the future prospect of food products from genetically engineered animals have also raised concerns. The validity of the health risks associated with all of these issues is hotly debated. Organic rules and practices do provide alternatives to some, but not all, of these practices. U.S. organic production standards for all livestock operations ban treatment with most synthetic veterinary drugs including antibiotics and growth hormones. Regulations also require the exclusive use of certified organic feed that excludes ingredients derived from urea and/or manure; and from mammalian or poultry slaughter by-products in feed for mammals or poultry. Manufacturers must prevent the contamination of organic feed with antibiotics and hormones. Animals must also be provided with regular access to the outdoors; grazing animals require certified organic pastures. Organic rules exclude all genetically modified organisms, both plant and animal, as well as products from cloned animals. Finally, irradiation of any organic food is forbidden. USDA regulations covering fish are not in place at this time.

Veterinary care. From the U.S. Federal Regulation: National Organic Program:

§ 205.238 Livestock health care practice standard.
(c) The producer of an organic livestock operation must not:
    (1) Sell, label, or represent as organic any animal or edible product derived from any animal treated with antibiotics, any substance that contains a synthetic substance not allowed under §205.603, or any substance that contains a nonsynthetic substance prohibited in §205.604.
    (2) Administer any animal drug, other than vaccinations, in the absence of illness;
    (3) Administer hormones for growth promotion;
    (4) Administer synthetic parasiticides on a routine basis;
    (5) Administer synthetic parasiticides to slaughter stock;
    (6) Administer animal drugs in violation of the Federal Food, Drug, and Cosmetic Act; or
    (7) Withhold medical treatment from a sick animal in an effort to preserve its organic status. All appropriate medications must be used to restore an animal to health when methods acceptable to organic production fail. Livestock treated with a prohibited substance must be clearly identified and shall not be sold, labeled, or represented as organically produced.
    Full text: Electronic Code of Federal Regulations (e-CFR),
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?type=simple;c=ecfr;cc=ecfr;
sid=4163ddc3518c1ffdc539675aed8efe33;region=DIV1;q1=national
%20organic%20program;rgn=div5;view=text;idno=7;node=7%3A3.1.1.9.31

See also:

National List of Allowed and Prohibited Substances. USDA, National Organic Program. Full text: http://www.ams.usda.gov/AMSv1.0/
ams.fetchTemplateData.do?template=TemplateN&navID=
NationalListLinkNOPNationalOrganicProgramHome&rightNav1=
NationalListLinkNOPNationalOrganicProgramHome&topNav=
&leftNav=&page=NOPNationalList&resultType=&acct=nopgeninfo

Synthetic Substances Allowed for use in Organic Livestock Production in the United States. eExtension, eOrganic, 2009. Full text: http://www.extension.org/article/18553

"Comparing Standards for Meat Production: USDA Agricultural Marketing Service Grass Fed, American Grassfed Association, USDA National Organic Program," by Ann Baier. ATTRA News 17, no. 4 (Aug. –Sept. 2009). Full text: http://www.attra.org/newsletter/attranews_0909.html

Meat and Poultry Labeling Terms. USDA, Food Safety Inspection Service, 2006. (Information about other meat labels allowable in the U.S., including "natural," "free range," "no hormones," and "no antibiotic") Full text: http://www.fsis.usda.gov/FactSheets/
Meat_&_Poultry_Labeling_Terms/index.asp

Veterinary care issues – Growth hormones. The use of natural and artificial hormones in livestock production – to promote animal growth in meat animals or increase the rate of milk production in cows – is completely banned in organic livestock production. The issue is a controversial one. To understand the significant differences in claims as to their safety, one needs to evaluate almost every aspect of their use. How do these substances affect animal health; how and when do they break down in meat and milk; and how do they impact human health, both directly through food consumption and indirectly through water contamination, via human and animal waste?

Natural and artificial hormones have been administered to conventionally raised cattle, and sometimes to sheep, for the purposes of enhancing animal growth in the U.S. and Canada for many years. Federal regulations do not permit the use of hormones in raising hogs, chickens, turkeys and other fowl, conventional or organic. Both the USDA and FDA have issued guidance for registration and administration of growth hormones and establishment of tolerance levels for certain hormone residues in meat. Meats and milk in this country have been found, for the most part, to contain hormone residues below government-defined thresholds for safe consumption. There is a related public health issue connected to hormone use: the increasing pharmaceutical pollution of U.S. waters from both human and animal waste. There are many unanswered questions about the health and environmental impacts of these water-borne drugs. The role that livestock production and waste management practices may play in this scenario is only now beginning to be addressed.

In contrast to the U.S., the European Union does not allow the use of growth hormones in livestock production, and the import of meat from animals treated with growth hormones has been banned on the grounds of food safety risks since 1988. Despite a 2008 World Trade Organization ruling that found against the EU's stance, the EU maintains its claims that precautions are necessary to ensure environmental and human health.

From the U.S.: "The Food and Drug Administration (FDA) is responsible for ensuring that animal drugs and medicated feeds are safe and effective for animals, and that food from treated animals is safe for humans to eat. Certain steroid hormones have been approved for use at very low concentrations to increase the rate of weight gain and/or improve feed efficiency in beef cattle. No steroid hormones are approved for use in poultry. All of the steroid hormonal growth-promoting drugs are available for over-the-counter purchase in the U.S., and are generally administered by the livestock producer at specific stages of production. Residue levels of these hormones in food have been demonstrated to be safe, as they are well below any level that would have a known effect in humans." Excerpt, The Use of Steroid Hormones for Growth Promotion in Food-Producing Animals. FDA, 2002. Full text: http://www.fda.gov/AnimalVeterinary/NewsEvents/FDAVeterinarianNewsletter/
ucm110712.htm

From the European Union: "Concerns are based on the accumulating evidence on the fragility of the endocrine equilibrium in all stages of life as well as the potential genotoxicity of these compounds and their metabolites. Exogenous hormone exposure may disrupt this delicate equilibrium as is evidenced by the pronounced effects of oestrogens and testosterone on functional imprinting. Thus even exposure to residual amounts of hormonally active compounds as present in meat and meat products needs to be evaluated in terms of potentially adverse effects to public health." Excerpt, Executive Summary, Assessment of Potential Risks to Human Health from Hormone Residues in Bovine Meat and Meat Products. Opinion of The Scientific Committee on Veterinary Measures Relating to Public Health, European Commission, Directorate-General XXIV, Consumer Policy And Consumer Health Protection, 1999. Full text:http://ec.europa.eu/food/fs/sc/scv/out21_en.pdf

Use of the synthetic hormone, recombinant bovine somatotropin (rBST), used to increase milk production in dairy animals, is also banned in organic livestock production. Milk produced in the U.S. or imported to the U.S. is one of the most regulated and tested foods in the U.S. Yet it is one of the most contested when it comes to food safety. As with the beef growth hormone debate, administration of rBST to dairy animals presents issues that are scientifically complex and shaded with political and philosophical rhetoric.

"Bovine somatotropin (BST) is a natural protein hormone that regulates milk production in cows. The hormone can be produced using recombinant DNA technology. Recombinant bovine somatotropin (rBST), also known by its Monsanto trade name Posilac, is a biosynthetic version of the naturally occurring pituitary hormone in cows. When injected in cows, rBST can increase milk production by 10% to 20%." Excerpt, Recombinant Bovine Growth Hormone, by: Joseph Holstead, Connecticut General Assembly, 2007. (R-0159). Full text: http://www.cga.ct.gov/2007/rpt/2007-R-0159.htm

"FDA's Center for Veterinary Medicine (CVM) has reexamined the human food safety of recombinant bovine somatotropin (rbST) in response to recent inquiries about the safety of this product. FDA's CVM approved Monsanto Company’s rbST product, Posilac in November 1993 after a comprehensive review of the product's safety and efficacy, including human food safety. CVM has issued a detailed report based on a careful audit of the human food safety sections of this approval. CVM's finding upholds the Agency's original conclusion that milk from cows treated with rbST is safe for human consumption." Excerpt, CVM Update: Update on Human Food Safety of bST. Food and Drug Administration (FDA), 1999. Updated 2009. Full text: http://www.fda.gov/AnimalVeterinary/NewsEvents/CVMUpdates/ucm130356.htm

"In summary, with one exception, the panel finds no biologically plausible reason for concern about human safety if rbST were to be approved for sale in Canada. The only exception to this statement is the occurrence of an antibody reaction (possible hypersensitivity) in a subchronic (90-day) study of rbST oral toxicity in rats that resulted in one test animal developing an antibody response at low dose (0.1 mg/kg/day) after 14 weeks…" Excerpt, Report of the Royal College of Physicians and Surgeons of Canada Expert Panel on Human Safety of rbST. Prepared for Health Canada, January 1999. Full text: http://www.hc-sc.gc.ca/dhp-mps/vet/issues-enjeux/rbst-stbr/rep_rcpsc-rap_crmcc-eng.php

See also:

Consumer Concerns about Hormones in Food, by Renu Gandhi and Suzanne M. Snedeker. (Fact Sheet #37) Program on Breast Cancer and Environmental Risk Factors in New York State, June 2000. Full text: http://envirocancer.cornell.edu/Factsheet/Diet/fs37.hormones.cfm

"Hormones: Here's the Beef," by Janet Raloff. Science News 161, no. 1: 10-13.

Bovine Somatotropin. WikiPedia the Free Encyclopedia, 2008. Full text: http://en.wikipedia.org/wiki/Bovine_somatotropin

Safety of Bovine Somatotropin (bST), eXention, 2008. Full text: http://www.extension.org/pages/Safety_of_Bovine_Somatotropin_(bST)

Frequently Asked Questions About rBGH. Organic Valley. Full text: http://www.organicvalley.coop/why-organic/synthetic-hormones/about-rbgh/

"Fighting on a Battlefield the Size of a Milk Label," by Andrew Martin. New York Times. March 9, 2008. Full text: http://www.nytimes.com/2008/03/09/business/09feed.html?_r=2&oref=slogin&
oref=slogin

Veterinary care issues – Antibiotics. Treatment with antibiotics is not permitted in any U.S. organic livestock operation. Therefore, antibiotic residues – traces of antibiotics or their derivatives in eggs, milk or meat – are not an issue in organic foods. Due to government required wait/withdrawal periods between antibiotic treatment and slaughter of all animals, organic and non-organic, antibiotic residues above government-set tolerance levels are generally not present in any animal product sold in the U.S.

If an organic animal is treated with antibiotics, it must be clearly identified and may not be sold, labeled, or represented as organically produced. Milk from treated cows is barred from the organic market even if it meets all other organic requirements. Other countries’ organic regulations allow re-entry of a cow into the organic dairy herd and into organic milk production after a wait period during which the cow’s body is cleared of all antibiotic residues. For instance, Canada’s rule specifies a 14-day withdrawal period.

The U.S. Food and Drug Administration (FDA) considers treatment with registered antibiotics and growth hormones safe for animals, humans and the environment. "To reduce the risk of antibiotic residues, the FDA requires withdrawal of antibiotics from animals for a specified period prior to harvest. Existing antibiotic-residue testing technology can detect residues that exceed the FDA's minimum thresholds. These tests do not have the sensitivity to verify "antibiotic-free" or that no antibiotics were ever administered. After an antibiotic is administered for treatment, the body slowly depletes the traceable residue." Federal Register, vol . 67, no . 250, Notices: Department of Agriculture (USDA), Agricultural Marketing Service (AMS). [Doc. No . LS-02-02] United States Standards for Livestock and Meat Marketing Claims (67 FR 79552) Monday, December 30, 2002. Full text:http://www.fda.gov/ohrms/dockets/dockets/06p0394/
06p-0394-cp00001-08-Tab-06-FR-Notice-2002-vol1.pdf

See also:

The Use of Drugs in Food Animals: Benefits and Risks, National Academies Press, 1999. Full text: http://www.nap.edu/catalog.php?record_id=5137

"Quality Milk and Tests for Antibiotic Residues," by William M. Sischo. Paper presented at Symposium: Drug Residue Avoidance: The Issue of Testing. Journal of Dairy Science 79, no. 6 (1996): 1065-1073. Full text: http://jds.fass.org/cgi/reprint/79/6/1065.pdf

"When it Comes to Animal Health and Welfare, There are Worse Things than Antibiotics," by Hubert J. Karreman. NewFarm, May 2007. Full text: http://www.newfarm.org/features/2007/0507/antibiotics/karreman.shtml

Veterinary care issues – Antibiotic resistance of bacteria. While not directly related to food safety, antibiotic resistance is a human and public health issue with links to the organic vs. conventional food debate. It is argued that the widespread use of antibiotics to treat non-life threatening problems in both human and animal medicine (including "sub-therapeutic" applications common in conventional industrial livestock operations) has speeded the evolution of antibiotic resistant pathogens. Organic producers, by regulatory definition, do not contribute to this problem. Some data collection has been done comparing populations of antibiotic resistant bacteria on conventional and organic farms and in organic and conventional meat. Evidence of antibiotic resistance differences has been found but conclusions are mixed. [For information about bacterial contamination of foods, see Section 5 of this publication.]

"Although not statistically significant, conventional farms tended to be more likely to have at least one Salmonella isolate resistant to 5 or more antimicrobial agents when compared with organic farms." Excerpt, abstract: "Antimicrobial Susceptibility of Salmonella from Organic and Conventional Dairy Farms," by K.A. Ray, L.D. Warnick, R.M. Mitchell, J.B. Kaneene, P.L. Ruegg, S.J. Wells, C.P. Fossler, L.W. Halbert and K. May. Journal of Dairy Science 89, no. 6 (2006): pp. 2038-2050. Full text: http://jds.fass.org/cgi/reprint/89/6/2038.pdf

"Organically-farmed pork samples showed significantly lower development of antimicrobial resistance in E. coli, thus contributing to reduce the development and spread of antimicrobial resistance among these food-borne bacteria." Excerpt, abstract: "Antimicrobial Resistance in Escherichia coli Strains Isolated from Organic and Conventional Pork Meat: A Comparative Survey," by J.M. Miranda, B.I. Vazquez, C.A. Fente, J. Barros-Velazquez, A. Cepeda and C.M. Franco-Abuin. European Food Research and Technology/ Zeitschrift fur Lebensmittel Untersuchung und Forschung 226, no. 3 (2008): pp. 371-375. Abstract: http://dx.doi.org/10.1007/
s00217-006-0547-y

"In conclusion, although meritorious and potentially beneficial, in the absence of a concerted effort to minimize dissemination of antimicrobial resistant bacteria among live animals and reduce bacterial cross-contamination during slaughter and processing, our findings suggest that cessation of subtherapeutic antimicrobial use during the final states of beef production will have limited impact on the prevalence of antimicrobial-resistant bacteria contaminating ground beef available to the consumer." Excerpt, "Microbial Quality of Ground Beef from Conventionally-Reared Cattle and 'Raised without Antibiotics' Label Claims," by Feffrey T. LeJeune and Nicholas P. Christie. Journal of Food Protection 76, no. 7 (2004); 1433-1437.

Several U.S. agencies are monitoring the development of drug resistance in relation to food production.

Antibiotic Resistance. (Information page) Food and Drug Administration.
http://www.fda.gov/AnimalVeterinary/SafetyHealth/AntimicrobialResistance/
default.htm

National Antimicrobial Resistance Monitoring System - Enteric Bacteria. (Information page) Food and Drug Administration. http://www.fda.gov/AnimalVeterinary/SafetyHealth/AntimicrobialResistance/
NationalAntimicrobialResistanceMonitoringSystem/default.htm

Impact of Residual Pharmaceutical Agents and their Metabolites in Wastewater Effluents on Downstream Drinking Water Treatment Facilities. [Research project] Environmental Protection Agency, 2001-2006. Project reports:
http://cfpub.epa.gov/ncer_abstracts/index.cfm/fuseaction/display.abstractDetail/
abstract/1066/report/0

Livestock feed. From the U.S. Federal Regulation: National Organic Program:

§ 205.237 Livestock feed.
  a) The producer of an organic livestock operation must provide livestock with a total feed ration composed of agricultural products, including pasture and forage, that are organically produced and, if applicable, organically handled: Except, That, nonsynthetic substances and synthetic substances allowed under §205.603 may be used as feed additives and supplements.
  (b) The producer of an organic operation must not:
    (1) Use animal drugs, including hormones, to promote growth;
    (2) Provide feed supplements or additives in amounts above those needed for adequate nutrition and health maintenance for the species at its specific stage of life;
    (3) Feed plastic pellets for roughage;
    (4) Feed formulas containing urea or manure;
    (5) Feed mammalian or poultry slaughter by-products to mammals or poultry; or
    (6) Use feed, feed additives, and feed supplements in violation of the Federal Food, Drug, and Cosmetic Act.

Full text: Electronic Code of Federal Regulations (e-CFR), http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?type=simple;c=ecfr;cc=ecfr;
sid=4163ddc3518c1ffdc539675aed8efe33;region=DIV1;
q1=national%20organic%20program;rgn=div5;view=text;idno=7;
node=7%3A3.1.1.9.31

See also: "You are What They Eat." Consumer Reports, July 2007. Full text: http://www.consumerreports.org/cro/food/food-safety/
animal-feed-and-food/animal-feed-and-the-food-supply-105/overview/

Livestock feed issues – Bovine Spongiform Encephalopathy (BSE, sometimes referred to as "mad cow disease") "BSE (bovine spongiform encephalopathy or 'mad cow disease') is a fatal neurological disease of cattle, believed to be transmitted mainly by feeding infected cattle parts back to cattle. More than 187,000 cases have been reported worldwide, 183,000 of them in the United Kingdom (UK) where BSE was first identified in 1986. The annual number of new cases has declined steeply since 1992. Humans who eat contaminated beef are believed susceptible to a rare but fatal brain wasting disease, variant Creutzfeldt-Jakob disease (vCJD). About 160 people have been diagnosed with vCJD since 1986, most in the UK and none linked to any Canadian or U.S. meat consumption." BSE ("Mad Cow Disease"): A Brief Overview, by Geoffrey S. Becker. Congressional Research Service Report for Congress, 2006. Full text: http://www.nationalaglawcenter.org/assets/crs/
RS22345.pdf

In 1997 the U.S. Food and Drug Administration (FDA) prohibited the use of most mammalian protein in the manufacture of animal feed intended for cattle and other ruminants. However, some components from cattle and other species are still allowable in cattle feed including blood and blood products, gelatin, and fats, oils, grease, and tallow. "There are significant differences between organic and non-organic meat production. To begin with, there is an absolute ban on the feeding of mammalian and poultry slaughter by-products to organic mammals and poultry. This contrasts with non-organic regulations, which still allow the feeding of cattle and other slaughter by-products to cattle and other livestock." Excerpt, "Answers to Your Questions: Mad Cow Disease Questions and Answers," by James Riddle and New Farm Answer Team. New Farm, 2004. Full text: http://newfarm.rodaleinstitute.org/certification/0104/answers.shtml

Myriad questions surround BSE, variant Creutzfeldt-Jakob Disease and the relative risks to animal and human health. Research, monitoring, policymaking as well as debate are all ongoing. To find out more, see: A Focus on Bovine Spongiform Encephalopathy. (Fact sheet) Food Safety Research Information Office, National Agricultural Library. Full text: http://fsrio.nal.usda.gov/document_fsheet.php?product_id=169

"Bovine Spongiform Encephalopathy and Variant Creutzfeldt-Jakob Disease: Background, Evolution, and Current Concerns," by Paul Brown, Robert G. Will, Raymond Bradley, David M. Asher and Linda Detwiler. Emerging Infections Diseases Journal 7, no. 1 (2001). (Centers for Disease Control and Prevention) Full text: http://www.cdc.gov/ncidod/EID/vol7no1/brown.htm

Bovine Spongiform Encephalopathy (BSE). (Information page, including link to Guidance for Industry 195: Small Entities Compliance Guide for Renderers – Substances Prohibited from Use in Animal Food or Feed). Center for Veterinary Medicine, Food and Drug Administration. Full text: http://www.fda.gov/AnimalVeterinary/GuidanceComplianceEnforcement/
ComplianceEnforcement/BovineSpongiformEncephalopathy/default.htm

Bovine Spongiform Encephalopathy (BSE). (Information page) Food and Drug Administration. Full text: http://www.fda.gov/oc/opacom/hottopics/bse.html

Bovine Spongiform Encephalopathy – "Mad Cow Disease" (Information page) USDA Food Safety Inspection Service. Full text: http://www.fsis.usda.gov/Fact_Sheets/
Bovine_Spongiform_Encephalopathy_Mad_Cow_Disease/index.asp

Livestock feed issues – Arsenic in chicken
Arsenic is often used in conventional chicken feed to promote growth, kill parasites and improve pigmentation of chicken meat. It is not allowed in livestock feed under USDA organic regulations.

Roxarsone is the most common arsenic-based additive. "In its original organic form, roxarsone is relatively benign. It is less toxic than the inorganic forms of arsenic-arsenite [As(III)] and arsenate [As(V)]. However, some of the 2.2 million lb of roxarsone mixed in the nation's chicken feed each year converts into inorganic arsenic within the bird, and the rest is transformed into inorganic forms after the bird excretes it… Three different pathways exist by which roxarsone in chicken feed can contribute to human arsenic exposure. Roxarsone, or its breakdown products, ends up in chicken meat and adds to the dietary intake of arsenic; roxarsone excreted in chicken litter contaminates land and groundwater after the manure is spread on cropland; and the large amounts of poultry litter made into fertilizer pellets for home gardens and lawns contaminate homegrown produce with arsenic and expose the consumer to arsenic dust." Excerpt, "Arsenic in Chicken Production," by Bette Hileman. Chemical and Engineering News, April 9, 2007. Full text: http://pubs.acs.org/cen/government/85/8515gov2.html

Organic products offer a real alternative; arsenic is not allowed in any animal feed under USDA organic regulations. While arsenic residues found in conventionally-reared raw and fast food chicken may test below government-mandated thresholds for safe consumption, concern rests with the cumulative effect of arsenic ingestion from multiple sources, and with the arsenic deposited on farm fields and pastures via chicken litter (bedding) and manure.

For more information, see:

Playing Chicken: Avoiding Arsenic in Your Meat, by David Wallinga. Institute for Agriculture and Trade Policy, 2006. Full text: http://www.iatp.org/iatp/publications.cfm?accountID=421&refID=80529

"Chicken with Arsenic? Is That O.K.?" by Marion Burros. New York Times, April 5, 2006. Full text: http://www.nytimes.com/2006/04/05/dining/05well.html

"Chicken: Arsenic and Antibiotics." Consumer Reports, July 2007. Full text: http://www.consumerreports.org/cro/food/food-safety/animal-feed-and-food/
animal-feed-and-the-food-supply-105/chicken-arsenic-and-antibiotics/

Arsenic in Poultry Litter: Organic Regulations, by Barbara C. Bellows. ATTRA - National Sustainable Agriculture Information Service, 2005. Full text: http://attra.ncat.org/attra-pub/arsenic_poultry_litter.html

Biotechnology: Cloning and genetically modified organism (GMOs).
For consumers who are concerned about genetically modified and cloned animals, organic production and labeling offers the best way to avoid them. USDA organic certification of cloned animals, their offspring and all products from them is not allowed. Although there are no genetically modified animal food products currently approved for consumption in the U.S., the organic label denotes absence of any GMO use anywhere in the organic food chain including animal feed, drug treatments and processing.

For more information on the rule and the debate, see:

Cloning and Organic Livestock Production. National Organic Program, 2008. Full text: http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5065143
&acct=nopgeninfo

"FDA's Animal Cloning Documents Underscore Safety of Meat and Milk From Cloned Animals," by Walt D. Osborne. FDA Veterinarian Newsletter 22, no. 6 (2007). Full text: http://origin.www.fda.gov/AnimalVeterinary/NewsEvents/
FDAVeterinarianNewsletter/ucm110044.htm

"Animal Cloning and Food Safety", by Linda Bren. FDA Consumer Magazine, March-2007. Full text: http://www.fda.gov/fdac/features/2007/207_clones.html

Not Ready for Prime Time: FDA's Flawed Approach to Assessing the Safety of Food from Animal Clones. Center for Food Safety, 2007. Full text: http://www.centerforfoodsafety.org/pubs/FINAL_FORMATTEDprime%20time.pdf

Genetically Engineered Animals (Information Page). Food and Drug Administration. Full text: http://www.fda.gov/AnimalVeterinary/DevelopmentApprovalProcess/
GeneticEngineering/GeneticallyEngineeredAnimals/default.htm

Meat irradiation.
U.S. organic regulations ban all applications of food irradiation. Food irradiation is the process in which approved foods are exposed to radiant energy, including gamma rays, electron beams, and x-rays in order to destroy microorganisms, bacteria, viruses, or insects that might be present in the food. Other applications include sprout inhibition, delay of ripening, increase of juice yield and improvement of re-hydration. "In 1963, the Food and Drug Administration (FDA) found the irradiation of food to be safe. Irradiation of meat and poultry is done in a government-approved irradiation facility. Irradiation is not a substitute for good sanitation and process control in meat and poultry plants. It is an added layer of safety."

A review of the literature done in 2004 pointed to a lack of adequate research conducted to specifically address health concerns that may directly result from the consumption of irradiated food. The authors concluded that, "current evidence does not exist to substantiate the support or unconditional endorsement of irradiation of food for consumption." "There are many differing opinions on the use of radiation in food processing. However, there appears to be universal support for sanitary processing as being on of the most important considerations. Irradiation of poorly processed food only sterilizes something that should not be consumed in the first place. In addition, other useful procedures that do not generate health concerns should not be precipitately discarded without due consideration. The other major consideration is that evolving technology may replace the need to use radiation as a means to process food." Excerpt, "Health Concerns Regarding Consumption of Irradiated Food," by Bradford C. Ashley, Patrick T. Birchfield, Blake V. Chamberlain, Russ S. Kotwal, Scott F. McClellan, Shannan Moynihan, Shamim B. Patni, Scott A. Salmon and William W. Au. (Literature review) International Journal of Hygiene and Environmental Health 207, no. 6 (2004): 493-504. Abstract: http://dx.doi.org/10.1078/1438-4639-00321

For more information see:

Irradiation Resources. USDA, Food Safety and Inspection Service, 2008. Full text: http://www.fsis.usda.gov/Factsheets/Irradiation_Resources/index.asp

Food Irradiation. Centers for Disease Control and Prevention, 2005. Full Text: http://www.cdc.gov/ncidod/DBMD/diseaseinfo/foodirradiation.htm

Food Irradiation. Wikipedia, the Free Encyclopedia. Full text: http://en.wikipedia.org/wiki/Food_irradiation

-4-

C. Are there fewer pesticide residues on organic foods than on conventionally grown foods? Are there fewer antibiotic and hormone residues in organic meat, eggs and dairy products than in conventional animal products? Is organic food safer to eat?
Find Out More. Issues and References, number 4.

4. Organic regulations ban or severely restrict the use food additives, processing aids (substances used during processing but not added directly to food) and fortifying agents commonly used in non-organic foods including preservatives, artificial sweeteners, colorings and flavorings, and monosodium glutamate (MSG). Materials that handlers and processors may use are defined by the U.S. National Organic Program's List of Allowed and Prohibited Substances.

To be labeled an "organic" processed food, 95 per cent of package contents must be organically produced. The 5 percent of non-organic ingredients usually fall in the "additives" category. While most conventional additives are prohibited in processed organic foods, organic foods may contain natural additives, and in some cases, one of several synthetic additives permitted by the National Organic Program. Restrictions as to how a permitted additive may be used may also apply. Some additives found in organic food, especially vitamin fortifying agents, are there for legal reasons.

Permitted additives are listed as follows in Title 7: Agriculture, Part 205 – National Organic Program, National List of Allowed and Prohibited Substances:
§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed products labeled as "organic" or "made with organic (specified ingredients or food group(s))."
§205.606 Nonorganically produced agricultural products allowed as ingredients in or on processed products labeled as "organic."
Full text: Electronic Code of Federal Regulations (e-CFR): http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?type=simple;c=ecfr;cc=ecfr;
sid=4163ddc3518c1ffdc539675aed8efe33;region=DIV1;
q1=national%20organic%20program;rgn=div5;view=text;idno=7;
node=7%3A3.1.1.9.31

The National Organic Program considers additions and deletions to the National List:
"The following criteria will be utilized in the evaluation of substances or ingredients for the organic production and handling sections of the National List:
  (a) Synthetic and nonsynthetic substances considered for inclusion on or deletion from the National List of allowed and prohibited substances will be evaluated using the criteria specified in the Act (7 U.S.C. 6517 and 6518).
  (b) In addition to the criteria set forth in the Act, any synthetic substance used as a processing aid or adjuvant will be evaluated against the following criteria:
    (1) The substance cannot be produced from a natural source and there are no organic substitutes;
    (2) The substance's manufacture, use, and disposal do not have adverse effects on the environment and are done in a manner compatible with organic handling;
    (3) The nutritional quality of the food is maintained when the substance is used, and the substance, itself, or its breakdown products do not have an adverse effect on human health as defined by applicable Federal regulations;
    (4) The substance's primary use is not as a preservative or to recreate or improve flavors, colors, textures, or nutritive value lost during processing, except where the replacement of nutrients is required by law;
    (5) The substance is listed as generally recognized as safe (GRAS) by Food and Drug Administration (FDA) when used in accordance with FDA's good manufacturing practices (GMP) and contains no residues of heavy metals or other contaminants in excess of tolerances set by FDA; and
    (6) The substance is essential for the handling of organically produced agricultural products.
  (c) Nonsynthetics used in organic processing will be evaluated using the criteria specified in the Act (7 U.S.C. 6517 and 6518).

From Europe: "Some people will be surprised at that 95 per cent. The urge to be organic is a quest for purity – so why be satisfied with 95 per cent? The reason is that some non-organic inputs, including additives, are so essential that they are permitted in organic food. Annex VI to the Regulations lists the allowed non-organic inputs allowed at up to 5 per cent of the total, under the headings: A) non-organic additives, yeasts and minerals; B) processing aids, such as releasing oils and flushing gases; C) agricultural ingredients. In Europe, a total of 45 EC-approved additives are currently permitted in organic food under Regulation No 780/2006, which amends the organic food regulation 2092/91." Excerpt: Additives and Ingredients for Health Eating: Organic Food. Food Additives and Ingredients Association (UK). Full text: http://www.faia.org.uk/organic.php

Conventional and organic food additives have a long history and have been developed for various purposes including emulsifying and thickening processed foods, raising nutritional value and extending shelf live. All are classified, tested and regulated internationally by the Food and Agriculture Organization (FAO) and in the U.S. by the Food and Drug Administration. Critics point to incomplete or questionable testing techniques for some additives, additives that pose a risk to certain populations (e.g. children) and the dangers of excessive or cumulative consumption of food additives.

For more information, see:

Food Additives. (Information page) Food and Drug Administration. http://www.fda.gov/Food/FoodIngredientsPackaging/FoodAdditives/default.htm

EAFUS (Everything Added to Food in the United States): A Food Additive Database. Food and Drug Administration, 2009. Database: http://www.fda.gov/Food/FoodIngredientsPackaging/ucm115326.htm

Codex General Standard for Food Additives: Online Database. Codex Alimentarius, Food and Agriculture Organization (FAO)/World Health Organization (WHO) Food Standards, 2008. Database: http://www.codexalimentarius.net/gsfaonline/index.html

Food Additives. Center for Science in the Public Interest. Full text: http://www.cspinet.org/reports/chemcuisine.htm

-5-

C. Are there fewer pesticide residues on organic foods than on conventionally grown foods? Are there fewer antibiotic and hormone residues in organic meat, eggs and dairy products than in conventional animal products? Is organic food safer to eat?
Find Out More. Issues and References, number 5.

5. Organic foods have been scrutinized for food safety risks as well as advantages. Some organic production practices and restrictions imply potential health hazards including bacterial and fungal contamination, and increased "natural toxin" and heavy metal content. Research to date on these issues has not substantiated significant increased dangers associated with organic foods.

Microbial contamination. Vegetables, fruits and grains. Bacterial contamination of organic food, especially fresh produce, has made news headlines during the past few years. Attention has been focused on bacterial pathogens that are spread via manures, including Salmonella and Escherichia coli. Because many organic farmers rely on animal manures for soil fertility, the safety of organic foods has been questioned. Organic regulations address this issue: Use of manure, especially raw (not composted) manure, on organic fields is restricted by law. These regulations are more restrictive than those that apply to conventional farms. Relevant sections of the regulatory text include:

Title 7: Agriculture, Part 205– National Organic Program -
§205.203 Soil fertility and crop nutrient management practice standard.
(a) The producer must select and implement tillage and cultivation practices that maintain or improve the physical, chemical, and biological condition of soil and minimize soil erosion.
(b) The producer must manage crop nutrients and soil fertility through rotations, cover crops, and the application of plant and animal materials.
(c) The producer must manage plant and animal materials to maintain or improve soil organic matter content in a manner that does not contribute to contamination of crops, soil, or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances. Animal and plant materials include:
  (1) Raw animal manure, which must be composted unless it is:
    (i) Applied to land used for a crop not intended for human consumption;
    (ii) Incorporated into the soil not less than 120 days prior to the harvest of a product whose edible portion has direct contact with the soil surface or soil particles; or
    (iii) Incorporated into the soil not less than 90 days prior to the harvest of a product whose edible portion does not have direct contact with the soil surface or soil particles;
  (2) Composted plant and animal materials produced though a process that:
    (i) Established an initial C:N ratio of between 25:1 and 40:1; and
     (ii) Maintained a temperature of between 131 °F and 170 °F for 3 days using an in-vessel or static aerated pile system; or
    (iii) Maintained a temperature of between 131 °F and 170 °F for 15 days using a windrow composting system, during which period, the materials must be turned a minimum of five times.
§205.239 Livestock living conditions.
(c) The producer of an organic livestock operation must manage manure in a manner that does not contribute to contamination of crops, soil, or water by plant nutrients, heavy metals, or pathogenic organisms and optimizes recycling of nutrients. Full text: Electronic Code of Federal Regulations (e-CFR): http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?type=simple;c=ecfr;cc=ecfr;
sid=4163ddc3518c1ffdc539675aed8efe33;region=DIV1;
q1=national%20organic%20program;rgn=div5;view=text;idno=7;
node=7%3A3.1.1.9.31

Several research studies have attempted to measure risks related to bacterial contamination of organic crops and animal products. A sampling of studies:

"The use of animal wastes for fertilization of produce plants increased the risk of E. coli contamination in organic (OR=13.2, 95% CI=2.2–61.2, P-value <0.0001) and semi-organic (OR=12.9, 95% CI=2.9–56.3, P-value <0.0001) produce significantly. Improper ageing of untreated animal manure significantly increased this risk in organic produce (OR=4.2 95% CI=1.7–12.3, P-value=0.005) grown using such manure as a fertilizer. Organic growers who used cattle manure for fertilization of their crops showed significantly greater risk of contamination with the E. coli (OR=7.4, 95% CI=1.6–36.8, P-value=0.003), compared to those who used other types of manure-based fertilizer." Excerpt, abstract: "Association of Farm Management Practices with Risk of Escherichia coli Contamination in Pre-Harvest Produce Grown in Minnesota and Wisconsin," by A. Mukherjee, D. Speh and F. Diez-Gonzalez. International Journal of Food Microbiology 120, no. 3 (2007): pp. 296-302. Abstract: http://dx.doi.org/10.1016/j.ijfoodmicro.2007.09.007

"No difference in bacteriological quality could be detected in lettuce at harvest after application of various types of manure-based fertilizers grown under Norwegian conditions… The results may indicate that the use of manure does not have considerable influence on the bacteriological quality of organic lettuce. However, others have suggested that there is a risk by using manure. There is a need for more research in the field." Excerpt, abstract: "Influence of Bovine Manure As Fertilizer on the Bacteriological Quality of Organic Iceberg Lettuce," by G.S. Johannessen, R.B. Froseth, L. Solemdal, J. Jarp, Y. Wasteson and L.M. Rorvik. Journal of Applied Microbiology 96, no. 4 (2004): pp. 787-794. Abstract: http://dx.doi.org/10.1111/j.1365-2672.2004.02208.x

Microbial contamination. Animal products. Certain aspects of organic livestock systems, including access to pasture (and exposure to pathogens there) and restrictions on methods for pest and disease control pose questions about the safety of meat, eggs and milk products. Organic veterinary practices limit use of antimicrobials in livestock production. Without conventional antibiotics and pathogen control materials, can organic animal products be as safe as those from conventional systems? Studies of selected conventional and organic animal products have found alarmingly high incidences of certain pathogens, particularly in chicken, but few significant differences between organic and conventional products. Some research is available.

"Although consumers assume organic products to be safer and healthier, there are aspects of organic animal husbandry, like access to an outdoor run, that can result in increased risks of food safety problems. The aim of this study was to compare housing and management of organic and conventional broiler farms in the Netherlands and to study the occurrence of Salmonella and Campylobacter infections on the former. Large differences were found between the two farming systems with respect to mixed or single farming, manure storage, drinking-water system, ventilation, access to an outdoor run, and pest control. From the 31 organic flocks sampled for Salmonella and Campylobacter in 2003, 13% were positive for Salmonella and 35% for Campylobacter. Results for the summer period are missing due to an outbreak of avian influenza, so the actual number of flocks infected with Campylobacter can be expected to be even higher. Campylobacter appears to be the main risk on organic broiler farms, so that it would be interesting to study specific risk factors of infection with this pathogen on these farms." Excerpt: "Campylobacter and Salmonella Infections on Organic Broiler Farms," by T.B. Rodenburg, M.C. Van Der Hulst-Van Arkel and R.P. Kwakkel. NJAS Wageningen Journal of Life Sciences 52, no. 2 (2004): pp. 101-108. Full text, Wageningen University Library: http://library.wur.nl/ojs/index.php/njas/article/viewFile/346/65

"Overall, chickens labeled as organic or raised without antibiotics and costing $3 to $5 per pound were more likely to harbor salmonella than were conventionally produced broilers that cost more like $1 per pound. Moreover, most of the bacterial we tested from all types of chicken showed resistance to one or more antibiotics, including some fed to chickens to speed their growth and those prescribed to humans to treat infections." Excerpt, "Dirty Birds: Even 'Premium' Chickens Harbor Dangerous Bacteria." Consumer Reports, January 2007. Full text: http://www.consumerreports.org/cro/food/food-safety/
chicken-safety/chicken-safety-1-07/overview/0107_chick_ov.htm

"We found significantly higher seroprevalence of Salmonella and Toxoplasma from ABF [outdoor, antimicrobial-free] herds (54% and 7%, respectively) than conventional (39% and 1%, respectively) ( p ¼ 0.001). Two pigs, both from ABF herds, were found to be seropositive for Trichinella. The results from this preliminary study suggest that all three pathogens were more commonly present in pigs that were reared in an ABF, outdoor, niche-market type of environment than the conventional, indoor-reared herds though there were some geographical variation in Salmonella. This warrants a robust epidemiologic study to determine the role of various risk factors in the two production systems that may lead to persistence of bacterial (Salmonella) pathogens and reemergence of parasites (such as Trichinella) of historical significance." Excerpt, "Seroprevalence of Trichinella, Toxoplasma, and Salmonella in Antimicrobial-Free and Conventional Swine Production Systems," by Wondwossen A. Gebreyes, Peter B. Bahnson, Julie A. Funk, James McKean and Prapas Patchanee. Foodborne Pathogens and Disease 5, no. 2 (2008): 199-203. Abstract: http://dx.doi.org/10.1089=fpd.2007.0071

"Studies directly comparing conventional and niche-market production systems for dairy, swine, poultry, and produce have observed that the prevalence of foodborne pathogens was seldom statistically different between production systems, but when difference were observed, prevalence was typically greater for the niche-market production systems than the conventional production systems. The published literature suggests that the perception of niche-marketed food products being safer and healthier for consumers with regard to foodborne pathogens may not be justified." Excerpt, "Niche Marketing Production Practices for Beef Cattle in the United States and Prevalence of Foodborne Pathogens," by J. Trent Fox, Shelby Reinstein, Megan E. Jacob and T.G. Nagaraja. Foodborne Pathogens and Disease 5, no. 5 (2008): 559-569. Abstract: http://dx.doi.org/10.1089/fpd.2008.0094

Natural toxicants. Natural toxicants are toxins plants produce to protect themselves from insects, diseases and other threats in their environment. These toxins, or phytochemicals, while serving the plant well, may have both positive and negative effects on humans who eat them. Along with the healthful phytochemicals that are covered in part 1 of this series of fact sheets, there are potentially harmful compounds such as toxic non-protein amino acids and pro-carcinogenic furanocoumarins. Much research remains to be done on phytochemicals in general, and on food systems comparisons specifically.

"Levels of phytochemicals and other plant defence compounds are modulated by many genotype-independent factors such as light, water, CO2, oxygen and ozone, nutrient supply, pesticides, levels of diseases and herbivore damage. Therefore different production methods for crops (conventional, low input and organic) have the potential to significantly affect the levels of the phytochemicals in the crops, and subsequently affect health and nutrition in the consumers…

"Based on the various factors that can affect phytochemical levels and profiles it is obvious that differences in cultivation conditions will have effects. Conventionally-grown crops live a life of 'luxury' receiving both high nutrient inputs and chemical control of pests and diseases, whereas organically-grown crops receive nutrients through potentially slower but more natural processes and control of pests and diseases is done via non-chemical processes (e.g. biocontrol)… In the case of organically-grown crops there could be a higher level of stress (due to increased pest and disease damage) and therefore a higher level of certain phytochemicals. It is clear that further research is needed to determine the pros and cons of the different production methods in relation to animal and human health and nutrition." Excerpt: Phytochemicals under Organic and Low Input Crop Production Systems – Potential Influences on Health and Nutrition in Humans and Animals, by R.N. Bennett and E.A.S. Rosa. Organic Eprints, 2004? Full text: http://orgprints.org/7883/01/bennett.doc

"The content of furanocoumarins (representing toxic chemicals) in Apiaceae vegetables [celery, parsnips] is often increased during transportation and/or storage, probably because of various stress factors. Like other mechanical injuries, some culinary procedures, e.g. grating of celery or parsnip, may cause an (occasionally very high) increase in these compounds in a processed food commodity… As regards the influence of different farming systems on the quality of the Apiaceae crops examined, some studies show a smaller increase in furanocoumarin levels in organically grown celery and/or parsnip when injury or pest infestation occurs. Follow-up studies should be carried out to investigate whether this trend is a general phenomenon." Excerpt: "Furanocoumarins in Vegetables: Influence of Farming System and other Factors on Levels of Toxicants," by V. Schulzova, J. Hajslova, P. Botek and R. Peroutka. Journal of the Science of Food and Agriculture 87, no. 15 (2007): pp. 2763-2767. Note: Review article. Abstract: http://dx.doi.org/10.1002/jsfa.3062

Micotoxins. Due to restricted use of fungicides in organic systems, mycotoxins – toxic substances from molds – are, in theory, of concern in organic foods. Some mycotoxins (e.g. aflatoxin) are well known as powerful poisons and carcinogens. Some also present dangers to animals eating infected forage and feed. Primary mycotoxins of concern, to date, are ochratoxin, fumonisin and deoxynivalenol, patulin, zearalenone and aflatoxin. Comparative data from organic vs. conventional food studies are inconsistent on this point; some studies find higher levels in organic food and animal feeds, particularly in grains, others do not. There are also data that point to cultural practices used by organic farmers that discourage fungal attacks and development of mycotoxins.

"A reliable method for the determination of patulin in apple juice, apple puree and apples was developed using two clean-up steps and high performance liquid chromatography and diode array (HPLC–DAD) analysis… The method was used for determination of patulin in 63 commercial apple products available on the Dutch market. With the exception of one sample, the level of patulin was lower than the detection limit in all the samples. No statistically significant difference was found between conventional and organic samples." Excerpt, abstract: "Analysis of Patulin in Dutch Food, an Evaluation of a SPE Based Method," by G. Boonzaaijer, I. Bobeldijk and W.A. van Osenbruggen. Food Control 16, no. 7 (2005): pp. 587-591. Abstract: http://dx.doi.org/10.1016/j.foodcont.2004.06.020

"The aim of this study was to develop a multicomponent analytical method for the determination of deoxynivalenol (DON), ochratoxin A (OTA) and zearalenone (ZEN), nivalenol (NIV), 3-acetyl-DON (3-acDON), 15-acetyl-DON (15-acDON), zearalenol (ZOL) and citrinin (CIT) in wheat. It also aimed to survey the presence and amounts of DON, OTA and ZEN in Belgian conventionally and organically produced wheat grain and in wholemeal wheat flours… Conventional wheat tended to be more frequently contaminated with DON and ZEN than organic samples, the difference being more significant for ZEN in samples harvested in 2002. The mean OTA, DON and ZEA concentrations were 0.067, 675 and 75 µg kg^-1 in conventional samples against 0.063, 285 and 19 µ kg^-1 in organically produced wheat in 2002, respectively. Wheat samples collected in 2003 were less affected by DON and ZEN than the 2002 harvest. Organic wholemeal wheat flours were more frequently contaminated by OTA than conventional samples (p < 0.10). The opposite pattern was shown for DON, organic samples being more frequently contaminated than conventional flours (p < 0.10)." Excerpt, abstract: "Development and Application of Analytical Methods for the Determination of Mycotoxins in Organic and Conventional Wheat," by L. Pussemier, J.Y. Pierard, M. Anselme, E.K. Tangni, J.C. Motte and Y. Larondelle. Food Additives and Contaminants 23, no. 11 (2006): pp. 1208-1218. Note: Conference paper: Second International Symposium on Recent Advances in Food Analysis, held November 2-4, 2005, Prague, Czech Republic. Abstract: http://dx.doi.org/10.1080/02652030600699312

One study has also looked at the levels and effect of mycotoxins in animal feed in relation to swine physiology. "Hematological and biochemical parameters of pigs fed with organically cultivated diets were not different from those of conventionally fed pigs. Pigs fed with organically produced wheat showed a slightly higher daily weight gain, but a lower carcass yield than the conventionally fed animals. The highest residues of DON [deoxynivalenol] and total-ZEN [zearalenone] (ZEN + alpha-ZEL + beta-ZEL) were found in bile. Bile samples of organically fed pigs contained lower concentrations of total-ZEN than those of conventionally fed pigs. Altogether, these data suggest that wheat from an organic farming does not have higher mycotoxin-contamination than wheat from the conventional farming system." Excerpt, abstract: "Influence of Organically or Conventionally Produced Wheat on Health, Performance and Mycotoxin Residues in Tissues and Bile of Growing Pigs," by I. Schneweis, K. Meyer, M. Ritzmann, P. Hoffmann, L. Dempfle and J. Bauer. Archives of Animal Nutrition 59, no. 3 (2005): pp. 155-63.

Heavy metals contamination. Unhealthy levels of heavy metals – arsenic, cadmium, copper, lead, and others – in fruits and vegetables are an issue for both conventional and organic foods. Organic farming practices that researchers have examined in this context are the application of organic fertilizers with heavy metal content (and subsequent accumulation in soils and uptake by plants), and the use of copper-based pesticides approved for use on certain crops. Currently available studies have not found consistent evidence of increased risk from heavy metals in organic farm soils or in organic foods.

"The levels of Cd [cadmium] in the wheat did not correlate with the cultivation system or the Cd content in the soil. Conventionally grown wheat from one field trial showed a significantly higher Cd level compared with ecologically grown wheat, while in the other field trial significantly lower Cd levels were detected in the conventionally grown wheat. No statistically significant differences in the concentrations of Cd, Pb [lead], Cr [chromium] or Zn [zinc] in rye, carrots and potatoes were detected between the cultivation systems. The results indicate that organic farming, at least in the short term, does not necessarily result in reduced levels of Cd and other potentially harmful metals in foods of vegetable origin. Factors other than cultivation system may be of greater importance for the final concentration of Cd and other metals in plant foods." Excerpt, abstract: "Does Organic Farming Reduce the Content of Cd and Certain Other Trace Metals in Plant Foods? A Pilot Study," by L. Jorhem and P. Slanina. Journal of the Science of Food and Agriculture 80, no. 1 (2000): pp. 43-48. Abstract: http://dx.doi.org/10.1002/(SICI)1097-0010(20000101)80:1
<43::AID-JSFA482>3.3.CO;2-P

"A database has been compiled with the levels of important contaminants (mycotoxins, heavy metals and pesticides) measured from 2002 to 2005 in winter wheat (Triticum aestivum) grown in Belgium according to the organic and conventional farming systems… When expressed as a percentage of the tolerable/acceptable daily intake (TDI/ADI), it seems that the corresponding estimated (conservative) intakes are the highest for DON [deoxynivalenol] (56% for organic and 99% for conventional cereal products), ZEA [zearalenone] (16% for organic and 32% for conventional cereal products), and Cd [cadmium] (19% for organic and 17% for conventional cereal products), all other estimated intakes of contaminants (including pesticides) being lower than 10% of the TDI/ADI." Excerpt, abstract: "Contaminants in Organically and Conventionally Produced Winter Wheat (Triticum aestivum) in Belgium," by P. Harcz, L. de Temmerman, S. de Voghel, N. Waegeneers, O. Wilmart, V. Vromman, J.F. Schmit, E. Moons, C. van Peteghem and S. de Saeger. Food Additives and Contaminants 24, no. 7 (2007): pp. 713-720. Abstract: http://dx.doi.org/10.1080/02652030601185071

See also:

Heavy Metals in Fertilizers Used in Organic Production, by Diana Tracy and Brian Baker. Organic Materials Review Institute, 2005. Full text: http://www.omri.org/AdvisoryCouncil/Metals_in_Fertilizers-b6-2005-02-14.pdf

Nutrient Management and Fertilizer. Environmental Protection Agency. Full text: http://www.epa.gov/oecaagct/tfer.html