There is increasing interest in organic growing processes for marijuana, and it's recommended that commercial growers follow National Organic Program guidelines. Pictured: Cannabis plants fill a cultivation facility in Pueblo, Colorado. (Provided by Urban-Gro)

Does my commercial cultivation qualify as organic? Can I be certified?

Pro Growing: Agriculture expert explains the tricky nature of using the word 'organic' for a crop the USDA does not recognize

Editor’s note: Welcome to Pro Growing, The Cannabist’s commercial cannabis cultivation column. In this series, agriculture expert John Chandler will cover all aspects of growing cannabis for the legalized marketplace — from techniques and trends to compliance and best practices. Chandler understands what is working and what’s not in the marijuana industry. If you’ve got a question for our pro, please let him know — via the email address in his bio below. And remember: Cannabist columnist (and author) Jorge Cervantes answers cultivation questions from readers and noncommercial growers regularly.


As everyday consumers, we have an underlying confidence in grocery store products labeled and sold as USDA Organic. As the cannabis industry continues to grapple with pest management and regulatory compliance, a significant interest has developed in how to market organically grown cannabis.

However, there is still some confusion surrounding the term “organic” in the marijuana industry. Some cultivators may be growing organically and not even know they qualify for specific certifications — while others may be looking to adopt their practices to achieve an organic certification. If you’re a commercial cultivator looking to achieve organic certification, the good news is standards are being established for the industry, though not through the traditional channels available for other agricultural products.

In 2000, the USDA defined the word “organic” for agriculture, including food and other products. Private agencies are authorized by the USDA to perform certification. Since cannabis is still a federally illegal crop, the USDA does not recognize it as a crop that can be certified as organically grown.

Alternative certification options exist for the commercial cannabis cultivator, but none are approved or regulated by the USDA, and therefore do not create official USDA organic certification. Additionally, because the federal government owns the use of the word “organic,” cannabis crops cannot be marketed as organic. This has created a lot of confusion and frustration among marijuana growers and consumers interested in sustainability.

Where to start

Cannabis cultivators interested in following organic practices would do well to use the guidelines of the National Organic Program (NOP). NOP restricts the use of the term “organic” to certified organic producers that follow current NOP regulations.

You can refer to the NOP list of natural and synthetic products (fertilizers and pesticides) that can be used in certified organic production. The list of products allowed for use is largely true to the cause — natural and organic the way most people would think of these terms. Very few synthetic materials are allowed, and only in special cases that will not adulterate the final product.

A non-profit organization, the Organic Materials Review Institute (or OMRI), also certifies products and the manner in which they can be used in certified organic production.

Pesticides and beneficials

In order to see how your grow facility measures up, let’s look at pesticides first. Certified organic does not eliminate the use of pesticides during the production process, but limits them to organically allowed pesticides that are used according to their label restrictions. Due to the pesticide regulations that most states with legal cannabis production have instituted and are enforcing, there are very few non-organic pesticides available to the commercial marijuana cultivator.

The typical synthetic systemic pesticides (so named because they become incorporated into and distributed through the plant system) that are used in large-scale non-organic agriculture are not allowed in cannabis production, because marijuana is consumed differently than a vegetable. Consumers don’t wash flower before burning it. Some states like Nevada allow the use of some systemic synthetics, but do not allow any traceable amount to be on final products. However, to be certified organic, cultivators cannot use synthetic systemic pesticides, regardless of whether the substance is detectable on the final product.

Organic pesticides allowed on cannabis include neem oils, soaps, plant extracts and microbiological products that have pesticidal properties. Additionally, there is strict regulation of how and when they can be used that must be followed. Beneficial insects are not regulated like pesticides, so they can also be used. So as long as a commercial cultivator is following state regulations around pesticides and not using synthetic pyrethroids (naturally derived, extracted from chrysanthemum flowers, are acceptable in organic production), your pest control is likely already organic — or could be with a few minor tweaks.

Fertilizers

Fertilizer is a more complicated topic. Synthetic nutrients include potassium nitrate, calcium nitrate and mono-potassium phosphate, which make up a bulk of the common base nutrients cannabis growers use.

Certainly there are arguments to be made that there is nothing wrong with these man-made compounds, but the fact remains that they are not allowed by NOP.

Many of the common synthetic-based nutrients available at hydro stores include some organic ingredients, which adds to the confusion. Of the hundreds of commercial marijuana facilities I have visited, only a couple are practicing truly NOP-approved fertilization of their crops.

Indoor cannabis cultivation shown in discussion on organic marijuana certification
A new cannabis cultivation facility in Massachusetts, installed in the summer of 2016. (Provided by Urban-Gro)

Generally speaking, there are two main methods of organic fertilization. Non-liquid options include kelp and alfalfa meals, guanos and compost, which are added to the soil and watered in with biological inoculants that help break down the products into plant available nutrients. Some growers also make teas out of these same solid ingredients and apply the tea to the soil and foliage. Alternatively, in the last 10-to-15 years many liquid, largely plant-available organic sources of nutrients have come to market (mostly fish and soy hydrolysates), making it easier for large-scale producers to apply NOP-approved nutrients to crops through their irrigation systems (fertigation). Often, growers utilize both methodologies to maintain proper nutrition delivery to their crops.

In my experience, certifiably organic marijuana crops do not necessarily mean lower yields. With the knowledge and technology available to organic growers today, comparably high yielding organic crops can certainly be grown.

Substrates

Substrate, or the rooting medium where marijuana is grown, is also of concern for the would-be organic cannabis cultivator. Coco coir is the most popular substrate with commercial growers. Although coir is a certifiably organic material, the majority of coir is buffered with calcium nitrate, which is not a certifiably organic material. Peat-based substrates (e.g. Pro-Mix and Sunshine) are also organic-based, but most of the economically viable products currently available to commercial marijuana growers have some inorganic fertilizers added to them, so sourcing an OMRI peat substrate would be required for organic certification.

Due to the manufacturing process and some ingredients, another popular cannabis growing substrate, rockwool, is not organic, and therefore there are no certifiably organic rock/stonewools available to would-be organic growers. The use of a certifiably organic material as substrate is a challenge that must be addressed for those growers hoping to certify and market their products as organic.

Cleaning compounds and the nitty gritty

In addition to pesticides and fertilizers, the cleaning compounds used — and how they are utilized in cultivation rooms, greenhouses and irrigation systems — will also be a consideration for those seeking to be certified organic marijuana producers.

Documenting that a harvester has been cleaned between use with non-organic and organic crops, as well as checking the chemicals used to clean harvest equipment, will be necessary to remain compliant.

Post-harvest, there are rules and considerations of concentrating and cooking with cannabis that will need to be addressed. For example, it is doubtful that butane and other hydrocarbon extractions will be considered organic.

Alternate certifications

Forward-thinking third-party organizations are working to provide recommendations on standardizing sustainable practices in the marijuana industry. These private agencies are sidestepping the word “organic” by certifying cannabis as “Clean Green” and “Certified Kind,” while using the USDA NOP as a basis for their certifications.

The Organic Cannabis Association (OCA) is working to pass landmark legislation in Colorado to certify marijuana crops as organic and create a template for other states to follow to improve consumer and industry transparency. Cultivators interested in obtaining a certification from the OCA must follow a thorough multi-phase process that begins with an initial site visit along with pesticide testing of random samples in their grow. Three more site visits and a formal review of insect and pest management techniques follow.

An OCA Pesticide-Free certification indicates the final product has zero residual pesticides. The one-year certification is issued only after a final review of lab results and an audit of pest management methodology. Other third-party groups such as the California-based Clean Green certified and the Oregon-based Organic Cannabis Growers Society offer similar audit services and certifications.

These new certification options for the marijuana industry are establishing the standard of what qualifies as organic, and therefore “good,” in the eyes of the consumer — although much still remains open to interpretation and further discussion.

The good news? With a commitment to complying to these alternate certifications, standards can start to be created and universally understood — moving us toward, ultimately, more sustainable cultivation practices and inherent consumer confidence.