I read the article that Diane Wells wrote (March 2010, Volume 8: Issue 3) about biodegradable films with interest because as the crop adviser for the Maine Organic Farmers and Gardeners Association I have to give the bad news to growers frequently. Diane is correct that certified organic growers may not use these mulches. Although they may be made from corn or other plant-based starches, these chemicals are polymerized and so must be considered synthetic chemicals after the production. According to regulation of organic agricultural production, synthetic mulches must be removed from the field at the end of the growing season.

In order to be allowed without removing the mulches from the field, the USDA National Organic Program (NOP) will have to favorably interpret the Rule (Section 205.206 ( c ) (1), amend the Rule, or add the synthetic materials in these mulches to the list of permitted synthetic materials (Section 205.601). We in the organic community have been discussing this for years, and I am sure that the NOP will decide soon which is the best way to address the situation.

I am writing to point out a distinction that Diane made that is not correct. She made a distinction between certified and noncertified organic growers saying that “… only noncertified organic growers can use the biodegradable films … .”

The USDA National Organic Program regulations apply to anyone using the term “organic” to describe their farm products, whether certified or not. There is no distinction between these growers with respect to following the law of the land. At this time, until there is a clarification from the NOP, no one using the term “organic” should use the biodegradable films.
Eric Sideman
Crop Specialist

The Growing article titled “The Task of Keeping Track” contains some erroneous information that may confuse your readers about how to participate in the Produce Traceability Initiative (PTI) and what it will cost. It starts correctly, stating that they need to contact GS1 US; indeed, the first step in PTI is acquiring a GS1 Company Prefix through the GS1 US Partner Connections program.

The next part is incorrect, though. It states that the grower (let’s call him Mr. Brown) should contact an organization called “GTIN,” but GTIN is actually the acronym for the GS1 Global Trade Item Number supply-chain standard. It’s a number that identifies products in the form of bar codes, and is created from the GS1 Company Prefix.

The article then states that to make bar codes, Mr. Brown should go to gtin.info (a Web site operated by a solution provider called Bar Code Graphics, Inc.); this is a valid option, but not the only one. There are three directions Mr. Brown can take: He, or someone working for him, can create GTINs and bar codes with Data Driver, a Web-based application provided with the GS1 US membership program along with the GS1 Company Prefix; he can ask his existing printer or graphics house to create the bar codes for him; or he can request help from a GS1 US Certified Solution Partner, including Bar Code Graphics, Inc. A complete list of them can be found at http://barcodes.gs1us.org/dnn_bcec/tabid/243/Default.aspx.

Additional help can be found at www.producetraceability.org, and more detailed information on how to build GTINs and bar codes can be found at http://barcodes.gs1us.org/dnn_bcec/Default.aspx?tabid=300.
Thank you,
Jon Mellor

Director, External Affairs
Lawrenceville, N.J.