food safety – The Garden Professors™

The Dirty Truth Behind the “Dirty Dozen”

By: Abi Saeed

Pesticide residues and risk assessments have been a major topic of interest and inquiry for me for over a decade, and something that I wanted to write about on the Blog for quite some time. Over the past couple of months, I have had several inquiries from people regarding the “Dirty Dozen” list, so I thought this was the perfect time to organize the evidence-based data on this topic. To see a prior post on this topic, you should also check out Jeff Gillman’s post on the Dirty Dozen from 2010 and a follow up post from 2011.

Before diving too deeply, I wanted to acknowledge some of the articles and resources that I leaned heavily on while putting this post together. These include an excellent article by University of California Davis Extension Food Toxicologist Dr. Carl Winter on pesticidefacts.org, and an article authored by multiple experts from University of Arkansas Division of Agriculture Research & Extension (Dr. Amanda McWhirt, Dr. Jackie Lee, and Ples Spradley). Since both of these articles are over 5 years old, I have updated some of the information in my post to reflect any changes in the science and methodology since the time their articles were published. I also want to acknowledge that much of the regulatory information that I will be sharing within this post will pertain to agriculture in the United States, and for more detailed information on this topic pertaining to other countries, I strongly encourage you to seek out evidence-based resources and/or reach out to knowledgeable experts.

What is the ‘Dirty Dozen’

Aside from being a great World War II film from the late 1960’s, the term ‘Dirty Dozen’ also refers to a consumer-focused publication put together by an environmental advocacy group based in the United States. The Dirty Dozen is a list of 12 produce items (fruits and veggies) that allegedly contain the highest pesticide residue levels (dubbing them to be the ‘dirtiest’). This list is developed annually by the Environmental Working Group (EWG) with rankings that are based on United States Department of Agriculture’s (USDA) Pesticide Data Program (PDP) report. Although this sounds important and valuable to share with consumers, the information contained in these lists is derived through problematic methodology, disseminated using a lack of complete and evidence-based data, and results in unnecessary fear and uncertainty surrounding the consumption of fruits and vegetables that can have significant negative ramifications for growers and consumers alike.

The EWG’s “Shopper’s Guide to Pesticides in Produce” deters people from buying conventionally grown produce on the “Dirty Dozen” list, encouraging them to only purchase organic versions of these items. This annual guide also contains a “Clean Fifteen” list which includes produce items with the “lowest amounts of pesticide residues”. Neither list goes into detail regarding what these residues actually are, and whether they are even harmful to the consumer, and are therefore continually challenged by many scientists as lacking in scientific credibility.

The 2025 Dirty Dozen list is as follows:

Spinach
Strawberries
Kale, Collard, and Mustard Greens
Grapes
Peaches
Cherries
Nectarines
Pears
Apples
Blackberries
Blueberries
Potatoes

Recently harvested strawberries. Photo: **Gerald Holmes, Strawberry Center, Cal Poly San Luis Obispo, Bugwood.org**

EWG’s Dirty Dozen and Clean Fifteen methodology

Prior to 2025 EWG’s Dirty Dozen list was formulated primarily using percentages of samples with detectible pesticides and the number and amount of pesticides detected (with absolutely no information regarding the relative toxicity of these pesticides). As of this year, they have included the metric “overall toxicity of pesticides on a crop” as part of their screening criteria. Although this is a step in the right direction, it is still arguably incomplete information to share with consumers (especially since the most important component, whether these residue amounts are actually harmful to consumers, is still not addressed by any of their metrics, nor clearly communicated in their publications and marketing). This glaring omission is a big red flag in the credibility of this publication, and one of the main reasons why I have such a problem with it. As many of you avid Garden Professors Blog readers know from the many great science-based posts that have been shared (including Linda’s article on Recognizing Bad Science), we need to look carefully at the information being shared, regardless of the source, and make sure that it is evidence-based, credible, and complete.

Understanding Pesticide Safety

I want to caveat this section by stating that this is covering the science pertaining to pesticides and human health based on the research we have on this topic to date (which is subject to change as more evidence-based information comes to light). The scope of this Blog post does not cover environmental/ecological/economic/etc. impacts of pesticides in general nor the overarching impacts of various types of agriculture and food production systems (both of these are very complex topics which will require much more time and research to cover).

Although the term ‘pesticide’ is synonymously used with insecticides by many, pesticides are actually a broad category that includes all substances used to control or eliminate pests (including weeds, arthropods, vertebrate pests, pathogens, etc.). Therefore herbicides, insecticides, miticides, rodenticides, fungicides, bactericides, etc. all fall within the category of ‘pesticides’. Humans have been using ‘pesticides’ for thousands of years, though much of the innovation in pesticides (especially synthetic formulations) has occurred over the past 100 years. We have also greatly expanded our understanding and implementation of safety protocols and consideration for human and environmental health especially over the past 50 years (since Rachel Carson’s ‘Silent Spring’ and the formation of the U.S. Environmental Protection Agency (EPA) in 1970). Thankfully we have come a long way from the ‘DDT is good for ME-E-E’ era (and still have quite a long way to go). Although we are not perfect, pesticides in general are continuing to become safer and more effective, and products with higher toxicity and non-target effects are continually being phased out in support of better chemistries with fewer human health and environmental impacts (though the latter has much more knowledge gaps than the former, and we still have a LOT more work to do on this front). As we learn more about these products with scientific studies, we continue to update our protocols pertaining to them, though there are still knowledge gaps which continue to be explored by researchers. As Extension and IPM (Integrated Pest Management) professionals, we continue to educate people on the importance of pesticide safety, and urge people to think of the environmental impacts of these products, using them only after other IPM strategies (such as cultural, mechanical, and biological controls) have been unsuccessful. Anyone who uses pesticide products (whether Restricted Use Pesticides applied by Certified Pesticide Applicators and those under their direct supervision, or readily available general use pesticides such as Neem Oil, Insecticidal Soaps, etc.) should do so responsibly and in accordance with the label (the label is the LAW!), only when needed, and minimize negative environmental impacts when possible. The history of pesticides and formation of current regulatory protocols is a fascinating topic that I encourage all of you to read up on if you are interested (and may be an interesting topic for a Blog post in the future).

Home garden pesticides on a retail shelf from 1997. Photo: **Gerald Holmes, Strawberry Center, Cal Poly San Luis Obispo, Bugwood.org**

Now that we have covered pesticide basics, let’s get into pesticides and food safety in Organic and Conventional agriculture. First and foremost, if you are purchasing organic produce, that does not mean it is pesticide-free. In the United States, Certified Organic produce refers to food items that are grown utilizing a specific set of principles governed by the National Organic Program. Furthermore, there could be several conventional operations that still follow some of these principles, though may not be Certified Organic. An organic pesticide is basically a pesticide that is approved by the USDA for use in organic agriculture. Although pesticides used in organic agriculture are usually naturally derived, there are also synthetic pesticides that meet the criteria and are allowed in organic agriculture (just as there may be organic pesticides used in conventional agriculture). All pesticides utilized in the U.S. (with the exception of minimum risk pesticides) are registered with and regulated by the EPA. Any of the aforementioned pesticides that are used and sold within the U.S. have rigorous testing surrounding their safety for humans (and maximum allowable concentrations which are set at levels significantly below [10-1000 times lower] those that caused no adverse effects during testing), labeled according to these appropriate evidence-based safety guidelines, and off-label use is prohibited, routinely investigated, and enforced. Regardless of organic/conventional designation: just because something is naturally derived does not mean that it is safer than synthetically derived products. There are many natural substances that are extremely toxic (eg. Botulinum toxin, Ricin, Cyanide, Arsenic, Asbestos, etc.) and many synthetic ones that are relatively benign in comparison. In summary: Organic does not mean pesticide free, and natural/naturally derived does not mean safe.

For any of us that have taken a toxicology class, one of the most memorable take home messages was “The dose makes the poison”. Credited to a Swiss physician named Paracelsus in 1538, this statement applies to any chemicals (including water, salt, oxygen, caffeine, Aspirin, etc.) that are consumed or absorbed by us, forming the foundation of health and safety guidelines that determine the maximum allowable concentrations (tolerance levels) of these substances in our food, water, and the environment.

One of the most useful and illuminating courses I have ever taken in my career was Environmental Risk Assessment, which covered important topics including toxicology, pesticide risks, and invasive species (among other concepts). This course also detailed how Risk Assessments are conducted, the rigorous regulatory processes and evaluations required before products are even available for use, and the evidence-based tools used to determine whether a substance is hazardous and at what level (dose). A great summary of the Risk Analyses pertaining to pesticides and food safety have been summarized by Alejandro Fernández, Agronomist and Director of Hygiene and Safety of Products of Plant Origin SENASA (Argentine Food Safety and Quality Service), on the Pesticide Facts website (link in resources). These Risk Assessments and Analyses are the foundation of how we go about making determinations regarding any substances that we may be exposed to (including food and medicine).

The Issues with the ‘Dirty Dozen’

One of the biggest issues with the Dirty Dozen list is the fact that they do not communicate what having the highest (and lowest) pesticide residue levels even means. They do not conduct an accurate Risk Assessment to be able to support their message for avoiding conventional produce on this list. Although they do talk about the hazards (substances that have a potential to cause harm to us), they omit the crucial component of actual risk (likelihood of that substance causing harm to us), which incorporates another critical component of Risk Assessments: Exposure (how much of the hazard we are exposed to over a given period of time). If we looked at actual risk from the residues (incorporating hazard and exposure) we would find that the residues found on these produce items on the Dirty Dozen list are extremely low, and far below the threshold of having any risk associated with them, especially if we account for exposure (how many we consume on a daily basis, and over an extended period of time). A peer-reviewed Risk Assessment on pesticide residues published in the Journal of Toxicology by Winter and Katz (2011) in response to EWG’s 2010 Dirty Dozen list found just that (link in resources). Their conclusions were: (1) exposures to commonly detected pesticides in the 12 Dirty Dozen commodities had negligible risks for consumers, (2) substituting organic commodities for these conventionally grown ones did not result in any significant reduction of risk, (3) the EWG methodology for determining risk of these 12 products lacks scientific credibility (Winter and Katz, 2011).

Based on this cool pesticide residue calculator (link in resources), a woman of average height and weight could consume 774 servings of spinach or 453 servings of strawberries (the #1 and #2 produce items on the Dirty Dozen list) in a day without any effects. This calculator utilizes the highest possible amount of pesticide residue recorded by the USDA in these produce items, and not the average amount. Now I don’t know about you, but I would personally struggle to consume even 10 cups of strawberries in a day (every day), let alone over 450 cups. This is a great illustration of how dose/risk works, and why these produce items are considered safe for human consumption in conventional agriculture.

Pesticide residue calculator results. https://www.safefruitsandveggies.com/pesticide-residue-calculator/

In summary: the EWG fails to mention that these residue levels are still safe, and far below the thresholds that can begin to have an impact on the consumer. This can have negative ramifications for farmers that grow the produce on these lists, especially if they grow conventionally as opposed to organically. Concerns that people may opt to avoid conventionally grown produce, or avoid those specific produce items altogether is an added hurdle for growers to worry about. Both conventional and organic farmers care about what they produce, and also want our food to be safe (for their families and ours). Our regulatory processes further monitor this safety in both conventional and organic production systems, and as the science is updated, so are these processes. Although many lack access to this, if you have access: reach out to local growers and get to know what their practices are to get a better understanding, and support local farmers when possible.

Furthermore, marketing and messaging like EWG’s Dirty Dozen list discourages people from consuming certain produce, and with only 1 in 10 Americans eating enough fruits and vegetables in their diet, the cons far outweigh the pros for this messaging. An article from the Alliance of Food and Farming details some of these negative impacts (see Resources). This type of fear-mongering disproportionately impacts consumers in lower income brackets, and those that lack access to certain produce. A 2016 consumer survey showed 15% of lower income shoppers surveyed would opt to eat less fruits and vegetables after hearing about the ‘Dirty Dozen’ (Huang et al., 2016).

The take home message should be: the produce that you purchase, whether conventional or organic, is safe to be consumed (and backed by rigorous testing that determines this). Do not be deterred from eating the produce of your choice. Choose produce that is enjoyable, affordable, and accessible to you. And whether conventional, organic, or home-grown: eat more fruits and veggies!

Delicious strawberries. Photo: **Gerald Holmes, Strawberry Center, Cal Poly San Luis Obispo, Bugwood.org**

Resources:

Pesticide Facts: ‘Dirty Dozen’ List Contaminated with Non-Science:
https://pesticidefacts.org/perspectives/dirty-dozen-list-contaminated-with-non-science/

What is the “Dirty Dozen” list and should you be worried about it:
https://www.uaex.uada.edu/farm-ranch/crops-commercial-horticulture/horticulture/ar-fruit-veg-nut-update-blog/posts/dirtydozen.aspx

Organic vs. Conventional Pesticides:
https://www.pubs.ext.vt.edu/ENTO/ENTO-384/ENTO-384.html

Pesticide Facts: Pesticide Risk Analysis Ensures Food Safety:
https://pesticidefacts.org/perspectives/risk-analysis-ensures-food-safety/

USDA PDP Report (2024):
https://www.ams.usda.gov/sites/default/files/media/PDPLABOPSOP.pdf

Pesticide Residue Calculator:
https://www.safefruitsandveggies.com/pesticide-residue-calculator/

Alliance for Food and Farming: Consumer Impacts
https://foodandfarming.info/alliance-for-food-and-farming-dirty-dozen-list-scientifically-unsupportable-hurts-consumers/

Washing fresh fruits and vegetables safely:
https://extension.umn.edu/preserving-and-preparing/wash-fresh-fruits-and-vegetables

Carl K. Winter and Josh M. Katz, 2011. Dietary exposure to pesticide residues from commodities alleged to contain the highest contamination levels. Journal of Toxicology, Article ID 589674, doi:10.1155/2011/589674.
https://pmc.ncbi.nlm.nih.gov/articles/PMC3135239/

Yancui Huang, Indika Edirisinghe, and Britt M. Burton-Freeman, 2016. Low-income shoppers and fruit and vegetables: What do they think? Nutrition Today 51(5): 242-250.
https://journals.lww.com/nutritiontodayonline/fulltext/2016/09000/low_income_shoppers_and_fruit_and_vegetables__what.6.aspx

The complicated issue of heavy metals in residential soils. Part 3: How can we garden safely in the presence of heavy metals?

This is the last part of our discussion on gardening in soils that contain heavy metals (you can catch up on part 1 and part 2 if you need to). Today we’ll focus on the strategies you can use in your gardens and landscapes to reduce your exposure to soil-borne heavy metals.

Raised beds can be an easy solution for gardeners with contaminated soils

Test your soil!

First – and this should really go without saying – you must test your soil to determine if it contains heavy metals of concern. The COVID19 pandemic provides the perfect comparison: you can’t assume you don’t have the virus just because you don’t have symptoms, and you can’t assume your soil doesn’t have toxic heavy metals just because you don’t think it does. The only way to know for sure, in either case, is through testing.

This eyesore did more than spoil the view.

Most soil tests routinely report aluminum, lead, zinc, and aluminum. Other metals, such as arsenic, cadmium, and chromium, may not be part of a basic soil test and you will need to request additional tests if these metals are likely to be present. Often, county health offices will provide free soil testing if you live in a region where there are known contaminants. For example, I live in the Tacoma area where large amounts of arsenic were deposited for decades downwind of an aluminum smelter. Residents of Pierce County can get free soil testing because of the potential danger.

The aluminum is higher than we would like to see, though everything else looks fine.

Even if you don’t live in an area where industrial or agricultural activity may have added toxic heavy metals to your soils, your soil may naturally contain high levels of some metal of concern. As I’ve mentioned in a previous post, our soils have high levels of aluminum. Because we are not downwind of the smelter site mentioned above, I would not have assumed we had any metals of concern, given the rural location of our land, but knowing this informs my choice of vegetables to plant.

The demolition of the Tacoma smelter. Finally.

Avoid adding more heavy metals

Fortunately, many of the consumer products that contained heavy metals are now gone and no longer will add to existing levels of soil metals. But there are still sources out there that gardeners are well-advised to avoid.

Older treated timbers. As mentioned in my first post, landscape timbers were once treated with a chemical preservative containing arsenic and chromium. Even though gardeners love reusing materials (we are a thrifty bunch!), these older timbers should be removed if they are still on your property. New timbers are treated with a copper-based solution, which is a more environmentally friendly preservative.
Kelp-based fertilizers and amendments. While these products are wildly popular with gardeners, they aren’t very effective fertilizers. Moreover, some kelp species accumulate heavy metals, like arsenic, in seawater and these metals will become a permanent part of your soils. Take a look at this fact sheet for more information.
Recycled rubber mulch. This product should be avoided for many reasons (you can read more about the problems in this fact sheet). As it disintegrates it releases high levels of zinc into the soil. And while zinc is an essential micronutrient in plants (and people!), high levels are toxic.
Unregulated composts and organic products. Certified composts and other organic products have been tested for pesticide residues and heavy metals: unregulated products have not. Unless you are making your own compost from materials you know to be free from contamination, your safest bet is to purchase certified products.

If you have materials like old timbers, you should never burn them or throw them away. They need to be disposed of as a hazardous waste, much like old cans of paint, mercury-containing thermometers, etc. Eventually, we may be able to use these hazardous discards for biofuel production through pyrolysis, or extract the heavy metals from them for reuse. For now, just dispose of them in a legal and environmentally responsible way.

Cedar is naturally decay-resistant and can be a good choice for rasied beds

Suggestions for safe gardening

If soil testing reveals high levels of metals of concern, there are work-arounds to allow you to still enjoy growing vegetables safely. If your soil tests reveal that your soil is safe for growing edibles, congratulations! You may still benefit from some of the suggestions below.

Cover exposed soil with ground covers and mulches (coarse organic or inorganic materials) to eliminate metal-laden dust.
Create raised beds for edibles using untreated wood or other metal-free materials. Line the bottom of the bed with an impermeable membrane to prevent movement of soil-borne metals into the beds.
If raised beds are not possible, use large containers to grow edibles.
Avoid using galvanized tubs, as they will leach zinc (and sometimes chromium) into the soil.
Fill beds and containers with clean (i.e., tested) soils or potting media.
Don’t plant vegetables near roadways, which are a source of airborne lead.

Have I mentioned how great arborist wood chips can be in gardens?

Smashing Pumpkin Myths: Bleaching to extend shelf (and porch) life

Scrolling through social media in September and October and you may see those basic signs of the season: scarves, pumpkin spice lattes, sweaters, and Halloween ideas galore. One of those Halloween ideas is to extend the life of your pumpkins, carved or otherwise, by giving them a treatment with household bleach. Keep scrolling and you might see another post decrying the use of bleach as inhumane and poisoning for wildlife. So which is it? Is bleach safe to use as a sanitizer on your jack-o’-lantern or are you poisoning the neighborhood squirrels? Let’s use our gourd to explore the science.

The bleach acts as a sanitizer, neutralizing fungi and bacteria on the surfaces of the pumpkin that will cause decomposition and rot. Even un-carved pumpkins will eventually succumb to degradation under the right conditions. But if bleach kills fungi and bacteria, will it kill wildlife? The answer is – not if it is used correctly. Bleach, and sodium hypochlorite (the active chemical in bleach) are toxic if consumed directly in concentrated amounts, however, dilute solutions break down quickly in the environment. Products containing sodium hypochlorite, including plain household bleach, are actually approved and labeled for use as a sanitizer by produce farmers to reduce both human pathogens and decomposition microorganisms and extend the shelf life of produce that finds its way to the grocery store, farmers market, and any other avenue from the farmer to the consumer. These wash water sanitizers are used more for reducing cross contamination of from pathogens introduced to the water from dirty produce, but it can reduce the microorganism load on produce items. If used correctly to sanitize the surface of the pumpkins, bleach DOES NOT pose an increased risk to wildlife (or human) health.

What is the proper way to use bleach in sanitizing that pumpkin so that it doesn’t face an early demise?

1) Make sure the pumpkin is clean by washing with plain water or a mild detergent to remove any soil or debris. Sanitizers like bleach are quickly neutralized (used up) on dirty surfaces (this is a good lesson for home cleaning, too – you cannot sanitize a dirty surface).

2) Prepare a DILUTE solution of plain household bleach (unscented, and not “splashless”). The recommended concentration is 200ppm sodium hypochlorite, which you can achieve with 1 Tablespoon of bleach per gallon of water.

3) Apply the solution to the pumpkin using a spray bottle. Alternatively, you can prepare enough solution to dunk the pumpkin(s) and immerse them in the solution. If you are sanitizing a carved pumpkin, I would opt for the spray method – dunking may result in infiltration of the solution in to the exposed flesh. It will still break down since it is a dilute solution, but it will slow down the process since it protects the bleach atoms from air and sun exposure.

4) Allow the pumpkin to air dry. Sanitation is not immediate (keep that in mind for sanitizing surfaces in the home, as well) and wiping can cause cross contamination

If I can do this with a pumpkin, should I be doing this with my other produce?

The short answer is NO. It is not recommended that home grown or purchased produce be washed with any sort of detergent or chemical in the water. Fresh cold water and friction should be sufficient for removing soil and pathogens on the surface. Proper protocols, equipment, and training are needed to make sure sanitation is done properly. Knowing which produce items can and cannot be washed with a sanitizer is important. However, if you are harvesting produce like pumpkins or winter squash for long-term storage you may want to consider sanitation using the above methods.

I don’t want to use bleach, can I use something like vinegar?

There are many sanitizers approved for use by produce growers for sanitation, so bleach is not the only option. For home consumers there aren’t so many options. Vinegar is often mentioned as a wash for produce. I found no direct mention in produce handling guides of using vinegar on pumpkin, but most produce wash solutions use vinegar at a much higher concentration because it is much less effective at sanitation. I found rates ranging from 1/3 c vinegar to 1 c water to 100% undiluted household vinegar for use as a produce wash.

Sources:

Sanitizers Labeled for Use on Produce (Produce Safety Alliance)

Produce Wash Water Sanitizers (UMN)

Guidelines for the use of chlorine bleach as a sanitizer in food processing operations (OSU)

The Scoop on Poop: Manure in the Vegetable Garden (and potential food safety risks)

“Can I use manure to fertilize my garden?” That’s a common question we get in Extension and on the Garden Professors page. The answer is absolutely, but there’s a “but” that should follow that answer that not everyone shares. And that is…but for fruits and vegetable gardens the manure you apply could be a potential source of human pathogens that could make you or your family sick. There are procedures and waiting periods you should follow to reduce the potential risk to human health from pathogens in manure and other animal products.”

Why manure?

First, application of manures to garden and farm production spaces is a good use of nutrients and provides a way to manage those nutrients to the benefit of growers and the environment. Using the concentrated nutrients in the manures to grow crops reduces what washed downstream in the form of pollution. In addition to adding nutrients to the soil, application of manure and other animal byproducts (bone meal and blood meal, for example) add organic matter to the soil, which improves soil texture, nutrient retention and release, and supports beneficial microorganisms.

Typical N-P-K composition for some manures and composts. Source: UC Davis

For organic production, both in home gardens and on farms (certified organic or not), manure and animal products are an important input for fertility. For the most part, manures offer a more concentrated (higher percentage) of nutrients by weight than composts composed only of plant residues, so less is usually needed (by weight) than plant composts to apply the same amount of nutrients.

While the nutrient levels of manures and composts can be highly variable, there are some general ranges that you can use to plan your application based on the needs you find in your soil test. (And you should be doing a soil test, rather than just applying manure or compost willy-nilly. Just because the nutrient concentrations are lower than a bag of 10-10-10, you can still over-apply nutrients with composts and manures).

So what are the hazards?

As you’ve probably realized from bathroom signs and handwashing campaigns, fecal material can carry a number of different human pathogens such as E. coli and Salmonella. The major risk around application of manures to edible crops is the possible cross-contamination of the crop with those pathogens. The number one hazard leading to foodborne illness from fresh produce is the application of organic fertilizers – mainly manure, but also those other byproducts like blood meal and bone meal. Add in the fact that the consumption of raw fruits and vegetables has increased over the last decade or more, and you’ll soon understand why Farmers who grow edible crops must follow certain guidelines outlined in the Food Safety Modernization Act (FSMA, which you’ll hear pronounced to as fizz-mah) to reduce the potential risk that these pathogens pose to people who eat the crops. Right now, only farms with a large volume of sales are required to follow the guidelines, but smaller producers are encouraged to follow them as best practice to reduce risk and liability. And while there isn’t a requirement for home gardeners to follow the guidelines, it is a good idea to understand the risks and incorporate the guidelines as best practice. It is especially a good idea if the produce is being eaten by individuals who are at higher risk of foodborne illness – young children, the elderly, or those who are immunocomprimised.

The recommendations are also suggested when there’s contamination from unexpected or unknown sources like when vegetable gardens are flooded (click here for a recent article I wrote to distribute after the flooding in Nebraska and other midwestern states).

Recommendations to reduce risk

As previously stated, while these recommendations have been developed for produce farmers, research showing the potential hazards of applying manures means that it is a good idea for home gardeners to understand and reduce risks from their own home gardens.

The set of guidelines outlined by FSMA cover what are called Biological Soil Amendments of Animal Origin (BSAAO – since we government types love our acronyms). Here’s the “official definitions” used in the rules for produce farming:

A Biological Soil Amendment is “any soil amendment containing biological materials such as stabilized compost, manure, non-fecal animal byproducts, peat moss, pre-consumer vegetative waste, sewage sludge biosolids, table waste, agricultural tea, or yard trimmings, alone or in combination”.

A Biological Soil Amendment of Animal Origin is “untreated: cattle manure; poultry litter; swine slurry; or horse manure.”

Image result for manure — Now that’s a pile of crap!

For BSAAO (we’ll call it raw manure), manure should only be applied to the soil and care should be taken not to get it on the plants. There’s also a waiting period between applying the manure and when you should harvest the crop. The length of the waiting period depends on whether the edible part of the crop comes in direct contact with the soil. Right now the USDA is still researching the appropriate waiting period between application and harvest, so the general recommendation until then is to follow the standards laid out in the National Organic Program (NOP) standards. Research shows that while pathogens may break down when exposed to the elements like sun and rain, they can persist for a long time especially in the soil.

For now, here are the recommendations:

For crops that contact the soil, like leafy greens (ex: lettuce, spinach, squash, cucumbers, strawberries) the suggested minimum waiting period between manure application and harvest is 120 days.

For crops that do not contact the soil (ex: staked tomatoes, eggplant, corn) the suggested minimum waiting period between manure application and harvest is 90 days.

For farmers following FSMA, the waiting periods could change when the final rule is released – some early thoughts are that it could increase to 9 – 12 months if the research shows a longer period is needed.

What about composted manure? Is it safe? The guidelines indicate that there isn’t a waiting period between application of manure that has been “processed to completion to adequately reduce microorganisms of public health significance.” But what does that mean? The guidelines lay out that for open pile or windrow composting the compost must be maintained between 131°F and 170°F for a minimum of 15 days, must be turned at least 5 times in that period, must be cured for a minimum of 45 days, and must be kept in a location where it can’t be contaminated with pathogens again (animal droppings, etc). Farmers have the added step of monitoring and thoroughly documenting all of the steps and temperatures. Now we know that that’s a bit of overkill for home gardeners, but suffice it to say that the cow manure that’s been piled up to age for a few years that you got from the farm down the road doesn’t meet that standard.

Image result for compost — Failure to maintain proper temperature on composted manure could mean that your goose is cooked, though this thermometer doesn’t have that setting.

“Aged” manure ≠ “processed to completion to adequately reduce microorganisms of public health significance.” So unless you know for sure that you’ve reached and sustained the appropriate temperatures in your compost, you should assume that it would be considered a BSAAO subject to the 90/120 waiting period. Bagged manure you buy at the garden center is likely to be composted “to completion” or may even have other steps to reduce pathogens like pasteurization. Sometimes the label will indicate what steps have been taken to reduce pathogens, or even state that it has been tested for pathogens.

The recommendations also specifically mention compost teas and leachates (a topic we handle with much frequency and derision here at the GPs, since there’s not much science to back up their use and I mention here with much trepidation). For the sake of food safety, any tea or leachate should only be applied to the soil, not the plant. And for home compost that doesn’t even contain animal manure the 90/120 day waiting period should still be observed in most cases since some of what goes into home compost is post-consumer. Since we put pieces of produce in there that we’ve bitten from or chewed on (post-consumer), plus some animal origin items (eggshells) there’s the potential that we could contaminate the compost with our own pathogens – and the environment is perfect for them to multiply.

The Bottom Line

While these guidelines and rules for farmers may just be best practice recommendations that we can pass on to home gardeners, common sense tells us that taking precautions when applying potential pathogens to our edible gardens. An ounce of prevention is worth a pound of cure, especially when were talking about poop.

Sources/Resources:

Produce Safety Alliance producer training materials
National Good Agricultural Practices Program: Soil Amendments (Cornell)
Biological Soil Amendments of Animal Origin (FDA Fact Sheet)
FSMA Final Rule on Produce Safety (FDA)
Manure in Organic Production Systems (ATTRA)