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November 9, 2017

REBUTTAL: Recycling Food into Fertilizer Registered for Use in Organic Agriculture

By Dan Morash Founder, California Safe Soil


We read with interest the July/August 2017 Western Growers article entitled: “Cause for Concern Over Organic Fertilizer Made from Food Waste?” by Stephen Meyer & Thomas Marrs of the Downey Brand law firm.  The article raises concerns for organic growers that may currently be using, or considering use of, registered organic fertilizer manufactured from recycled food. We think those concerns are unfounded. California Safe Soil, LLC (“CSS”) appreciates the opportunity to offer our point of view.

CSS was founded in 2012 to commercialize its patented technology to recycle food into fertilizer in only three hours, using enzymatic digestion. We located a pilot plant in West Sacramento, to pursue research with agronomic experts at UC Davis; interact with regulatory bodies in Sacramento; and establish relationships with specialty crop growers in California. By 2015, we had achieved promising research results; cleared all the regulatory hurdles; and were selling everything we could produce at the pilot plant. We had completed a published “challenge test” with experts at UC Davis, affirmatively proving that our process eliminates pathogens. This study became the basis for our permanent license from the California Department of Food and Agriculture (CDFA). We also obtained approval from the Washington State Department of Food and Agriculture (WSDA) to register our organic product, Harvest to Harvest Organic (H2H Organic), for use in organic agriculture. H2H Organic was also accepted for registration by CDFA. We reached food recycling agreements with Save Mart Supermarkets, Nugget Markets, and Sacramento’s Golden 1 Center. We joined Western Growers in 2014, received the 2015 Thrive-SVG Accelerator “Most Sustainable Technology” award at the Forbes AgTech Summit, and became a charter member of the Western Growers Center for Innovation and Technology in 2015. On the strength of these results, in 2016, we financed and constructed our first commercial scale plant in McClellan, California, which we have successfully operated ever since.

Meyer & Marrs call out CSS by name and warn that “food producers should use caution before buying organic fertilizer made from food waste,” based on the following arguments:

1. In 2016, a court invalidated National Organic Program (NOP) guidance 5016 allowing green waste compost because “composters cannot always control their green waste feedstock.”

2. Anaerobic digestion, a technology designed to produce energy from waste, has many synthetic contaminants, like cans, bottles and plastic bags; “most products derived from anaerobic digestion do not meet NOP’s criteria [for use in organic agriculture].”

3. Processed food, like butter, cereals, snack foods and beer, contain synthetic preservatives, like BHA and BHT.

4. Anaerobic digestion doesn’t mineralize synthetics, and may harbor pathogens like E. coli.


Our corresponding responses are:

1. We collect food previously offered for sale to the public after it has been culled for freshness by store staff. These are primarily fruits and vegetables, meat, fish, prepared foods and fresh bakery. This feedstock has been shown to contain no measurable levels of pesticides, especially considering it was offered to consumers immediately prior to culling.

2. Anaerobic digestion (AD) is primarily an energy technology. The CSS technology is enzymatic digestion (using food grade enzymes registered for use in organic agriculture). None of the comments about AD are relevant to the CSS technology.

3. We recycle the perishable food, like fruits and vegetables from the produce aisle. For a variety of reasons, processed foods containing BHA and BHT are typically not what we recycle.

4. As mentioned above, our process creates a pathogen free product and in the studies we have done at the request of organic producers there are no detectable pesticide residues.


H2H Organic was subject to exhaustive review by WSDA and CDFA for compliance with NOP standards before the product was successfully registered and approved for use in organic agriculture. It is erroneous to suggest this product may not fit organic systems.

The organic produce market continues to grow at a double digit rate, creating a great opportunity for members of Western Growers. Amazon’s acquisition of Whole Foods will only accelerate the trend.  Existing organic fertilizers, like fish fertilizer and other organic wastes, have a limited capacity to meet that need. Recycling food, in one form or another, is as old as agriculture. Today is the anomaly, with up to 40 percent of food production going to waste. Recycling food that would otherwise be wasted is an enormous resource that can fill the gap, and maintain competitive supply conditions for organic growers. We have done the research, met the regulatory requirements, and produce an effective, high quality, consistent product at a competitive price, to meet growing market needs. CSS is committed to providing the transparency in organic food production that growers and consumers demand and deserve.