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By: Kim Flottum

No longer impossible, but it comes down to location, location, location. An exclusive report on this timely, and not-well-known topic.

September 01, 2003


by: Kim Flottum

If I were to ask you to define organic agriculture, you d probably give an acceptable definition, hitting most of the big points, and some of the fuzzier, more esoteric concepts. More than three quarters of us garden to one degree or another, and we all keep bees. Who better to understand the all natural lifestyle, even if we don t practice it religiously?

But now there is an official USDA definition for organic and the difference between what most of us think and what actually is amounts to a stack of paper nearly three feet tall. Though not terribly complex or difficult to understand the detail involved, and the sheer amount of information to absorb can be daunting. This is, we re told, a necessary evil, to maintain the integrity of the term Organic.

Recently, you or someone you know has probably seen a jar of 'Organic Honey' on a shelf somewhere. Can this be? For years when asked if the beekeeping industry could produce organic honey in the U.S., the stock answer has been, 'Define Organic.' Well, now we can define organic honey, and yes, it can be produced in the U.S. More easily, I suspect, than you first imagined, but more difficult, I again suspect, than any of us could imagine.

There are, to produce organic honey, basically four components to the program: 1) where your bees are and where they forage; 2) how you manage them including housing and pest/disease control; 3) how you handle the crop, including harvesting and storage; and, 4) labeling. A fifth component should be added I suppose, and that s the record keeping system you ll need to employ to document absolutely everything you do.

This record keeping, plus your application, and perhaps surprise visits will be duly noted, and judged, and recorded by a certifying agent who works for an organization that has passed USDA muster as being able to determine if your operation meets the requirements for organic production. Currently there are 80 or so certification organizations operating, and another 200 or so are pending approval. This number will surely increase as organic operations of all types increase. But all certifiers are not cleared for certifying all types of organic operations. For instance, certifiers specializing in grain production may not have expertise in evaluating a poultry, or beekeeping operation. Large certifying businesses tend to have most of the skills necessary to certify most types of operations. Those that work most with beekeepers are the livestock people, who operate under those regulations. Your bees, with very few exceptions, are considered livestock, and your operation is evaluated accordingly.

Another consideration is the size of your operation. If you produce less than $5,000.00 per year of organic products (all types, any product), you will come in under the wire for some of the record keeping and certifying requirements and get to use the label. Not many though. And, if you are challenged, you will have to be able to document your operations. Income from non-organic products sold do not contribute to this amount, so you may run a large operation concurrently. But be careful. On average, this total would come from fewer than 20 colonies, producing about 60 pounds of honey apiece. Each pound produced selling for $4.00 (average wholesale and retail price). Production and prices will vary, but this amounts to, at most, only a couple of yards dedicated to this practice. You may, however, engage in producing organic pollen or beeswax (cosmetics cannot be labeled organic, so don t bother trying that). These additional crops may change the equation on colonies operated and total income.

FIRST To begin, you need a plan. A well thought out document that explains in detail how you will attain, and maintain your organic status. If you are careful, and thorough, this excercise will solve many problems before they arise, which is the purpose. For instance, how will you handle Varroa, where will you obtain organically produced wax foundation, and how close is that landfill, somewhere in the next township.

Before you even begin to develop your plan, locate a certifying agent or organication (see the USDA web page at end of this article). They will provide the background and guidance you ll need to produce your plan. The better agents provide a worksheet that takes you through your operation and the season, asking questions along the way. If you can t answer a question, they usually provide help.

You will invest significant dollars in becoming certified - both the fee (which is determined by the size of your operation and the number of crops you are producing), and the investment in changing the way you do things. Don t assume you know it all. You don t.

WHERE THEY FLY Location is going to be the most challenging hurdle for most beekeepers. Your plan requires a map of where your organic honey-producing colonies will reside, and, if you move them mid-season, where then they will sit later. Basically your bees must always have sufficient organic forage. Regulations specify that within the area surrounding your hives - a flexible circle extending about two miles in every direction - your bees must not encounter a whole host of man-made obstacles. These include, but are not limited to urban centers, landfills, cultivated (non-organic) crops routinely fertilized or chemically treated, golf courses and industrial facilities. Genetically modified planting areas must be avoided, and further, they require a significant buffer zone to avoid contamination with wild or organic forage. Roads, large and small municipal boundaries, and water sources are needed too, and don t forget prevailing wind direction and all water sources. These man-made obstacles will need to be identified, but may not, in and of themselves, pose an organic problems. The fundamental guideline is, are your bees foraging on organically grown plants, or wild plants that qualify?

Plants blooming during the season within the area must be indicated on your plan, and government agencies and other owners in charge of the land, plus the acres your bees will cover need to be noted. There s more, so don t skip this very important requirement.

There s no doubt that when you finish this part of your plan you will know more about your honey sources than you probably ever did, and, with a bit of preparation, could begin producing organic varietal honey. Now that would be a premium crop.

Your bees are free to roam on any crops or wild flowers that grow on land that has not had prohibited materials (synthetic fertilizers, herbicides, pesticides or sludge) applied in the previous three years. With few exceptions this excludes pretty much all active farm land, and essentially all urban and suburban areas. Not all, but a lot.

There are great areas of conservation reserve land that meet this requirement in many states. Far more in the Midwest, mountains and west than east of the Mississippi, though. But there are large tracts in the eastern mountainous areas and other spots that fill the bill. Providing that is, you can isolate your bees to those acres. USDA maps are on the web, or check your nearest Extension outlet.

You ll need to prove the status of all the land within your flight circle for your plan - owners or managers - and history, too. You can see that the western slope of the Rockies is probably a better bet than pretty much anywhere in New England, and easier to deal with for records. But don t give up before you look.


WHERE THEY LIVE The boxes your bees live in, should you choose this mission, will be just a little different, too. All natural, for all items in contact with the bees all the time. Using any preservative other than an oil based plant on the outside is out, by the way. Stains and other preservatives can t be used, nor can paraffin dipping. But, organic beeswax dipping would be, if you ve a mind and lots of wax. Frames are wood only, and wax foundation, organic wax foundation, is required. Plastic s out.

The organic wax foundation part of this poses the greatest change. Not available at your nearest Wal-Mart, or even any national bee supply company, you ll need to be creative here. Wired frames with starter strips of home-made organically-produced wax is the way many will start. But where do you get those initial blocks of wax to melt down, roll or pour and then emboss? Molds are available, mostly made in Europe, and a couple roller companies exist in the U.S. An entrepreneur with some marketing savvy and initiative has an opening here, for certain.

The caveat, however, is being able to document the source of the wax (invoices) and making certain that the source was, indeed, operating as a certified organic producer. Someone will ask, and you better have the paperwork. And, there is a whole list of requirements you ll need to meet to insure that organic wax and regular wax don t become co-mingled. (The same holds true for honey produced.) Remember, all this is in your plan.

MANAGEMENT Let s begin at the beginning. Organic bees. Who has organic bees? I don t. Nobody I know does. Yet. But you can produce your own, you know. And, for starters you ll probably have to. The queen s gotta be organically raised, too. Not a lot of those for sale, are there? You ll need to think that one through.

So to begin producing organic honey, you ll need to back up and first produce organic bees to produce the honey. I imagine you ll have to start an organic colony with inorganic (unorganic?) bees, but then manage them organically. Produce a queen(s) from that colony and then introduce her to yet another colony you ve been raising organically, so the two mesh. This seems to be a chicken/egg thing, and though it sounds confusing, it s just time consuming. And a real pain for the paperwork. Don t forget the paperwork that documents all this. Ever.

These initial colonies will probably be used mostly for wax production for additional colonies next season. It seems clear that you ll need to invest a season s preparation to get all this going. Maybe more, maybe less if you don t have long Winters.

o, to move the plot along, let s imagine you have a dozen colonies set up with the right equipment, setting in the right place, living with the right indoor/outdoor furniture, and everybody has been organically produced. And, and, you ve documented it all - i s dotted and t s crossed.

Record keeping gets kicked up a notch now. Every inspection recorded. Every one. Don t forget. What will you find? The same stuff, mostly. The same old problems will appear. Here s the scoop. To stay organic, no drugs. None. So management, specifically integrated pest management will become your best friend. American foulbrood - burn. Just a frame, maybe a super, maybe a hive. NO terra allowed (but see below). European foulbrood and chalk, requeen (yeah, right!), or otherwise reduce stress. Perhaps feed (see below for that item). Grease patties are allowed (the use of these is a bit fuzzy - does the Crisco® need to be organic, since bees don t actually eat the grease?), but sweetener (sugar or honey) needs to be organically produced. Fumigillon isn t allowed either. And certainly not Apistan or Checkmite+. Menthol is, though.

For Varroa there s nothing. Yet. There are, however, as of late July three products on, or near the market that are going to make Varroa control possible. ApiLifeVar has a Section 18 in several states already, with more on the way. I m told every ingredient - menthol, thymol, eucolyptol and camphor - are allowed individually. The newest treatment - Sucrose Octanoate - would also be allowed, as would ApiGard - Thymol - when (and if) it is released in the next year or so. The only hurdle to all of these is that to date they have not been approved to use in an organically run operation. To remove this obstacle, the Eastern Apicultural Society is beginning the petition phase to get these approved. Stay tuned.

All three of these will almost certainly be approved to use in a hive to control Varroa (but, recall only two things are certain). Once that happens, even though all three treatments are labor heavy, maintaining a (nearly) chemical-free, (almost) Varroa-free colony is economically feasible.

But with the chemical mind-set we currently have, alternatives are often given second status. That needs to change. The mechanical methods used need to be explored even further. Screened bottom boards, increased ventilation, and isolation from infected colonies all need to be increased. Certainly, the standards of maintaining healthy colonies need attention - plenty of (organically approved) food and water, protection from the common pests - ants, skunks and other nasties, feeding if necessary (and it will be sometimes) with organic pollen (you collected some last season, right?) and sugar (honey better, and only you have it) to avoid problems . . . all the things you ve been doing for years to reduce stress, and thus disease susceptibility.

A big part of this must be the introduction of stock resistant to the three pests - AFB, Varroa and Tracheal mites. Hygienic, SMR and Russian-stock will blossom, I suspect. And new introductions will have a market if they indeed do what they re supposed to.

There s an additional point that needs to be made, and it s important. You can t let a colony just die. If you have a sick colony, and need to save it in a hurry, you must pull it out of organic production and treat with the traditional chemicals - according to label instructions - and use the honey harvested for other uses. Again, if organically approved methods don t work, you must resort to stronger, more effective measures, regardless of the status of the colony.

I ll bet there s a benefit here that you haven t picked up on. An organically raised queen, and supposedly drones, will not have had the opportunity for any exposure to chemicals during their formative weeks. And later, when you introduce that queen (your own or someone else s) to your hive, she ll be walking into a virtually synthetic-chemical-free environment. This double exposure in the past has been blamed for poor queens, poor drones, and significant supercedure problems. We should see fewer problems along those lines. C.C. Miller would approve of these procedures, I think.

So. You ve got healthy organic bees, living in organic boxes, traveling to organic-only fields and producing organic honey. Getting it is next. Removing involves brushing, escapes or blowing. Repellents aren t allowed (BeeQuick may be the exception here, pending the outcome of their petition to use a certified organic label). But first, let s take a look at where you re taking these frames of honey, and what you ll do with them.

Your extraction environment (I realize most of us don t have dedicated honey houses) needs to be pest free, primarily due to your diligent efforts to keep pests out with barriers and good maintenance. For those that do get in (I m thinking mostly mice here), controls need to be, yes, organic. No poisons, or the like, can be used that will affect the honey. Prevent first, control later if necessary is the word.

Uncapping (cold knives if possible, low heat if not) procedures and machines need to be documented. Everything s stainless of course. Transport (pipes need to be food grade) and heating should be monitored, and documented. Anything over 110°F can t be called raw, and intermediate and storage containers need to be up to snuff - but you were already doing that, right?


If you ve done all of the above successfully, been certified (or are too small to be certified), you can now, officially, label your product '100% Organic.' The USDA has an official logo you can use. You ve done the work, paid the price and sweated the details - get your money s worth.

If you are producing honey only, the '100% Organic' label fits. However, if you are doing flavored, or fruit-added cremed honey, those products must be considered. There is a whole section on labeling in the regulations you ll need to be aware of, and comply with. Read carefully because your label, too, needs to pass muster for the organic people, and the usual state and federal requirements haven t gone away. Moreover, some states have their own organic regulations that will need attention. Some states, too, are the only certifiers, so by dealing with them you should have taken care of everything.

The demand for 'organic' is increasing at an alarming rate. If you can, it s worth the effort.


I started this by describing a stack of paper three feet tall. That much information isn t in this article. I haven t touched the handling, wholesale and retail marketing requirements, the National List of approved chemicals, and a hundred other items. The initial plan you put together, and the documentation required afterwards were strongly mentioned. Not, however, strongly enough. The people who certify you have a standard to uphold, and a boss that makes them tow the line. They will be thorough. You absolutely need to do your homework before you begin this.

An alternative organization exists, realizing that some operations that honestly try to obtain Organic status cannot do so for a variety of reasons. Meant for small farmers distributing through local channels - farmer s markets, roadside stands and the like - this approach reduces the paperwork required, but maintains all the standards of the USDA s program. It is called Certified Naturally Grown, and so far has a foot in the door for recognition. Bee Culture is working with this organization to develop standards that reflect the quality control of USDA, and the reality of a sideline beekeeper s operation and resources. By next season these should be available. In the mean time, check out Naturally Grown at for additional information.

Another topic that may rise to the surface is 'just because we say it s organic, does everybody believe us?' Well, not quite, not yet. Everybody has their own standards, it seems. The EU, Canada, U.S., London, Italy . . . all similar, but all different. Right now, these primarily cultural differences are being ironed out. There may be, one day, a universal standard. Maybe.

What if you flat out lie? You said it was organic, but you mixed in a couple barrels of . . . something else, so you could fill that big order. Well, if you re caught, and you probably will be because of the competitive market this stuff will have, the fine is $10,000. And a bee sting on your nose. Shame on you, anyway.

And finally, there is a group of people who are making all this work for USDA. The National Organic Standards Board officially develops the standards for substances to be used in organic production and advises the Secretary on the implementation of the program.

Chosen for expertise, skills and because they raised their hand, these people deal with stacks of paper yards high. Beekeeping is fortunate in that one of these people is Nancy Ostiguy, from Penn State, familiar to many for her work with Varroa mite control. She was helpful in producing this article by explaining some of the whys and hows.

Producing 'Organic,' or even 'Naturally Produced' honey, pollen or wax isn t going to be for everyone. But it will be a lucrative niche market to exploit for those with the resources and location. But don t discount it before you explore the requirements. You may be surprised.

For all of the information on the USDA National Organic Program, go to Click on agencies, find AMS under Marketing and Regulatory Programs on the right hand side of the screen. There, you ll see National Organic Program. Then sit back, relax and enjoy all the thousands of pages of information that will amaze and delight you.


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