CCOF Member’s Views on Whole Foods Market Responsibly Grown Rating System

In May of this year, a group of five certified organic fruit and vegetable farmers, whose combined careers represent 147 years’ experience in biological agriculture, approached the nation’s largest USDA National Organic Program (NOP) certifier, CCOF (California Certified Organic Farmers), for help in defending our certified organic label’s value in a volatile marketplace. 
This appeal was prompted by a recent rollout in 400 Whole Foods Market (WFM) stores. The nation’s iconic retailer of certified organic produce developed a proprietary fruit, vegetable, and flower rating system, known as Responsibly Grown. The stated purpose of this initiative—to examine and rate conventional and certified organic WFM produce suppliers on parameters of soil health, pesticide use, food safety, labor practices, greenhouse gases, water conservation, waste reduction, and recycling—is one that all farmers should welcome. In good faith, many certified organic farmers participated in Responsibly Grown’s detailed, time-consuming, and expensive application process, hoping to receive distinction for sustainable practices beyond their organic production system’s heralded renunciation of toxic and synthetic inputs. 
In the fall of 2014, when Responsibly Grown was rolled out in stores across the nation, some of these same certified organic growers were shocked to learn that their farms had won “Good” or “Better” ratings, when a number of conventional farms, who pledged to abstain from a short list of WFM prohibited pesticides, were being awarded “Best” distinctions. 
In early May, five farmers initiated private communications with key WFM personnel, delivering recommendations for changes to the Responsibly Grown program. On May 15, the CCOF Board of Directors expressed support for these farmers’ concerns with Responsibly Grown and directed CCOF’s executive director to initiate a dialogue with WFM executives to address the several issues those farmers raised.     
Over a month before this dialogue was initiated, the simmering controversy was covered by the New York Times, National Public Radio, and assorted media outlets. The five farmers also presented a public letter to WFM Co-CEO John Mackey outlining their objections to the high cost, excessive time demand, and devaluation of pesticide use standards in Responsibly Grown’s rating outcomes. 
An amicable dialogue amongst WFM, CCOF, and the five farmers commenced on June 18 and continued over several weeks. Key, immediately effective agreements were reached and a commitment to further collaborate on additional modifications to Responsibly Grown over the remainder of this year has been secured. 
As one result of these agreements, effective immediately, certified organic growers are free to postpone application to Responsibly Grown until January 1, 2016. If a certified organic grower has already applied, continued efforts towards compliance may be suspended until January 1, 2016. Furthermore, as of July 2015, produce from certified organic farms which have not completed or initiated Responsibly Grown applications will no longer be displayed as “Unrated” in WFM stores, but will henceforth be automatically awarded “Good” ratings (until January 1, 2016).  
WFM, CCOF, and farmers have agreed to discuss over the next several months restricting additional pesticides that are allowed in Responsibly Grown’s “Best” category to greatly reduce or eliminate the number of conventional farms awarded this status. We will examine the overlaps between USDA-NOP law that governs the practice of certified organic farmers and similar requirements in WFM’s Responsibly Grown program and to determine how many additional points can be automatically awarded certified organic growers without unnecessary duplication of effort or documentation. 
Consideration will be given to the replacement of comparatively judgmental “Good,” “Better,” “Best” designations by a simple numerical score, amongst other alternatives that more effectively recognize the signature achievement of certified organic in dramatically reducing pesticide residues on fruits and vegetables. Furthermore, discussions will be held with a view to reducing paperwork and monetary costs to smaller-scale certified organic growers entering the program (who already incur significant costs and paperwork to achieve USDA organic certification), and to establishing a systematic means to verify all Responsibly Grown supplier claims. 
WFM has also expressed a willingness to seek international accreditation for their Responsibly Grown rating system. 
Small-scale certified organic suppliers who were not effectively communicated with during WFM’s three-year Responsibly Grown planning process, which began in 2012, look forward to a series of grower meetings the grocer has promised to host this fall in major production regions to solicit farmer input.            
Whole Foods Market, distinguished as the first national grocer to have its retail operations awarded certified organic status, enjoys supplier relationships with many of CCOF’s organic farmer members, associations that often exceed a quarter-century or more. WFM is itself USDA certified organic by CCOF, and a recognized, valued member of our CCOF family. As fellow members of the greater organic community, we dedicate ourselves to passing on singular achievements in improving the quality and safety of the food Americans eat, however modest those might be, to a new generation of farmers who must accomplish much more in the next generation than we have in ours.
This article was written by Tom Willey.
Tom Willey, with his wife Denesse, has operated T&D Willey Farms since 1981, a seventy five acre CCOF Certified Organic (since 1987) farm in Madera, California growing a wide array of Mediterranean vegetables the year round. Willey Farms produce is appreciated in specialty markets and fine restaurants up and down the U.S. West Coast as well as, until recently, on the tables of over 800 weekly Community Supported Agriculture (CSA) subscription members in their own community. T&D Willey Farms CSA has been acquired by The Food Commons. T&D Willey farms has supplied Whole Foods Market with certified organic produce for some 25 years. Tom was, until recently, Slow Food USA's governor for California's Central Valley and passionately advocates for local food prominence through his writing, speaking, radio and event organizing activities. His monthly Down on the Farm radio interview program features the work of progressive farmers and others prominent in San Joaquin Valley's agriculture and food communities. Tom has served over the years on the boards of directors of the Ecological Farming Association (EFA) and California Certified Organic Farmers (CCOF). He currently serves as a Policy Advisor to The Cornucopia Institute which monitors integrity of the U.S. organic industry.