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(fwd) Organic food standard is flawed, public comment needed
On Sun, 28 May 2000 18:04:47 GMT, in alt.permaculture
While the new USDA organic standard is a significant improvement over
original disastrous proposal, there are some remaining problems that
citizen input to get fixed.
Problem: Higher standards may not be allowed.
Solution: Tell USDA that 205.501(b)(2) and 205.501(a)(12) should be
explicitly state that the federal organic standard only specifies the
requirements that must be adhered to, not the maximum, and certifiers
only allowed but encouraged to implement and enforce stronger
without permission from government and regardless of whether others do
We need to leave the door open to continual innovation and a free
superior standards above the federal floor to make progress toward
sustainability. Also, we don't know what a future administration may
do to the
federal standard; if it is lowered, certifiers must be able to
existing level of quality.
Problem: Growers may use certain forms of sewage sludge even though it
contains heavy metals and other toxins.
Solution: Tell USDA that 205.2 should be changed to prohibit any form
sludge, and that sewage sludge should be defined as synthetic so that
National Organic Standards Board (NOSB) and the public will have legal
to analyze any proposals to change the sewage sludge prohibition in
otherwise changes could be quietly slipped in later.
Problem: Use of certain types of genetic engineering is in limbo, and
quietly slipped in later without public oversight.
Solution: Tell USDA that 205.2 should be changed to restore the NOSB
of genetic engineering, including their full list of "excluded
to specify that all forms of genetic engineering are synthetic, so
that the NOSB
and the public have legal authority to be involved in any changes,
weakening changes could be sneaked in later.
Problem: The proposed rule holds organic farmers responsible for the
actions of others and fails to address the economic consequences of
pollution, chemical drift, and mandatory spray programs.
Solution: Tell USDA to guarantee that all damage from genetically
and pesticide products, including genetic pollution damage to organic
is fully compensated by those making and using them, not by organic
by the public. This requires that all users of genetically engineered
post a bond to ensure the money is there, and provide public
their use so the locations of potential genetic pollution sources are
farmers in the area. Genetic pollution is especially serious since
genes can cause an irreversible, continually growing problem over
chemical pollution fades away over time.
Problem: Food handlers are allowed to use toxic pesticides if they
organic methods are "not effective", while still calling it "organic".
Solution: Tell USDA that 205.271(c) should be changed to
prohibit any use of a synthetic substance not approved for organic
Problem: Irradiation is not defined and could be slipped in later.
Solution: Tell USDA that 205.2 should be changed to define irradiation
include all techniques using ionizing radiation, and that irradiation
be defined as synthetic so that the NOSB and the public will have
power over any attempts to weaken the prohibition in the future.
Problem: The fee structures are burdensome for small farmers.
Solution: Tell USDA that the costs of the organic program should not
be borne by
organic farmers but by those involved in destructive practices such as
toxics, soil erosion, etc. People should not be penalized for doing
thing by moving away from practices that can undermine the long-term
Problem: USDA may get pressure to undo the things they got right.
Solution: Tell USDA to refuse to weaken the standard's good provisions
Ecolabels allowed; Certifier ability to de-certify; 100% organic feed
with no antibiotics or animal parts; Detailed percentage labeling,
100% organic; NOSB's authority under the law for the National List;
accrediter, not certifier; Flexible organic plan format; Commitment to
costs on the first round; No antibiotics allowed either in animal feed
fruit production; Includes mediation in the appeals process; and
resource conservation and a process-based approach.
You can comment in 3 ways (deadline June 12, 2000):
via the Internet at: www.ams.usda.gov/nop/,
by fax to: 703-365-0760,
by postal mail to:
Keith Jones, Program Manager, National Organic Program,
USDA-AMS-TMP-NOP, Room 2945-So, Ag Stop 0275,
P.O. Box 96456, Washington, D.C. 20090-6456.
Whichever way you comment, be sure to refer to Docket Number
For more info and to get involved:
These have more detailed explanations and language you can cut & paste
www.purefood.org/newsletter/biod26.cfm (BioDemocracy News #26 April
BioDemocracy Campaign/Organic Consumers Association
6114 Highway 61, Little Marais, Minnesota 55614
phone: (218) 226-4164, Fax: (218) 226-4157, email:
To subscribe to the free Organic View electronic newsletter, send an
firstname.lastname@example.org with the simple message: subscribe
National Campaign for Sustainable Agriculture
P.O. Box 396, Pine Bush, NY 12566
phone: (914) 744-8448, Fax: (914) 744-8477, email:
The Center for Food Safety
666 Pennsylvania Ave, SE, Suite 302, Washington DC, 20003
Phone: 202-547-9359 Fax: 202-547-9429 E-Mail:
If you're very short on time, download
print it, put your name & address and a stamp on it, and drop it in
delete N0SPAAM to reply by email
Lawrence F. London, Jr. Venaura Farm ICQ#27930345