Subject: Some Questions about the Organic Standards (fwd)

From: "Lawrence F. London, Jr." <[email-masked]>
Date: Fri, 6 Feb 1998 21:04:46 -0500 (EST)

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Date: Fri, 6 Feb 1998 02:31:32 -0800 (PST)
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Subject: Some Questions about the Organic Standards

>Date: Wed, 4 Feb 1998 21:36:31 -0800 (PST)
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>Subject: Some Questions about the Organic Standards
>From: Claire Cummings <[email-masked]>
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>>	Some Questions Raised by the Proposed USDA Organic Standards
>>
>>By: Claire Cummings						
>>
>>        Just about everything we care about: our land, air, water, food,
>personal health, social justice, and even democracy, is affected by an
>action currently being taken by the [US] federal government.  For the last
>thirty
>years, the organic farming movement has grown and matured, producing food in
>ways that are more ecologically and socially sound than conventional
>farming. Now, the USDA has proposed regulations for the organic industry
>that would destroy all that we have created.  And the way this was done was
>an undemocratic and unpleasant surprise to those who worked hard to
>formulate acceptable federal standards, not to mention the thousands of
>small farmers who developed the standards and practices that built the
>organic industry, literally from the ground up.
>>
>>        What does the word "organic" mean to you? The new proposed
>regulations would redefine "organic" to include toxic sludge, genetically
>engineered organisms, and irradiated food. By demeaning the term, it would
>effectively prohibit the use of the word "organic" on labels for foods
>produced under stricter guidelines.  The high standards already set in
>California by its organic foods law would be superseded by the new federal
>law. These ecological practices, the health of the land, the hope of the
>consumer are all jeopardized.
>>
>>	The new law changes the qualifiying requirements and raises the costs of
>registering as an organic producer and will put hundreds of small farmers
>and many third party certifiers out of business.  Public confidence will be
>jeopardized because people would not be able to rely on organic labels as
>meaning what they have come to expect, a pure product, grown or prepared
>with concern for the highest level of safety. For instance, instead of
>requiring livestock feed to be 100% organic feed, the new regulations would
>allow 20% non-organic feed, confinement operations and liberal drug use
>(only for the livestock, of course, not the producer.)
>>
>>        What is your favorite issue?  Democracy and freedom of expression?
>These new regulations were not produced by the agency that was created to do
>this work. In 1992, the USDA formed an advisory board to write these rules,
>The National Organic Standards Board. The NOSB met for years, did their job,
>and made a complete set of recommendations to the USDA that were acceptable
>to growers, processors and consumers.  The USDA ignored the work of the NOSB
>and promulgated their own set of rules instead.
>>
>>	Who is behind these substandard rules? Clearly, the beneficiaries would be
>the agribusiness conglomerates who would not have to adhere to the high
>standards that were developed by the organic industry.  The losers, as
>usual, would be the organic farmers and the consumers who care about how
>food is produced. Why would the agribusiness interests care about organics?
>Because it is not a marginal market anymore. The U.S. organic industry is
>worth 4 billion dollars in annual sales and is growing at over 20% a year.
>In a press release last year, Swissair announced that "the trend towards
>organically grown foods is increasing across the globe", and by the year
>2000 Swissair will ensure that 90% of the products they use to prepare meals
>are organically grown and even their coffee will be fair trade coffee. Must
>be something good going on.  And this re-writing of the rules amounts to
>nothing less than a hostile takeover of the success of the organic industry
>by industrialized agriculture interests, hoping to cash in on the trend.
>>
>>	There must be a story here, about how the interests that stand to gain,
>whoever they are, were able to re-write the rules that were already drafted
>by the NOSB, and get the USDA to promulgate them, in the face of all the
>contributions already made by the organic industry and the expectations of
>the American public. This is a misappropriation of the word "organic" and
>the value that it has come to mean to the consumer.  It is an abuse of the
>public's trust in nation's organic farmers.  It may even be a theft of the
>organic industry's ownership of the word organic, a "takings" by the
>government of the intellectual property of the leaders who developed the
>meaning of the word "organic", organizations like California  Certified
>Organic Farmers, the Organic Trade Association, and the Organic Farming
>Research Foundation.
>>
>>        The USDA defends their rule making procedure.  They say that this
>is just a proposal, not set in stone, and point to the "public process" of
>comment that is now being conducted.  As if. First, it should be pointed out
>to the USDA that the experts who worked on these rules, the NOSB, took six
>years to do their work. The rules are hundreds of pages of technical
>material. The NOSB recommendations were then ignored, and an entirely new
>set of rules were proposed, by the USDA, as a nasty surprise for all of us.
>>
>>	What is the public supposed to do, write a third version of their own? The
>timing of the comment period would be a joke, if it were not such a serious
>matter.  The public, not even having the resources or the expertise of the
>NOSB members, are supposed to review hundreds of pages of complicated
>regulations, and in less than 90 days, read and respond to the USDA's
>version of these enormously complex and technical regulations. Even the
>comment process itself is highly complex, requiring citations to specific
>rule sections to be considered. This is democracy at work?  Appoint a
>committee, ignore its recommendations, dump a load of bureaucratic sludge on
>the public and expect us to dig our way out?
>>
>>	And how did it happen that the NOSB proposals were dumped?  Who wrote the
>new rules? The USDA is avoiding the public outcry that would result if this
>story gets told. They have made it very difficult to get informed and they
>do not want to hear from us. California is the largest agricultural state in
>the nation and home to most of the growing organic industry.  The USDA has
>scheduled no hearings on the rules in California.  And the State of
>California is going along with the gag. California farmers and the public
>were given only one month to comment to the State Department of Food and
>Agriculture about these rules and how they should respond to USDA.
>>
>>	Why are these regulations being shoved down our throats? As a former USDA
>attorney, having witnessed the rule making process myself, I have little
>confidence that the agency will pay attention to the public. As my friend,
>and superb organic farmer Janet Brown says, even a dog knows the difference
>betweeb being tripped over and being kicked on purpse. But does the public
>recognize a denial of due process here?  Even if the timing were better,
>will the USDA listen? I doubt it. Does anyone know of a federal agency rule
>making process where the public has been able to stop the process?  The
>agency is forcing the public to comment on rules that are so fundamentally
>flawed that no good outcome is possible. The public comment period is only
>playing the game on their turf, according to their rules, but we absolutely
>have to respond. These rules must not be allowed to stand, and the process
>for drafting any new ones must stand up to public scrutiny.  Small changes
>to a bad law at the last minute are not a remedy for this wholesale theft of
>the public's confidence in organics, but what choice do we have?  We deserve
>an accountable, transparent process.
>>
>>        Care about international trade?  The new rules declare that their
>major purpose is to encourage agricultural exports. But the new standards
>are actually lower than those of some of our trading partners in Europe and
>Japan.  So is this a stealth attempt to use the World Trade Organization to
>reduce the standards in other countries and create a new lower common
>denominator, one more friendly to agribusiness?  The GATT rules on
>agriculture are up for renewal.  Instead of being a world leader in setting
>high standards in food health and safety, the United States is continuing to
>push for the interests of industrialized agriculture.
>>
>>        Care about social justice issues?  Labor and employment practices
>by agribusiness, health problems related to pesticides by farm labor and the
>security of the small family farmer are related issues.  If corporate farms
>continue their take over of our food supply, then these businesses and their
>giant trading corporate partners can set the price of basic food
>commodities, dictate the wages and working conditions of farm workers and
>put family farms out of business through the consolidation of land holdings
>and economies of scale.  Polluting farming practices and poor labor
>conditions are cheaper and are more likely to occur if corporations are
>allowed to continue taking over our food production.  Preserving the family
>and small scale farm that can employ alternative methods and that can
>produce food for local consumption ensures food safety and is more
>environmentally sound than industrialized farming methods, and the organic
>industry is made up of primarily small sized producers.  We have not fully
>addressed the issues of sustainability within the growing organic industry,
>but that question may become moot if these laws are passed.  Lower standards
>will allow for a greater take over of organic farming by agribusiness and
>put the small producer out of work and off the land.
>>
>>	Care about personal or public health?  A recent report by the California
>Department of Pesticide Regulation stated that, in 1995, the last year
>studied, pesticide related illnesses are up 20%, overall. That figure is
>admittedly low, since so little pesticide illness is reported or verified.
>The largest component of this rise in illnesses is the use of agricultural
>chemicals.  The report stated that the number of farm illnesses related to
>pesticide use increased 46%. Isn't one of the major reasons the consumer is
>buying more organic food, particularly the fastest growing segment of the
>industry, organic dairy products, due to concern about health?  Why would we
>want to lower those standards and risk losing the trust that we have created
>in the public, a sophisticated consumer market that has been willing to pay
>higher prices for food that they know has been produced in a healthy way
>with pure ingredients?
>>
>>	Our food is so plentiful and the earth is so generous, we have come to
>take it for granted.  These days, almost half of our food is purchased
>already processed and consumed outside the home, mostly at fast food
>restaurants.  If we care about food, it is often about price or purity; we
>want our food to be cheap and safe. But as the price we pay for food
>steadily declines, along with it we are losing our interest in how it is
>produced.  This disconnection, on a spiritual and social level, with the
>source of our nourishment, must be our greatest loss. We can continue to
>abdicate responsibility for our food supply or we can take it back. Now.
>Begin by telling the USDA to withdraw these rules and start over.
>>
>>Claire Cummings
>>
>>Attorney, former farmer, writer, activist.  Board of Directors of Food
>First and Community Alliance with Family Famers; Marin Food Policy Council,
>and Commentator on Food and Farming on KPFA radio.
>>
>Claire Cummings
>P.O. Box 5124
>Mill Valley, California 94942
>
>tel: 415 - 491-1948
>fax: 415 - 491-1240
>