While the new USDA organic standard is a significant improvement over their original disastrous proposal, there are some remaining problems that require 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) must be changed to explicitly state that the federal organic standard specifies the minimum requirements, not the maximum, and certifiers are not only allowed but encouraged to enforce stronger standards without permission from government and regardless of whether others do likewise.
If a future administration lowers the federal standard, certifiers must be able to maintain the existing level of quality which would then be above the federal level. National Organic Standards Board (NOSB) is selected, and thus ultimately controlled by, the USDA, so it can't necessarily be relied on to represent our interests. In the long run, control of changes is more important than the initial state. The USDA proposal gives the Secretary of Agriculture veto power over any implementation of stronger standards. If combined with a steady erosion of the standard, all the work to build the organic movement and get a good initial standard could be lost. To avoid this requires putting no restrictions on higher standards, leaving the door open to continual innovation and a free market of superior standards above the federal floor, so consumers can use their power in the marketplace even if the federal standard is debased.
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 of sewage sludge, and that sewage sludge should be defined as synthetic so that the National Organic Standards Board (NOSB) and the public will have legal authority to analyze any proposals to change the sewage sludge prohibition in the future, otherwise changes could be quietly slipped in later.
Problem: Use of certain types of genetic engineering is in limbo, and could be quietly slipped in later without public oversight.
Solution: Tell USDA that 205.2 should be changed to restore the NOSB definition of genetic engineering, including their full list of "excluded methods", and 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, otherwise weakening changes could be sneaked in later.
Problem: The proposed rule holds organic farmers responsible for the polluting actions of others and fails to address the economic consequences of gene pollution, chemical drift, and mandatory spray programs.
Solution: Tell USDA to guarantee that all damage from genetically engineered and pesticide products, including genetic pollution damage to organic farmers, is fully compensated by those making and using them, not by organic farmers nor by the public. This requires that makers and users of genetically engineered products post a bond to ensure the money is there, and provide public notification of their use so the locations of potential genetic pollution sources are known to farmers in the area. Genetic pollution is especially serious since reproducing genes can cause an irreversible, continually growing problem over time, while chemical pollution fades away over time.
Problem: Food handlers are allowed to use toxic pesticides if they decide organic methods are "not effective", while still calling it "organic".
Solution: Tell USDA that 205.271(c) should be changed to unconditionally prohibit any use of a synthetic substance not approved for organic production.
Problem: Irradiation is not defined and could be slipped in later.
Solution: Tell USDA that 205.2 should be changed to define irradiation to include all techniques using ionizing radiation, and that irradiation should be defined as synthetic so that the NOSB and the public will have legal 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 use of toxics, soil erosion, etc. People should not be penalized for doing the right thing by moving away from practices that can undermine the long-term health of the earth.
Problem: USDA may get pressure to undo the things they got right.
Solution: Tell USDA to refuse to weaken the standard's good provisions for: Ecolabels allowed; Certifier ability to de-certify; 100% organic feed provisions with no antibiotics or animal parts; Detailed percentage labeling, including 100% organic; NOSB's authority under the law for the National List; USDA as accrediter, not certifier; Flexible organic plan format; Commitment to reduce costs on the first round; No antibiotics allowed either in animal feed or in fruit production; Includes mediation in the appeals process; and Emphasis on 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 TMD-00-02-PR.
For more info and to get involved:
These have more detailed explanations and language you can cut & paste from:
www.purefood.org/newsletter/biod26.cfm (BioDemocracy News #26 April 2000)
www.SustainableAgriculture.net/action_needed.htm
www.centerforfoodsafety.org/facts&issues/orgrule.html
www.purefood.org/Organic/stdprobs.cfm
BioDemocracy Campaign/Organic Consumers Association
6114 Highway 61, Little Marais, Minnesota 55614
phone: (218) 226-4164, Fax: (218) 226-4157, email: info@organicconsumers.org
web: www.purefood.org
To subscribe to the free Organic View electronic newsletter, send an email to:
info@organicconsumers.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: Campaign@magiccarpet.com
web: www.SustainableAgriculture.net
The Center for Food Safety
666 Pennsylvania Ave, SE, Suite 302, Washington DC, 20003
Phone: 202-547-9359 Fax: 202-547-9429 E-Mail: office@centerforfoodsafety.org
web: www.centerforfoodsafety.org
Berkeley Ecology Center, 510-548-2220, www.ecologycenter.org
If you're very short on time, download www.centerforfoodsafety.org/OrganicWatch.pdf
print it, put your name & address and a stamp on it, and drop it in the mail.