THE ORGANIC ORGANIZER, a publication of the Organic Farmers Marketing
Association, Inc. http://www.iquest.net/ofma/
Eric Kindberg, Co-chair of the Communication/Telecommunication Committee
Copyright pending. Free for use only in its entirety or by excerpt through
contacting and permission from this email address: erorganic@aol.com All
users please give credit as above.
REGARDING THE SMALL FARM EXEMPTION.
OFPA exempts small farm operations under §2106 COMPLIANCE REQUIREMENTS.
(d) SMALL FARMER EXEMPTION. Subsection (a)(1)** shall not apply to persons
who sell no more than $5,000 annually in value of agricultural products.
**The Subsection (a)(1) makes certification by an accredited USDA certifying
agent mandatory to affix a label to, or otherwise provide market information
concerning, an agricultural product if such label or information implies,
directly or indirectly, that such product is produced and handled using
organic methods, except in accordance with OFPA.
The House/Senate Joint Conferee Report, in a final statement before passage
of OFPA, says, "Farmers who sell less than $5000 of agricultural products may
represent their product as organic without certification but no USDA label is
authorized to be used in this instance."
A COUPLE OF OBSERVATIONS ABOUT THE SMALL FARM EXEMPTION OF OFPA:
STOPPING MISREPRESENTATION BY COMMERCIAL, CONVENTIONAL FARMS AS NOT SELLING
MUCH ORGANIC PRODUCT.
The Small Farm Exemption because it applies to the gross farm income means
every farm with total conventional and organic sales over $5000 must be
certified. This closes any loophole of a commercial size conventional farm
contending it does not sell over $5000 organic for instance at a farmers
market, to CSA customers, restaurants or to local retail outlets.
And,
HOW DO WE ENCOURAGE BEGINNING AND TRANSITION FARMERS TO BECOME ORGANIC
FARMERS?
Create an expanding and permanent market for "organically produced" products
through implementing:
- a set of high quality organic standards that the consumer recognizes as
worth paying for (the National Organic Standards, including the National
List), and
- a transparent method to assure the consumer they are consistently getting
what they are paying for (accreditation/certification/equivalency).
OFPA does these things.
And so what are the problems with the $5000 Small Farmer Exemption?
IS THE $5000 GROSS SALES FIGURE FOR NOT HAVING TO BE CERTIFIED TOO LOW?
Raising the $5000 figure to say $40,000 gross farm income may seem to be an
assistance when the small grower is looking at their personal income
statement, but it will open the door to larger commercial, conventional
growers to reap the economic benefits of selling organic products locally.
If done, there would be many more growers selling their product as organic
and never having to be certified. Do local small organic growers want more
competition for which it is very difficult to monitor whether they are truly
conforming to the National Organic Standards?
IS THE COST OF BECOMING CERTIFIED WHEN A FARM EXCEEDS $5000 GROSS FARM SALES
TO HIGH?
The Small Farm Exemption was put in OFPA to allow beginning farmers without
many sales to develop to a level where they could afford to be part of the
USDA National Organic Program. Cost of certification varies from locality to
locality. Some State organic programs like Kentucky ($25, any size), Texas
($150, 20 acres), Maryland, New Hampshire, New Mexico, and Idaho perform
certification and to some extent subsidize the certification. Some private
certifying organizations have subsidized farm and handling operation
applicants for years. Those most involved or with the greatest expertise in
organic farming and handling regularly volunteer their time, expertise and
energy. OCIA Chapter certification committees, approximately 38 of them
across the US, are all volunteer workers. Sometimes an office administrator
is paid, but volunteers do most of the work. On the other hand inspectors
are always paid. After years of involvement in certification and inspection
of organic farms and handling operations, I feel confident in stating that
the true cost of organic certification is greatly undercharged for by the
semi or mostly volunteer certifiers like OCIA chapters, Florida, N. Carolina,
etc., even CCOF and the NOFAs. If you look at the certification prices now
charged by the for-profit private certifiers, QAI, FVO, who have never really
made any money yet, and the non-profit private certifiers like Oregon Tilth
and OGBA, one obtains clarity on what organic certification really costs.
Investigation indicates most certified organic farmers and handlers, as well
as applicants who do not qualify, are presently being subsidized by small
groups of certified organic farmers who are participating on the
certification decision making body. If organic farming is actually a
business, it is time for a change. In my certification experiences,
volunteerism has reached its limits. Just as organic farmers and handlers
are professionals, so certification and inspection needs to be professional
and have profession practices and systems and quality pay for quality work.
In the next Bulletin of the Organic Organizer we will delve into
certification agent operation and explain how we calculated the cost of an
organic certification agency under OFPA.
For now let us just say and we do seriously propose that after implementation
of OFPA the total cost for the smallest farm applicant (those above the $5000
level) will be at the highest, if priced reasonably by the certifiers
themselves, approximately $237.50 annually. This certification cost comes
out to 4.75% on a gross of $5000. At $10,000 gross sales, the percent
becomes 2.3% and drops in half from the cost at $5000 gross. Of course, it
would be about the same certification cost for an organic farm grossing
$40,000, which would then make certification cost .59% of the gross. How
much acreage is certified to achieve what gross income is dependent on the
organic farmer's activities. The NOP could compensate some way for small
farmers perhaps be charging only $2 annually per farmer for the accreditation
cost to organic farmers grossing between $5000 gross and $40,000 gross. A
much more direct and effective way to reduce certification expenses is for
each State to subsidize certification of small farms and perhaps small
handling operations.
If the small organic farmer with over $5000 gross cannot live with private
certification cost, perhaps, their State needs to be prompted to follow
Kentucky and Texas's lead and implement an approved State Organic
Certification Program with subsidized fees for small or all growers. This is
certainly within the grasp of organic farmers in every State to accomplish.
I would suggest that the expense of $237.50 annually is payable by any
organic farm seriously interested in growing and becoming economically viable
for its owner(s).
Organic: a partnership between farmers, marketers, customers and the
environment.
<End>
Best, Eric Kindberg
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