Sounds to me like a constructive and valid idea, for small farms, small
certifiers, small handling operations. We will have to define "small"
because the Small Business Administration's definition is I believe less then
$100,000,000 in sales for business. Absurd in light of petite organics. Let
us compose the definition, for farms, certification agents (under
accreditation, on site inspection is the term for inspection) and handling
operations under $40,000 in gross sales. Such entities (Regulatory
Flexibility Act language) must must be certified (or as applicable
accredited) but not inspected except every 5th year. Along with the
reduction in Federal Governmental monitoring, USDA/NOP should charge a lesser
pro rated fee for those certifying agents certifying small farms or those
certifiers that have less then $40,000 gross, thus balancing some of the
efficiencies garnered by either a farm, handling operation or certifier
becoming very large--over $40,000 in sales. I think we have found a
direction to take the wave. All the language needs to be based on the
Regulatory Flexibility Act so SBA can be the advocate in court for small
organic entities. Now we have to clearly compose the proposal and move to
inform others for their comments, culminating in the large scale public
response during the comment period. I would encourage OFMA to join this
effort and would support the same personally.
Best regards, Eric Kindberg
n a message dated 97-10-28 12:00:04 EST, sals@rain.org writes:
<< Subj: Re: One size fits all NOT
Date: 97-10-28 12:00:04 EST
From: sals@rain.org (sal)
To: sals@rain.org (sal), Erorganic@aol.com, london@sunsite.unc.edu,
sals@rain.org, sanet-mg@shasta.ces.ncsu.edu,
organic-certification@listserv.oit.unc.edu, Sprinkraft@aol.com,
wfof@ptel.net, richmo@indy.net, dhinds@ucol.mx
..Why not do for the small farmer what they may do for the small certifier.
Let the small farmer after he goes through the transition period get
certified every 5 years that will cut down on the inspection cost leave
inspectors time to check out the big mix operations and it will also make
sure the farmer understands the certifying rules . There is no need to tax
these small growers out of business as we want even more small farm
certified not less. There are more small farms now in Ca. and it is
growing thanks to CSA and farmers markets and of course the organic
movement. I say give the small grower of say $40000 in sells the same
break we are hopefully giving the small certifier. The inspection every 5
yr. plus paper work every year plus he has to follow all other rules should
help more small growers be certified . I think the public will go for
that. I don't mind being certified I just need to keep my cost down and
this would be a big help. >>
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