Re: All opinions aside, these issues were decided 7 years ago: Erorganic

Erorganic@aol.com
Fri, 7 Nov 1997 05:32:02 -0500 (EST)

In a message dated 97-10-31 10:38:14 EST, dmhinds@acnet.net writes:

<< Subj: All opinions aside, these issues were decided 7 years ago:
Erorganic
Date: 97-10-31 10:38:14 EST
From: dmhinds@acnet.net (Douglas Hinds)
Reply-to: dhinds@ucol.mx
To: Erorganic@aol.com
CC: sanet-mg@shasta.ces.ncsu.edu

(I've sent this three times already but it hasn't come back to me
through sanet so I've no way to confirm it's getting through).

Erorganic@aol.com wrote:

> not to certify, would be contrary to OFPA itself. OFPA says anyone
selling, or
> labeling or implying directly or indirectly that a product is organic must
be
> certified. All opinions aside, these issues were decided 7 years ago by
> those that at that time had been farming for 3 to 15 years organically and
> consumer, environmentalist along with organic certifiers.

I think you've hit the nail on the head. You have provided many well
stated and thoughtful reasons in support of your point of view.
However, others have also presented excellent and sometimes pointed
motives in support of alternative solutions (and the need for them) to
these real problems, which may not have been sufficiently apparent at
the time OFPA was drafted. Perhaps these differences help to explain
why OFPA hasn't yet been implemented yet - there seem to be aspects of
the law's implementation that remain unresolved, and a reappraisal of
some of OFPA's basic tenet's (such as obligatory certification), may
well be in order, and many others also seem to believe that is true.

eak: Passage of OFPA did not resolve the personal opinions and practical
knowledge that had been gained over the years by everyone in the organic
community. Some of the delay in the NOSB recommendation development process
can be attributed to controveries continuing after compromise was legislated
in OFPA itself. However strong many of those opinions were over the last 5
years and are still held by some sectors, the major reason for the slowness
rest with two factors. 1.) USDA Secretary Madigan, under the Bush
administration appointed members of the NOSB that were mostly unfamiliar with
organic farming, handling and certification systems and practices. Only in
the last round of appointees did the balance shift. 2.) The entire USDA
staff, minus one who came on late, were unfamiliar with the same knowledge.
OFPA was in essence a way to bring organic knowledge to the elite decision
makers in and out of government. In the last 5 years, the entire structure
of US agriculture has moved more radically towards environmental soundness
and pure and unadulterated food than what had existed in this country since
1900. This educational process has and continues to take a massive amount of
volunteer energy and patience. The process is not over. Sal's concerns and
many others on many issues still remain to be answered within the Final
Organic Rule.

For instance, some have indicated a need for distinguishing between
"organic" and certified organic", whereby "certified organic" would
indeed be subject to a federally mandated, standardized certification
program, while "organic" would be subject only to a legal definition at
the national level.

I would be very interested in knowing whether you personally would be
agreeable to having this issue re-examined within the framework of the
original body responsible for the drafting of the OFPA.

eak: The original body responsible for the drafting of OFPA, that you speak
of falls into three groups, actually to my knowledge, 4 groups. 1.) The
consumer, environmental, public interest groups that worked through Senator
Leahy of Vermont--this culminated in the CSPI meeting in DC, 88 or 89, where
there was so much controversy that the Mott Foundation funded a national
meeting in Leavenworth, KS to bring some consensus on organic
standards--everyone was invited. 2.) The earliest iniatiating groups were
economically motivated with some relation to certified organic farmers--those
being Senator Fowler of Georgia who actually proposed an act first, followed
by modifications by Senator Lugar of Indiana, then came Senator Leahy. 3.)
Then there were the organic farmers themselves, represented largely, but not
exclusively by organic certifying agents, Ron Gargasz, than the leader of
OCIA International, CCOF, Oregon Tilth, etc, all who felt the proposed
organic act needed to be modified to work for farmers and consumers. 4.)
Then there was OFPANA, now OTA (which moved from being an association of
organic food producers to being a "trade" association in the early 90's and
formally retaining a lobbyist in DC). Along with OFPANA, which about the
time of passage of the Act became dominated by food processors and
manufacturers, there were a couple other offshoot, mostly processor
representative organizations in this fourth group, who have withered away.

In my opinion, it would be extemely difficult for any or all of these grass
roots organizations to reassemble and consider these issues. Reading the NOSB
recommendations directs ones attention to the depth of discussion that has
been done since 1992. Reviewing the NOSB meeting minutes lets everyone know
that after 12 or more NOSB meetings, all with public comment periods that
sometimes went from noon to midnight, and extended examination of the issues,
it is now time to actively participate in the public comment period. The
period is the appropriate time to discuss any changes that will benefit the
entire organic community.

There is yet another body that did extensive work in drafting OFPA--the US
Senate and House. The Senate Report (101-357) is 17 pages long. The
House-Senate Conferee Report another 6 pages. The Senate held open committee
meetings. All participated in the drafting. I appreciate your challenge to
the organic community and to myself to participate in re-examining the Act
itself. It is clear that the participants in its drafting are so diverse and
extensive that it would take another 5 years to re-examine.

I would offer an alternative suggestion: Pick issues and discuss them over
SANET. Such dialogue should bring the real issues to the surface. That is
the best I can support--other then participation within the OFMA policy
development process and comments during the public comment period.

I'm sure you
believe in the validity of your reasoning and are confident that only a
strengthened and more unified position adapted by the organic community
as a whole would result from such a re-evaluation. (Does that sound
familiar)? Surely you're not afraid of a little healthy debate - and we
all know that in practice, in the vast majority of cases certification
is a necessary adjunct to marketing. Still, there seems to be instances
where great injustices will be committed in the name of a perhaps
foolish consistency and in any case, enough controversy has been shown
to exist to warrant an OFFICIAL re-examination.

Assuming that this is the case, what would you suggest in terms of
procedure, in order to subject this matter once again to legislative and
public scrutiny? (Who, how, when and where are the appropriate
questions here).

eak: Informed public comment during the public comment period on the Proposed
Rule.

Best Regards, Eric Kindberg

I have no doubt that your comments will be very helpful in this regard,
so I thank you for them in advance. The resulting debate will benefit
from the last seven years experience and take into account factors that
were not contemplated at that time. And the results will hopefully
settle this issue once and for all (unless other unforeseen
complications or incongruities become apparent once again in the distant
or not so distant future, and lead us into a still more profound
analysis).

--

Douglas M. Hinds, Director General
Centro para el Desarrollo Comunitario y Rural A.C. (CeDeCoR)
(Center for Community and Rural Development) - (non profit)
Petronilo Lopez No. 73 (Street Address)
Apdo. Postal No. 61 (Mailing Address)
Cd. Guzman, Jalisco 49000 MEXICO
U.S. Voice Mailbox: 1 630 300 0550 (e-mail linked)
U.S. Fax Mailbox: 1 630 300 0555 (e-mail linked)
Tel. & Fax: 011 523 412 6308 (direct)
e-mail: cedecor@ipnet.com.mx, dmhinds@acnet.net, dhinds@.ucol.mx >>

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