Date: Sun, 09 Nov 1997 09:46:45 -0800
From: Diane Cooner <firstname.lastname@example.org>
Subject: "self" article
Greetings to all :-)
I too saw the recent issue of Self magazine while on line at the market
the other day. "Can You Trust Organic" blaring from the front cover made
me think about our community's infighting on fine points, and wonder
about the impression that the organic industry is making on the general
population. Obviously, it's not as good as we could hope for!
eak: It is very interesting that you and Mr Benbrook would assume that
discussion issues on cost, paperwork, licensing the term "organic" and small
farm exemption would have something to do with the cover of "Self" magazine.
I see no correlation between the two. Historically, there have been
different viewpoints expressed by the many individuals in organic farming,
handling and certification who innovated the techniques, practices and
systems. But that is what the democratic process is all about. By far and
large the biggest differences have and still exist because some people have
been communicating and evolving consistently over the years on issues and
differences and some people have been out of the loop--and what that means,
is the latter people either have not been actively involved in the
development of organic farming practices and systems, standards,
certification systems, or even are or never have been certified as a farmer
or handler. That should not lessen their freedom to express input to
development of the National Organic Program. However, it does raise the
question how do we evaluate each others comments? My experience is one has
to ask, what has been your role, your experiences, your background? And what
is the rational for the organic standards or licensing system being
structured this way or that? The Public Comment period on the Proposed Rule
is about to be upon us providing us all with the opportunity to communicate
between each other on how to make "organic" permanently trusted by the
consumer. This is the time for discussion and active public involvement.
One of the reasons for OFPA is to differentiate between those who are organic
farming, handling and certifying and those who would rather not be certified
as organic. This differentiation mandated by Congress and implemented by
USDA will create a stronger bond of trust between consumers and the certified
organic farmer and handler through consistent and uniform standards and
organic certification procedures.
Our societies greatest present complaint against government is that the
bureaucrats, lobbyist, academics and professional commenters like the press,
do not have to live by the rules that are promulgated and enforced. True.
And yet everyone must have the right to have their say, including "Self"
magazine. To me their question is valid and worthy of attention. So are the
questions of Douglas Hinds, who has never been certified for being an organic
farmer or handler, and Larry London, who is I believe not certified either,
and Chuck Benbrook, who has never been certified, and Sal, who never answers
the question about presently being certified, to Rich who is certified and is
president of an OCIA chapter, to everyone else that wants to get into the
Act. Personally, I think SANET's rambling discussion about the small farm
exemption has presented the viewpoints. Now, those participants can put
their viewpoints down in print and send them to USDA. And so "Self" (what a
name for a magazine) offers its "thoughtful" insights too. "Self" is doing
all of us a service if it stimulates multitudes of consumers to think about
"organic" and put their thoughts down in email, print and handwriting and
send them to USDA.
On to the next SANET discussions.
Should synthetic substances, food additives, processing aids, yeasts,
rennets, enzymes, etc. be allowed in processed organic food labeled
Does the public have the right to "public access to certification documents
and laboratory analyses that pertain to certification" with the
non-disclosure of "any business related information concerning such client
obtained while implementing" certification?' Both these quotes are from
And bear with me, here is the most significant of all: What are the
procedures for and the content of the National List?
In the first sections of OFPA ,all synthetic substances are prohibited from
use in organic farming and handling and all natural substances are allowed to
be used. However, OFPA makes it more complex as follows:
Quoting the Senate Committee Report on prepared for passage of the Organic
Foods Production Act of 1990:
"Most consumers believe that absolutely no synthetic substances are used in
organic production. For the most part, they are correct and this is the
basic tenet of this legislation. But there are a few limited exceptions to
the no-synthetic rule and the National List is designed to handle these
Organic farmers have used some synthetic substances for several good reasons.
For example, some organic farmers use certain synthetic analogues to natural
substances when those substances are difficult to obtain. Insect pheromones,
a often-used biological control substance in organic farming, are very
difficult to collect in nature and are therefore synthetically produced. The
Committee does not specifically disallow the use of pheromones in organic
farming simply because they are synthetically produced when pheromones are
effective and ecologically benign.
The Committee does not intend to allow the use of many synthetic substances.
This legislation has been carefully written to prevent widespread exceptions
or "loopholes" in the organic standards which would circumvent the intent of
this legislation. The few synthetic substances that are widely recognized as
safe and traditionally used in organic production are explicitly cited in the
bill as potential items to be included on the National List if the Board
(NOSB) and the Secretary approve of their use.
The Board and the Secretary may consider allowing the use of synthetic active
ingredients in the following categories only: pheromones; copper and sulfur
compounds; soaps; horticultural oils; toxins derived from bacteria; treated
seed; fish emulsions; vitamins and minerals; livestock parasiticide and
medicines; and production aids such as machinery cleansers.
Organic farmers also use substances in which the active ingredient is known
to be natural but which also contain inert ingredients that are undisclosed
as a matter of trade secret law under the FIFR Act. The Committee suspects
that many of these inert ingredients are synthetic. For example, adjuvants
would fall into this category.
Until such time as FIFRA is altered to require the full disclosure of inert
ingredients, organic farmers should be allowed to continue using compounded
substances if the active ingredient is natural and if use of the substance is
recommended by the NOSB and approved by the Secretary for inclusion on the
National List. However, in order for the NOSB to evaluate whether certain
compounds should be listed, the Board will need some information about the
inert ingredients in question. The Committee directs the Board to seek the
advice of the Administrator of the EPA, who has information on inert
ingredients submitted as part of registration, as to whether such inert
material would be appropriate for organic production. EPA's response will
not limit it's regulatory responsibility for such material.
Almost all State and private (certification) organization standards also
provide for certain exceptions from the no-synthetic rule, some more
explicitly than others. In deciding upon an acceptable list of materials for
the Organic Standards Board and the Secretary to consider, the Committee
surveyed State and private regulations to ensure that the above categories,
while more restrictive than most of the current standards, will indeed
protect the integrity of the organic product while at the same time provide
the producer a reasonable amount of flexibility on production materials.
The Committee understands that just because a substance is natural does not
mean that it is safe and appropriate for organic production. The National
List may also include natural substances otherwise allowed under this title
but which are determined to be harmful to human health or the environment and
inconsistent with organic farming. Certain botanical pesticides may be
considered by the NOSB and the Secretary to be inappropriate for organic
production because their use poses significant harm to human health or the
environment. Whatever natural items appear on the National List shall be
prohibited from use in organic production.
Finally, the National List is designed to cover ingredients used in
processing. The bill allows that up to five percent of processed food
labeled "organically produced" may contain non-synthetic ingredients which
are not organically produced if those ingredients are included on the
National List. The five percent figure was arrived at after consulting with
various organic food processors as the amount of flexibility necessary in
processed food. The Committee intends that the guideline for processed food
ingredients on the National List be that such ingredients are difficult or
impossible to obtain. An example might be certain spices that are
unavailable at this time from an organic farm. It may also include items
that are not technically organically produced such as yeast.
Several steps must be taken before an item appears on the National List in
any of the above categories. First, the Organic Standards Board must review
the substances in question based upon criteria cited in the bill and with the
aid of the Board's technical panels. The Board may decide what substances
require review. As well, individuals may petition the Board to evaluate
substances for inclusion on the National List. The Board then constructs a
Proposed National List which is submitted to the Secretary as recommendation
for composition of the final National List.
The Secretary may not include exemptions for synthetic substances other than
those exemptions recommended by the National Organic Standards Board. The
Proposed National List represents the universe of synthetic materials from
which the Secretary may choose. Before establishing the final National List
the Secretary shall publish the Proposed National List in the Federal
Register and seek public comment. The same procedures are to be followed for
any amendments to the National List."