> 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.
Gee, thanks Eric.
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?
Stay tuned, folks!
> 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.
Sounds good. But read on.
> ... 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
Uh oh! Now we have to answer this.
Eric - First of all, this is sanet, not the organic-certification list
server. You have questioned the creditials of everybody who's opinion
is different from yours (apparently everybody except other members of
the OFMA Brand of Directors). Charles Benbrook was Executive Director
of the Boad on Agriculture of the National Research Council when its
Committe on the Role of Alternative Farming Methods in Modern Production
Agriculture publish their report on Alternative Agriculture in 1989. (I
guess you haven't read it). Does HE need to be certified in order to
speak his mind? You are proving our point. This thing has gone out of
Control (and YOU seem out of control) but can & will the corrected.
Larry Lawrence is the one that organized the reunions in his area you
needed to promote NOSC, when you got the $165,000.00 feederal grant to
travel around dong that. (The results? OFMA)! You want him too to be
Sal is an organic farmer who's knows what he's talking about. (Where
are YOU farming now, Eric)? Maybe he doesn't answer your questions
because he finally figured out that your sympathies lie elsewhere and
you're not going to be of any help to him whatsoever. (OK, your comment
on the SBA regulations was good, if patronizing). Now me.
I am an acredited inspector for the University of Colima's organic
certification program, as a result of a course given jointly by the
University & the OCIA a few years back. There were 50 or so of us from
all over Mexico, Central & South America & the synergy was better than
course. However, due to the fact that I sometimes market & therefore
can't certify, I've never used it.
As previously stated, I've grown organically since 1968 (in San Marcos,
CA - that farm's now a trailer park) and that was a CSA type operation
(roadside stand). Here in Mexico I still have 5 acres of riverside land
way back in the hills and farmed fruit with the best team of mules you
can imagine, and NEVER have used a single agrochemical on it. That too
was a local sales operation and the excess was trucked to the city and
sold by me in farmer's markets. We'd just put up a bit of shade. Since
then, I've participated as a invited lecturer in statewide events in
various states, promoting the use of biological control, organic matter,
crop rotation, cover crops, repellent crops, crops that attractive pests
away from main crops and other non-toxic, non-sythetic farming methods
that enhance the growth of healthy soil micro-fauna y flora, soil
fertility, innate disease resistence, etc.
Marketing organic produce in the U.S. is definitely NOT our number 1
priority, and in fact, few certified organic products, are available yet
in Mexico. That may be your main interest, but it's not ours. We have
been here since 1974 and in it for the long haul, not the quick cash.
We are planning on forming a second OCIA chapter here in Western Mexico
if we can spare the time (we have the future members waiting).
Meanwhile, we work with the existing chapter in Southern Mexico. We
help growers find markets directly & have had no need to certify
ourselves yet. That may change soon.
Our priorities are: 1).- The environmet 2).- Fair play for the growers
& farmworkes. The organic market is one option in that context & I hate
to see it exploited by self serving interests, including those that have
used governmental funds to futher their own private agendas. I hope I
have made myself sufficiently clear and will attempt devote a little
time as possible to this niggling, while keeping the record straight and
our eyes focused on the road ahead. There's a lot left to be done, but
it appears that a few minor flaws in OFPA having already created a
pathological atmosphere & therefore must cleaned up.
The problem isn't so much the law. Must of it is fine. But the points
that AREN'T fine are seriously wrong & permit the wrong people too much
power in service of the wrong ends (which is why I'm bothering to answer
your endless stream of inaccuracies. I'm aware that this is all you do,
but that's not the case with the rest of us). I will present a concrete
proposal relative to OFPA as soon as I get it into the computer. In
fact, it's rather simple.
Lastly, I really wish Eric would address the points I raise rather than
involve my personal history (which he seems to always present in an
incomplete or distorted perspective), because I don't really feel I need
to spend this time setting the record straight, with so much in front of
us left to be done. Whatever. Maybe it's for the best. Just please
keep it to the point from here on in.
> "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.
You can count on that.
> On to the next SANET discussions.
> Should synthetic substances, food additives, processing aids, yeasts,
> rennets, enzymes, etc. be allowed in processed organic food labeled
Organic means not synthetic. So the answer is no.
> 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.
Those substances are not applied to the crop but are used to attract
pests away from crops, so there's a valid exception to the rule.
There's no contact with the crop.
> 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.
Each must be reviewed on a case by case basis and when a given product
is the best alternative available, that may be sufficient basis for an
exception. In other words, present organic standards involve many
exceptions based on necessity - the impending total loss of a crop for
instance. These circumstances are now left in large part to the
discretion of the inspector. When no synthetic subtance will be present
in an otherwise organic food product and are necessary due to the
inavailability of a more "organic" alternative solution, there may be
sufficient basis for certification.
> 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.
They can patent and disclose.
> 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.
The old figure was 10% of that allowable for conventional products.
> 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."
> >From my perspective these are "real" issues. With the coming of the Proposed
> Rule discussion seems in order.
Yeah they're real. They're just not the ONLY real issues.
> Best regards, Eric Kindberg
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: email@example.com, firstname.lastname@example.org, dhinds@.ucol.mx
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