<< It's fine to quote the OFPA text Eric, but it's not the
Bible.
eak: Are you suggesting OFPA is the Bible Douglas. I am not. It is only a
US Statue. There are a few more laws. If you would like to contest them
too, feel free. My choice after recognizing that the majority in this
country chose to pass the Act was to make it work for small to moderate size
organic farmers, handlers, certifiers and their customers. My participation
on SANET is to the issues, the historical background and the systems and
practices that make up organic public policy. Although, I have found the
conversations on a variety of issues very informative. My opinions and
emotions are really not of significance to supply on SANET. Just the facts
sir, with a few comments.
I strongly suggest you take the time to study logic and
semantics, because if you really believe that "minimum" is completely
different than "consistent", then either you are Daffy Duck or there's
method to your madness and it's Scrooge (and this too is consistent -
with the vested interest of the Disney company in organic products that
you mentioned earlier).
eak: Canada has an organic act that use the word "minimum" standards in the
language in contrast to the US using "consistent". Under law, there are
completely different meanings to these two words. "Consistent" means there
is a single, uniform and one standard of whatever. To be certified organic
in the US, the best similarity I have come up with is to think of an
interstate trucking license. No matter what state you take the test, the
test is the same, and if you fulfill the requirements you get it, if you do
not, come back and try again. The criteria for receiving the license are the
same in most respects everywhere. You get different staff and some
subjective comments but the evaluation criteria are the same from state to
state. Likewise will be the procedures for licensing a certified organic
farm or handling operation.
OFPA, as it was finally implemented does authorize an accredited certifying
agent to in cooperation with an organic farm, wild crop operation or handling
operation applicant develop an organic plan. "Such a plan shall be reviewed
by the certifying agent who shall determine if such plan meets the
requirements of the programs." The organic plan will allow some variability
in evaluation factors within limits. The State of Texas has developed what
in my judgement is an extremely fair and balanced approach to such a plan.
It is structured to encourage continual improvement of the systems of farm
production. It no doubt it can be improved upon. The NOSB recommended a
very thoughtful organic handling plan. Both are worthy of review and
consideration. And there are more.
As noted previously, under OFPA, each State is authorized overall authority
to assure that farmers, handlers and certifiers within the State operate in
conformity to OFPA. In addition, each State is authorized under OFPA to
choose its role. Each state can be accredited as a certifying agent and
actually do certification and/or can have legislation or administrative law
that sets forth a State organic standards (a certification program) and seek
approval from the Secretary for that State organic program. Each state can
choose to do both, none or one of the options. Democratic government are run
by the people. Seems to me organic farmers and handlers along with consumers
need to get together and make the decision for the State they live in.
I have reviewed previously how nothing in OFPA prohibits any person or
certification agency from using their "seal" or certifying that any standard
they wish to truthfully describe is or is not being used on a particular
organic farm or handling operation. However, there is only one standard in
the US, a consistent standard, for products labeled and sold as "organic".
OFPA was passed for that purpose.
And Douglas further asks:
"Please state clearly: Are you or are you not
receiving funds from any source to do these posts? (I myself am not, and
I plan on doing a few other things today). >>
And now, not wanting to leave Douglas concerns lacking a full response.
Douglas, I have farmed continuously for 26 years until I separated from my
partner of 24 years a year ago last May. I planted crops in my
fields--green manures, wheat--and came home from a trip consisting of
speaking at the Upper Midwest Organic Conference, attending the OCIA Int'l
Annual Meeting in Cedar Rapids and finally meeting in DC with the
Undersecretary for Marketing and Regulatory Affairs, American National
Institute of Standards and OGC to present an organic farmer proposal for
structuring the USDA program for accreditation of States and private
certifying agents. Upon returning, my fields were plowed up and replanted
with a grass/legume mix. At that point, I concluded I needed to find a new
place to live. My search continues and I am now hitchhiking through south
central Iowa. I have had to buy all my organic food for the last 10 months,
the first time in 26 years. Now having bought organic farm products in every
area of the US and some of Canada over the last months, many trends are
clear. I would like to volunteer this information:
Meat produced on organic certified farms and processed by organic certified
handling operations is the wave of the immediate future for the 10 large
distribution coops and community coops as well as chain organic stores.
Once OFPA is implemented, international demand for organically produced
meat products from the EU and the Pacific Rim will skyrocket.
There is not enough consistent supply of organically produced vegetable and
fruit products in the US. Sometimes there is virtually nothing available in
some categories. Last year and this year was the first time organic
strawberries came into the retail outlets and some coops coast to coast.
Quality of produce in the retail coops/stores has so improved, primarily
because of large, very professional produce farming operations having found
the future is in organics. It is hard for any low quality, poorly handled
organic product to make it into a retail outlet any more. International
markets for produce remain on a point of explosive demand.
Organically produced eggs and dairy products are expanding at 50% annual
growth rates with very little slow down in sight. Organic dairies are coming
into production for local or regional demand at a fast rate.
Domestic and international markets for organic grains, beans and seeds are
expanding at levels that are finding farmers hard to meet the demand.
Organic fiber markets are expanding domestically and internationally with
feminine hygene products, clothing textiles and sheetings. The conversion
system from fiber to finished product has some snags that need ironing out as
well as the pre-harvest defoliation of the plant using natural substances
presents a challenge. But as with the other markets, the future is one way,
just up.
I do not even want to get into the pricing. The single, salient need after a
quality National Organic Program is improvement of the farm to buyer
marketing system. On the local scenes, CSAs, restaurants (85% of leading
restaurants are purchasing some organic products), local retail coops and
stores and other more direct farm to customer relationships organic farmers
by their grass roots nature are opening markets left and right, with no
thoughts of looking back. These sales are the primary educational point that
everyone else benefits from up the food chain. The organic production
research and the public education done by individual farmers are not prepaid
for and should be held with greatest support and respect.
On organic sales to retail regional outlets, food processors and
international trade purchases, the entire marketing/pricing system is
chaotic, but working. Building an organic farmer controlled
marketing/pricing system is legal in the US and possible. With prices that
make conventional farmers look in disbelief, it is now time for organic
farmers everywhere to look at what they want for the future. Most indicate
they want a stable, very efficient marketing system that provides a long term
sustainable price for them to do the good job on production and improve their
efficiency and soils. How to integrate that with local supply for local
demand as well as fulfill processor, international and retail coops/stores is
the mission of the Organic Farmers Marketing Association. We invite you to
join us in building a new, farmer run, market driven, "sustainable" organic
agricultural base. http://www.iquest.net/ofma/
The single, overpowering priority of small to moderate organic farmers at
this time is to get quality standards and quality certification--a level
playing field on organic standards. I feel that there should be a degree of
flexibility regarding the regulatory program on small to moderate size
organic farmers, handlers and certifiers. In fact the Regulatory Flexibility
Act recognizes that Acts of Congress are passed to regulate large business
entities. The Regulatory Flexibility Act administrated by SBA (Small
Business Administration) is a process whereby small entities, organic
farmers, handlers, certifiers in our case, can be released of the burden of
undo regulatory rules. While large business must conform. The details all
have to be worked out. Discussing the issues and involving all consumers to
deliver their informed messages during the Public Comment Period is the
all-important next step.
And now to further address Douglas' concerns:
OSFVP concluded the National Organic Marketing Cooperative Feasibility Study
on April 3, 1996, with the able assistance of many wonderful organic farmers
nationwide. Since that time I have not been employed by anyone.
In order to survive without farmland until my personal relationship is
settled, I have entered into several small contractual engagements related to
expertise I possess. No one has every paid me to offer insights into OFPA or
to fly to DC or speak anywhere else regarding OFPA or to be president of
Arkansas OCIA or to be an OFMA representative as a non-governmental member of
the US delegation to the CODEX Committee on Food Labeling, etc. The cost to
me has been quite large, but the issues, experience and I hope the benefits
to consumers, the environment, small to moderate size businesses and farmers
are worth every bit of my investment. Thoughtfully, organic farmers and
conference coordinators have contributed to assist in transportation and
rooms sometimes. Around June of 1996 the C. S. Mott Foundation and the
Jessie Smith Noyes Foundation funded Ozark Small Farm Viability Project, a
501(c)(3), to provide quality information on the Proposed Rule for the
National Organic Program to citizens throughout the US. Under the grant, I
have been contracted to write the side by side comparison of the Proposed
Rule with OFPA. There has been only one employee of OSFVP under these two
grants--the typist who built the database. The database is for postal
mailing the side by side comparison of the Proposed Organic Rule and the
Organic Foods Production Act (and relevant recommendations of the NOSB) to
all those interested.
Your name can be included on the database by sending a note to OSFVP, POB 99,
Mt. Judea, AR 72655 (include email address please). The delay in publication
has forced all concerned to remain hanging on beyond the original granting
period that ended June 1, 1997. The grant was funded for the Proposed Rule
to come out in October 1996. That is all history now.
I am not paid anything now and haven't been paid for any services under the
grant since April 1997. As I said before, whether on a certification review
committee, or providing information on organic farming, handling,
certification, markets or the NOP, or working to get a quality and responsive
National Organic Program, or being on the National Organic Standards Board,
most everyone's work is to a great extent volunteer.
Best Regards, Eric Kindberg
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