In our capacity as individuals and friends, we developed and now
share the below short "thought piece." If it is useful, fine; if not, hit
delete and let's get on with life. I thought it appropriate to share it with
SANET since many of the points and thinking were shaped by the long dialogue
we have shared these past months.
On another matter, there is a stunning "Perspective" piece by four
lang grant/ USDA/ARS scientists, and a colleague from the Netherlands --
W.J. Lewis, van Lenteren, Platak, and Tumlinson -- in the Nov. Proceedings
of the National Academy of Sciences entitled "A Total System Approach to
Sustainable Pest Management." (Pages 12243-12248; will be on the PMAC web
page in a few days; accessible now via the PNAS website, search by autghor
is easiest). It presents the most sober and accurate appraisal I have ever
seen by scientists within the system of the current "state of the art" in
pest management. Their expressed view of the potential of biointensive IPM
and biotechnology is virtually 100% in accord with the views commonly
expressed on this list, and in the Consumers Union book "Pest Management at
In the same issue of PNAS, maybe the one before, there is another
key paper by Tabashnik, et al on Bt resistance which further reinforces the
conclusion that resistant alleles are much more common than once thought,
hence reaffirming the risk of rapid emergence of resistance if Bt-transgenic
varieties are widely planted, given the inadequate resistant management
plans now in place.
FOR EVALUATING THE ORGANIC "RULE"
Charles M. Benbrook and Frederick Kirschenmann
As we anticipate the publication of the organic rule which will define the
Organic Foods Production Act of 1990, it occurred to us that a set of
principles for judging the appropriateness of various provisions might be
useful. Such principles may also be helpful in shaping recommendations for
change in the language proposed by USDA.
The complexity of the rule, the scope of its impacts, the short comment
period, and the range of views held in different communities are bound to
result in a wide range of suggested reforms. Widely different perceived or
hoped for impacts of the OFPA will be described. The circle of individuals
hoping to influence the outcome of the process is growing rapidly, as is the
diversity of issues likely to arise in the comment period.
How will USDA respond to the expected, large volume of recommended reforms?
How will the public debate over controversial provisions, and needed
solutions, influence the views of consumers, most of whom are just learning
about the program?
USDA's ability and willingness to accept recommended changes in the rule
will be a function of three things---unanimity, consistency with the
statute, and the justifications offered for changes in light of the general
goals of OFPA and "good government."
Accordingly, we felt that a shared understanding of a set of "first
principles" to apply in reviewing the rule may be useful to a wide range of
communities who will structure their comments and recommendations largely
independent of one another and without the benefit of time and dialogue to
recognize mutualities. To that end we offer the following principles to
anyone that finds them useful.
Perhaps they will also prove helpful to USDA as the department works to
integrate the expected recommendations into a cohesive set of changes that
collectively will---we all hope---make the rule simpler, clearer, and more
effective in achieving the stated purposes of OFPA.
1. Ecological Principle. Organic production should fit into and benefit
from nature's systems. Dual goals should guide farm management
decision-making: producing high quality, safe food in a manner that tends
to preserve the integrity and stability of the biotic community, and builds,
or at least sustains, the inherent productive capacity of the soil and
biological resources used in the production process.
Organic processing should, as much as possible, retain the integrity of the
product so produced.
Any deviation from this ideal, in production or processing, should only be
allowed when there is clearly demonstrated need, and must not undermine the
long-term goals of building soil productivity and producing nutritious, safe
food that consumers can buy and enjoy with confidence.
2. Precautionary Principle. Any materials used in the production or
processing of organic food must be proven safe. No materials will be
allowed simply because they have not been proven unsafe or because benefits
may appear to outweigh risks.and uncertainties. The burden of proof shall
always be on the party wishing to use the material. and contending it is safe.
3. Systems Principle. The acceptability of practices, processes and inputs
in organic production should be judged, first, on their impacts on whole
organisms and the biological and ecological process that govern interactions
within living systems. Those that are found to contribute to the health of
organisms and systems should then be evaluated in terms of their intrinsic
properties independent of their use and impacts on living systems.
1. Don't-Fix-What-Isn't-Broke Principle. First do no harm. Focus on
quality outcomes rather than process or compliance with norms. Allow for
the continuity and preservation of processes and decision-making models that
have established a record of integrity in meeting the basic goals of OFPA,
that demonstrate both transparency and responsiveness to all concerns and
communities, and which enjoy the respect of those involved in and affected
2. Perpetual Improvement Principle. The rule should encourage the
continued improvement of the organic craft of both producers and processors
of organic food. The rule should avoid freezing practices in place based on
current knowledge and research.
3. Flexibility-Within-Integrity Principle. The rule should embrace
diversity and simplicity to the full extent possible without eroding
consumer confidence or violating organic principles.
4. Equitable Fee Structure Principle. In all instances those who benefit
should pay. In general, the industry should continue to cover the costs of
certification. Provisions in the rule should strive to keep costs to a
minimum while providing adequate resources to insure credible certification.
Necessary costs imposed on growers, processors, the trade or taxpayers
should, as a basic goal, be shared equitably and in relation to the benefits
received from the costs imposed. USDA, working with public funds, should
bear the administrative costs of the accreditation process, and on an
ongoing basis, should collect and share data, and carry out and commission
independent analyses helpful in documenting the magnitude of direct and
indirect costs and benefits associated with OFPA implementation.
Charles Benbrook 208-263-5236
Benbrook Consulting Services 208-263-7342 (fax)
5085 Upper Pack River Road http://www.pmac.net/
Sandpoint, Idaho 83864
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