On Tue, 16 Dec 1997, Michele Gale-Sinex/CIAS, UW-Madison wrote:
> I also came in this a.m. to a note from Craig Cramer about something
> else, with a mention that there is an organic certification list
> server that Larry London moderates.
It's not a moderated mailing list. I just started the list and am list
owner; I'd be glad to set up another person as co-owner
to help manage it if anyone would like to do this.
> Can someone send me sub info pronto and copy it to the group? I've
> asked Cramer for enough this semester.
Here it is - please let me know if you need help subscribing.
If you want to subscribe, send mail to
with the following request:
subscribe ORGANIC-CERTIFICATION <Your_e-mail_address> as given in your
Rose & Fred Lieberman wrote:
> Hi, folks. My name is Rose Lieberman and I'm an organic farmer in
> Upstate New York. I'm new at it, but I have some opinions.
> 1. I don't like people telling me what to do. So, already I'm
> in trouble, I guess.
There are a lot more of us that feel the same way.
> 2. If we don't get certified, can we use the term "organic"?
According to the federal Organic Foods Production Act of 1990 (OFPA),
which has not taken effect yet and whose text is unfortunately NOT an
issue in so far as the Rules now subject to debate, YOU CAN NOT! This
is the major problem with OFPA, which is scheduled to take effect after
the Rules are defined in March of 1998.
> 3. Why doesn't the USDA give the certifying process over to the
> Cooperative Extension? They've had a relationship for a long time.
> The staff is already there and would probably love to get back out
> into the field which, by the way, has been diminishing over these past > few decades.
OFPA doesn't contemplate that and as stated by others, this would not
necessarily resolve the problem.
> 4. Why not "verify"? Why do we have to "certify"? I have a
> 50-lb bag of "Verified Organic" whole wheat flour sittin' in my
> cupboard. I don't know, but it sounds like organic to me.
There are some third party certifying groups that have the word verified
in their name (i.e. "Farm Verified Organic - FVO). OFPA requires these
certifiers to become registered and adhere to the federal standars.
This may not be bad but as stated, certification is mandatory in order
employ the word organic. And THAT is bad for a number of reasons that
have been discussed here and on other lists earlier, some of which I'm
pasting in below.
> 5. There is really no significant business benefit in the form
> of profits to going organic. So many groups could care less. As long
> as the produce looks good and isn't sprayed with anything illegal,
> there doesn't seem to be a problem. Just ask any restauranteur or
>From my experience, most distribributors and buyers of strictly organic
products WILL ask who certified it and do accept certifications done
only by certain certifiers. But this is something best left between
buyer and seller.
> 6. I really dislike someone coming to my farm, not being able to
> take my word, take a few samples, walk away, and bill me for what I
> feel is an exhorbitant fee.
That IS offensive, but that (and a lot more) is what OFPA will require,
in order for you to be able to use the word "organic". Of course some
believe that this is how the world is now. But I'm certainly not one of
> My bottom line is: If we have to, then I say give it to the coop ext
> agents. They have the manpower, the knowledge, the relationship with
> USDA, and the connection to major universities.
That's a respectable and well founded opinion Rose (even if not
extentionists are equal), but it's not what OFPA mandates. And OFPA's
going to cause serious problems for a lot more honest people than
dishonest ones. Not only that, some dishonest people (morally
dishonest, if not actually legally so), are going to be able to take
advantage of OFPA for their own gain.
"Re the Organic Standards Proposed Rule. The full text of the rule will
be available on the Web at the AMS web site at following URL:
No date is given but: [It was posted Dec. 16 & is downloadable either in
text or acrobat (.pdf) form. There are 2 separate files - the one
publish in the federal register and the complete proposed rule].
" The proposed rule will be published in the Dec. 16 Federal Register.
Comments must be received by March 16, 1998. Interested persons are
invited to submit written comments to: Eileen S. Stommes, Deputy
Administrator, Agricultural Marketing Service, USDA, Room 4007-S, Ag
Stop 0275, P.O. Box 96456, Washington, DC 20090-6456. Comments also may
be sent by FAX to (202) 690-4632 or via the Internet through the
National Organic Program homepage:
Unfortunately, the major defects reside in OFPA itself, which is NOT
open to debate. That is, neither a debate NOR OFPA's GLARING and DEEP
SEATED DEFECTS were fully contemplated. HOWEVER, if enough adverse and
pointed commentary is presented in a serious and responsible manner,
that plus the steady threat of court action if these faults are not
addressed, may do the job.
OFPA's defects are real, present and significant. And if no adequate
response is achieved, the threatened court action will become in fact
the last line of defense for the word organic, before taking to the
hills of alternative labels, leaving the hogs to sit on their (by then
hollow & wormy) prize "o" word.
If that happens, as stated previously, I kind of like the SERA concept
(the verb WILL BE in spanish) an acronym representing "Socially and
Ecologically Responsible Agriculture" and I've written a little text
for public consumption about the reasons for doing this, but we're
certainly not at the point where that's needed yet, nor do I have it in
a final state, and OFPA can still be re-evaluated and modified. Good
reasons for doing so abound!
[Regarding alternative labels, other than organic]
Steve Moore wrote:
From: Douglas M. Hinds [SMTP:firstname.lastname@example.org]
Sent: Thursday, December 11, 1997 7:50 AM
Subject: [Fwd: Directory of Label Groups is being Compiled]
This is the upshot of making organic certification compulsory.
Organic certification looses it's meaning, the compulsory aspects
- and the corresponding exclusivity of the "O word" for private
interests will be overturned by the courts, diversity reigns and
the organic insider power elite becomes shrill, fangless and lonely.
That's the future as I see it, if OFPA takes effect as it is
But meanwhile, too many people will be needlessly hurt and sustainable
agricultural practices are not getting the support they deserve from
government. That could be changed, but it will take more than a
little commitment and some degree of work on the part of many to
make it happen. How many of you are game, in principle? Then all we
need to do is determine which points and tactics we agree on, in order
to consolidate a defined movement. And it doesn't take many to start.
It takes a clear idea and a coordinated effort.
[Steve Moore's reply......]
The Pure Food Campaign seems to be one group which is already up and
running with an organized effort to oppose USDA's folly. Their web
site can be viewed at:
Good Points, Steve. But looking at this in a cold, hard, practical
light; although I agree that these coincidences appear to justify
developing a formal collaborative effort, I'd seen an article of theirs
to that effect months ago and after e-mailing several of those mentioned
in it or linked to it received no reply. Also, as an organization
connected to Jeremy Rifkin, who's radical approach and publicity
oriented tactics are not credible with many - even in those instances
where he supports valid points, like in the area of GE organisms (which
they claim are going to be allowed into the organic market under OFPA
and that the USDA is in collusion w/ big business to that effect;)
causes many of those we'd like to attract to reserve judgment and stand
There may be some real truth to their claim - but it's probably founded
on relationships that exist mainly because the facts have not been well
documented yet and the "collusion" is not all that intentional.
Established authorities, whether governmental or in commerce, tend to
get the benefit of the doubt in the eyes of many, particularly in the
U.S., and the same was true for the organic movement years back and
explains why the organic movement itself has remained divided and
contradictory. After all, how long did it take for the harmful effects
of tobacco use to become recognized by the Surgeon General and after
that, banned in public places?
I believe we need a better centered, broader based and more focused
effort that we'll have develop ourselves and collaborate with any and
all who share that view, rather than rely on any other group,
particularly when that view involves elements that have negative
connotations for many responsible (if less committed) people. We can
develop criteria and disseminate it freely. My own positions on some
issues are apparently farther out than most people - even those in sanet
- can identify with, probably because they haven't had any appreciable
degree of direct experience with those issues and are unlikely to do, as
long as they keep plodding on down the same, safe mainstream course.
(Taking a step back, perhaps I detect a touch of bitterness in that
statement of mine).
In short, I believe that the next logical step should be to discuss and
(attempt agree on - or at least) subject to peer review the points we
want to raise (whether collectively, in coordination or separately),
limit ourselves to those points (except where personal or group agendas
are truly different), using similar and in many cases shared arguments
and data, identify the channels through which opinions should be
directed in order for them to be most effective, in relation to our
goals (which should also be defined and discussed, in relation to
In that sense, I see these aspects of OFPA as being most flagrant, each
of which can obviously be amplified on - preferably in a precise &
concise way - remembering that the goal is to make our joint or related
proposal(s) assailable and to attract widespread and /or well informed,
credible support. Beginning with those aspects that may be the least
controversial (the order itself is subject to comment and change):
1).- OFPA's Small Farm Exemption is ten times too small.
2).- Rather than provide incentives to farm using non contaminating
agricultural technology, OFPA does the opposite - it makes farming
organically more expensive, both due to the fees involved and introduces
added (and unnecessary) layers of bureaucracy. While it may be said
that OFPA will provide a doorway to the "lucrative" organic market for
"legitimate" (i.e. those that comply with OFPA as presently written),
this simply makes organic foods themselves less competitive and is
counter productive as a whole to the goals of a cleaner environment and
healthier food for all.
3).- Organic certification should not and can not be compulsory.
Restricting use of the word "organic" to those products that comply with
OFPA as presently written (i.e. "CERTIFIED organic" only), does not
protect the true organic farmer because the certification procedure
itself was never infallible, nor will not be so under OFPA. Instead of
providing a consistent, minimum definition at the national level for
organic foods (which could be enforced in the same way that ANY product
is already subject to existing truth in advertising laws), it simply
creates further opportunity for increased abuse and additionally, is
both unjust and almost certainly, unconstitutional.
The potential for abuse stems from the still inherently discretional
aspects of the certification procedure (although this may be made more
objective than before in some cases), due to the greatly increased
degree of complication certification will involve and above all, the
privileged position some self styled champions of organic agriculture
have obtained through personal contacts within the USDA (and who in fact
have used public funds to further their own efforts to corner the
organic market; that is, to develop a private marketing entity), and who
are now ready to "help" (even long time) organic growers become
certified under the intricate new standards, obviously at an increased
cost to both farmer and consumer. [This statement may well need a
little cleaning up - but it's true].
The unconstitutional aspects are derived from OFPA's infringement on the
farmer's and/or distributor's right to inform the public regarding
information pertinent to the nature of the product and the buyer's
right to be informed, the fact that the word organic represents the only
word that at present embodies a high degree of consumer recognition and
is therefore an asset which was created at the expense of many true
organic farmers who may or may not choose to certify their product as
per OFPA; and the fact that the nature and meaning of any word lies in
it's prior use, a use that in this case is not directly related to the
conditions of obligatory certification that OFPA pretends to impose.
OFPA in effect, attempts to alter via legislation and in an arbitrary
and contradictory manner, the significance of a word who's meaning and
market value are already well established, to the detriment of many
affected organic (and would be organic) farmer's whose right to earn a
livelihood in his manner of choice will be compromised.
4).- OFPA neglects to call for the additional research that is needed in
order to quantify the damage being done to the environment by needlessly
applied agrochemicals. Comparative studies that take into account the
true economic, environmental and social costs of alternative vs.
conventional farming methods (including energy consumption) are not
receiving at present the priority they deserve. Likewise, no commitment
by Congress was made to act on the results of such findings (i.e.
legislate in a congruent manner), once available. In short, the law
went needlessly too far in one area, while completely neglecting a much
more important and far reaching one.
Steve Moore wrote:
Regarding your list of specific issues:
1).- OFPA's Small Farm Exemption is ten times too small.
> It seems to me that $50,000 is just as arbitrary as $5,000 or
> $500,000. I think the more important issue is the nature of the
> market. I would suggest redirecting the "small farm exemption" to a
> "direct to consumer exemption", i.e., CSA, farmer's market, roadside
> stand, and possibly mail order. There are numerous examples of direct
> to consumer exemptions in USDA marketing orders. The point being
> that there is no need for USDA to intervene in a transaction made
> directly (face-to-face) between the farmer and the consumer.
I completely agree with your last sentence but don't think CSA is the
only reason not to certify. I think certification is something that
should be left for each to choose and not made obligatory, and that the
existing truth in advertising laws would be adequate, once consistent,
minimum national standards are set for organic products. I don't think
laws can take words out of their native contexts and reserve them for
the use of the privileged few (even if they're good ole boys from
Arkansas who know a highly placed USDA official who's in good with Mr.
Bill), and I don't think that organic certification is or ever will be
as authentic as some would have us believe. Nor do I think that the
certifiers necessarily know any more about it than some of us who just
prefer to grow that way for our own reasons and aren't so interested in
serving ourselves with the big spoon (that comes from a spanish phrase,
but I think it makes the point).
In other words, I think certifiers are often high priests that help keep
organic foods expensive and out of reach (or impractical) for the vast
majority. The market itself (and I'm not necessarily talking about the
coventional commercail market - the co-ops are an important and growing
force here too), will determine most of what needs to be done, and the
relationship is mainly between buyer and seller, unless there's fraud
involved. And there can be increased penalties for that, which can be
based either in statutes or in contracts between the provider and
receiver. Otherwise, you and I agree.
People want live, healthy, uncontaminated food. But "organic" as a word
may be dead if OFPA is implemented as now written. (That happens a lot
to those that are kidnapped. And remember what happened to Gorbachov
after being kidnapped - he lost his following). It's not a good idea to
let yourself be put in a legal straight jacket or concentration camp.
It's better to go down fighting, take to the hills, use a different
label and / or pursue the court action that will be both needed and
> 2). Disincentive for organic. concur.
> 3) Compulsory certification. I concur with your concern about this
> issue, but found your argument a little convoluted. Seems like this
> needs some work, as you already note.
So help me clean it up. Or maybe I'M convoluted. My brain sure is (as
all brains are). And I don't get much sleep lately.
> 4) Lack of research support. This is an important issue, but I
> don't think opposition to USDA's rules and OFPA in general will get
> very far on this issue. The law overlooks the problem, but "so what".
> I can imagine proponents of OFPA will concur and simply say pass
> another law.
They could. But the point is that the wrong priorities took effect.
The focus was shallow from the start. The petty issues took precedence
over the major ones, which helps justify opening up OFPA and the whole
can of worms again, which is what the organic marketing people are
fighting. (Even your CSA exemption would require amending OFPA, simce
it's not related to the rule and the rule is the order of the day in the
meetings scheduled and the commentary that will be received). But I
think the USDA has no real ax to grind here. They don't really want to
appear to be favoring what WE know are mercenaries at heart. They think
a certain person really IS mr.organic (and he does kind of look like
it, what with his overalls and all. Too bad he sold out. Of course
Pancho Villa would just cut the tops of his ears off). I think the
more scandalous and earth shaking effects of OFPA must be brought our
and stressed in order to get the Act amended. And those elements are
> The upshot of the meetings of our local farmers group is to continue
> to meet and focus on reviewing the USDA rules now that they are
> public. Some of us will be attending the Eco-Farm Conference at
> Asilomar in January and hope to broaden the base of our coalition
Good deal. It sounds like the California group's got it together.
Nothing really revolutionary, but competent enough. How about a little
more reactions from some of the rest? Sitting on any eggs?
We still need dates and places for those regional meeting where the
interventions will be put on record.
Douglas M. Hinds, Director General Centro para el Desarrollo Comunitario y Rural A.C. (CeDeCoR) (Center for Community and Rural Development) - (non profit) Cd. Guzman, Jalisco 49000 MEXICO Tel. & Fax: 011 523 412 6308 (direct) e-mail: email@example.com, firstname.lastname@example.org, email@example.com
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