Organic Farmers Marketing Association,
8364 S SR 39, Clayton, IN 46118
317-539-6935, (phone/fax), firstname.lastname@example.org
National Coalition Against the Misuse of Pesticides,
701 E Street, Washington, DC 20003,
202-543-5450, (fax) 202-543-4791, email@example.com
FOR IMMEDIATE RELEASE
Contact: Cissy Bowman, OFMA
Jay Feldman, NCAMP
USDA's Proposed National Organic Rule Could Destroy Consumer Confidence,
The Organic Marketplace and the Organic Family Farm
WASHINGTON, DC (December 23, 1997) - The U.S. Department of Agriculture's
(USDA) National Organic Program Proposed Rule is currently under review by the
Organic Farmers Marketing Association and the National Coalition Against the
Misuse of Pesticides. Severe discrepancies exist between the Organic Foods
Production Act of 1990 and the National Organic Program Proposed Rule released
for public comment December 16, 1997.
The organic production and distribution community, which now encompasses a
multitude of small to moderate size private enterprises, has grown at a rate
of 23% per year for the last 5 years without any government support or
encouragement and is now a 3.5 billion dollar industry.
Demand is skyrocketing because organic farming stands for respect of the
environment, acknowledges the consumer-producer partnership, provides for
humane care of livestock and protects the farmers and farm workers who put
food on our tables and clothes on our backs.
There were some positive proposals in the Rule such as the inclusion of
organic fibers as a production sector and the process for establishing
equivalency of foreign organic certification programs. But those attributes
do not diminish the error of a Proposed Rule with little substantive content
on, or guidelines for, organic farming and handling operation plans and such
basic organic farming necessities like legume based crop rotations.
The rapidly expanding community of organic farmers, consumers, certification
agents and handlers have expressed shock and horror upon reading the USDA's
Proposed Organic Rules.
The USDA's Proposed Organic Rule violates:
· the general prohibition on the use of synthetic substances in organic
farming and handling mandated in the Organic Foods Production Act. Proposing
the use of toxins derived from GMO modified bacteria, Piperonyl butoxide, (a
toxic synergist), amino acids used as growth promoters, antibiotics used as
pesticides, synthetic animal drugs and other animal health care substances,
synthetic and genetically modified food additives and processing aids are all
radical deviations from the original Congressional act.
· the authority and role of the National Organic Standards Board's
responsibilities and powers to limit USDA consideration of allowed and
· OFPA requirements by allowing synthetic substances in organic farming that
can not be considered for use under the National List procedures. The
National List procedure only allows for the consideration of synthetic
substances in 10 specific categories. Consideration of such substances are
subject to technical and scientific, health and environmental review and
· the OFPA requirement to review and evaluate all pesticide product
ingredients in botanical pesticides, including undisclosed inert but toxic
substances. The Proposal allows synthetic inert ingredients to be used on
organic farms without review for toxicological concern that includes EPA List
2, Potentially Toxic Inerts and EPA List 3, Inerts of Unknown Toxicity.
· the Act by proposing new criteria that would allow wide use of synthetic
substances in organic foods. The new criteria and definitions proposed by
USDA are "non-synthetic", "extraneous additives", "unintentional additives",
"incidental additive", "synthetic amino acid additives", "inconsequential
additives", "non-active residue", "non-agricultural ingredient", "non-organic
agricultural ingredient or product", "active ingredient in any other input
other than pesticide formulations."
· the clear prohibition of using synthetic substances in processed organic
foods. The Proposal creates new illegal categories in the National List to
allow synthetic processing aids, food additives, enzymes and Genetically
Modified Organisms. The National List process calls only for consideration of
non-synthetic, but not organically produced ingredients up to 5% in processed
foods labeled organically produced.
· the National List procedures by opening for public consideration the use of
"ionizing radiation," "biosolids" (sewage sludge) and Genetically Engineered
Organisms in organic farming and handling.
· the prohibition against use of synthetic medicines, antibiotics and
paraciticides from birth for livestock, poultry and dairy animals whose
products are sold as "organically produced," if the synthetic substances are
not on the National List.
· the requirement of feeding only organically produced feed to livestock
raised for "organically produced" meat, dairy and egg production.
· the requirement of feeding dairy animals organically produced feed for 12
months prior to producing milk and dairy products labeled as organic.
· the organic standards of providing organically raised livestock adequate
space for movement and access to the outdoors.
· the legislative language and intent by proposing reliance on residue testing
for synthetic substances rather than conforming to OFPA, which prohibits any
use of synthetic substances that are not on the National List.
· the exemption granted when using the term "made with (certain) organic
ingredients" for processed food from all requirements of the Act. Small
businesses choosing to enter organic processing using only a limited number of
organic ingredients are unduly burdened by such a Proposal. Under the Act,
products using the label language "made with (certain) organic ingredients" do
not have to be processed, packaged or stored by a certified organic handling
· the requirement for the certification of all handling operations that
contract to process, package and store certified organic products by
illegitimately proposing to exempt those handling operations that work for no
more than three certified operations.
· the requirement to certify all handling operations, including restaurants
and retail establishments, that process products and sell them as "organically
produced," by proposing to provide an exemption from certification for these
operations. Processing, as defined in OFPA, includes all the normal culinary
arts, food manufacturing and packaging.
· OFPA by creating a new category of certification, the "certified facility."
The language and intent of OFPA requires that farms and handling operations
can be certified as utilizing a system of organic farming or handling. In the
Proposed Rule, USDA is proposing to accept perpetual and intensive confinement
livestock operations as an organic "certified facility."
· the intent and spirit of the Act to encourage and promote organic family
farming and small businesses by proposing excessive fees and by promulgating a
Proposed Rule wildly out of conformance to OFPA. The Act describes not just a
system of farming and handling, but incorporates progressive concepts
providing for the institutionalization of a public/private partnership based
on mutual respect. The National Organic Program will receive virtually all
its income from organic farmers, handlers and certifiers it serves and will
not receive substantial annual operating appropriations from Congress. The
NOSB needs to have oversight powers on spending and efficiency in the future.
Jay Feldman Executive Director of National Coalition Against the Misuse of
Pesticide, an organization representing consumers, farmers, environmentalists
and labor, called the USDA proposal "a disappointing effort that will have the
effect of undermining organic farming practices, environmental protection and
consumer support for the organic label in the market place. Rewriting this
Rule to conform to the Organic Foods Production Act is of critical importance
to all those concerned about pesticide contamination and poisoning,
environmental protection and safe food."
Cissy Bowman, certified organic farmer and Secretary of OFMA said, "If the
proposed Rule is adopted I will feel that the organic label will be terribly
misleading and I will be selling the public a false bill of goods.
Implementing the Proposed Organic Rule as is, without radically rewriting it
so that it conforms to the OFPA, will result in the devastation of consumer
trust in the term organic. In response to this deplorable organic Rule,
consumers and organic farmers must form a solid, active and unyielding
coalition to implement OFPA properly."
There is 90 days for the public to provide email, postal or fax comment.
Copies of the December 16, 1997 Federal Register contain the Proposed Rule,
frequently available at public libraries. The Proposed Organic Rule can be
bought by calling 202-512-1800 or it can be accessed at www.ams.usda.gov/nop
The Organic Farmers Marketing Association is now preparing a side by side
comparison of the Proposed Rule with the Organic Foods Production Act. Copies
of the Proposed Rule, side by side and other relevant papers are available on
the OFMA website at http://www.iquest.net/ofma/sdbysd.htm
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