Thought some of you might find this interesting. Some points of
response to the NOP as formulated w/ the Pure Foods Alliance of MA
and the Natural Law Party of MA.
------- Forwarded Message Follows -------
Subject: Re: USDA's proposed redefinition of "organic"
Date: Mon, 29 Dec 1997 17:02:23 -0600
I meant to include this forwarded message in my last message, hope you find
The USDA's proposals cover a lot of ground, and while many of us are
mainly concerned about genetic engineering, I think it's important
not to ignore other salient issues in the proposals. So here's the
text of a message I've been sending out:
Suggestions for Responding to the USDA's Proposed Organic Standards
I'm encouraging people to address five points. If any of them are left
unresolved in the final regulations, many "orthodox organic" zealots like me
will be inclined to lobby Congress to reject the entire proposal.
For the next 90 days of public comment, the USDA is where all our energy on
this issue should be aimed--not at Congress, not at the President (all of
whom will become important *after* the 90-day comment period), but strongly
to the USDA. This is our only opportunity to influence the *content* of the
regulations. Once the regulations reach Congress and the President, the only
issue will be acceptance or rejection, so the following points need to be
1) Prohibit genetic engineering in every phase of the organic food
chain--not only GE seeds, but GE (or GE-derived) fertilizers or other
agricultural inputs, and foods produced from GE sources or using GE
processing agents or their derivatives (e.g., rennets, enzymes such as alpha
2) Irradiation should be prohibited under the organic label. It fosters
continued reliance on nuclear technologies in general, and simply doesn't fit
into the traditional organic orientation. It has been likened to genetic
engineering in its reputed ability to modify chemical structures in the food
it treats, particularly creating novel proteins, whose bioactivity is
completely unknown and unpredictable.
3) Use of municipal sewage sludge as organic fertilizer should be banned.
Quite aside from the human waste issue, organic accreditation boards have
decried sewage as contaminated with heavy metals such as cadmium and lead,
which are readily absorbed by many crops.
4) All organic livestock should receive feed which was grown and processed
without use of genetic engineering, irradiation, and municipal sewage sludge.
(This is particularly important to dairy consumers.)
5) The definition of organic should be determined by concensus among those
who have been growing, eating, selling, and promoting organic food over the
long term--not by industrial ambitions or popular vote. At a minimum,
organic implies *natural from start to finish*. Diluting the meaning of
organic is a crime against nature and a crime against consumers who have
demonstrated a burgeoning interest in organic products.
Respondents should emphasize the issue of "what constitutes organic," rather
than safety questions. The safety questions are irrespective of the organic
issue, and we should secure the integrity of the organic label first, and
*then* turn to the safety, etc., questions, if we wish--but for the entire
conventional food chain. Otherwise, if we emphasize safety at this point, we
invite the chemical (a.k.a. "biotech") industry to engage in a debate in
which by definition they should have no role to begin with. If we stick with
organic as a tradition and as a lifestyle choice, there's nothing for
them to debate.
Concerned citizens (including citizens of countries buying American products)
should multiply themselves as quickly as possible, providing their friends,
family, associates, health food stores and organic markets, cooperatives,
churches, associations, etc., to which they might belong--in brief, virtually
everyone they know--with the information needed for additional responses to
the USDA. If we can take Secretary Glickman at his word, the fate of the
aforementioned issues rests entirely in the hands of the public--for the
Responses can be made at the USDA web site (http://www.ams.usda.gov/nop), but
it's complicated-- requires making comments at exact locations within the 600
pages of the proposal. It's actually simpler to comment by letter, addressed
Eileen S. Stommes, Deputy Administrator
Ag. Stop 0275
P.O. Box 96456
Washington, DC 20090-6456
Whatever you do, and however you do it, please do it soon!
Pure Foods Alliance of Massachusetts
Natural Law Party of Massachusetts
Michele Gale-Sinex, communications manager
Center for Integrated Ag Systems
UW-Madison College of Ag and Life Sciences
Voice: (608) 262-8018 FAX: (608) 265-3020
Ain't no man can avoid being average, but there
ain't no man got to be common. --Satchel Paige
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