1. If foods and products produced abroad can label their foods as they wish
using happy terms like "pesticide free, free range, sustainably produced, and
natural/organic" without the New Organic Patrol (NOP) on their case, how do we
Comments: Under OFPA, any product proposed for importation to be labeled or
sold in the US must have been produced to standards of farming, handling and
certification equal or exceeding the USDA/NOP. Per the Organic Foods
Production Act of 1990, "providing market information concerning, an ag
product if such label or information implies, directly or indirectly, that
such product is produced and handled using organic methods" is illegal. This
is the part of OFPA to prevent exactly what you propose would be negative
above--the use of free range, sustainably produced, natural/organic, pesticide
2. How many thousands of consumers will bail out on us because of the USDA's
involvement with the word Organic? Charles Walters at Acres USA called it a
dilution of the meaning of the word. A lot of us have worked hard to have the
word impart a sense of well-being and trust in our marketplace. Does anyone
have any insights on the NOP and consumer confidence?
Comments: Organic consumers know what they want to buy--food produced without
synthetic or toxic substances. If the USDA/NOP is not going to guarantee
that, they will turn to other sources. At this point, consumer and organic
farmer knowledge of what the Proposed Rule says is only becoming understood.
The USDA/NOP proposal is outrageous arrogant, inconsistent with both domestic
and international buyers perception of "organic" and illegal under OFPA. Even
though the USDA Office of General Counsel and the USDA/NOP staff act
completely self confident of the legal basis for their Proposed Rule, the
Secretary, Assistant Secretary for Ag Marketing and Regulatory Services and
Administrator of the Ag Marketing Service I propose have no idea how
inconsistent the Proposed Rule is with OFPA. That is why there is a public
comment period. However, one problem with commenting is the immense amount of
material a commenter must cover to get a good picture of what is being said in
the Proposed Rule and what OFPA says. http://www.iquest.net/ofma/ offers some
OFPA guarantees the highest standard in the world for "organically produced"
products. What has happened with publication of the Proposed Rule is a small
cadre of National Organic Program Staff, inexperienced in organic standards
for farming and handling and organic certification practices and systems, have
been let lose to express their inclinations, opinions along with their
predilections for increasing the market for "organic" products, which means
not following the OFPA standards but proposing new standards not support by
organic farmers or customers. They have also been unduly influenced by
processors/marketers and FDA in the livestock section. The NOP staff did
stand up for organic principals in GMOs against OMB, for not allowing sewage
sledge against EPA, for not allowing irradiation against FDA. The actual
Proposed Rules compromises struck to get the Proposed Rule out for public
comment were the two instances of proposing the use of GMOs: those being in
organic farming (toxins derived from Bts) and handling operations (chymosin as
a rennet). In fact, the USDA/NOP staff was successful in having irradiation
and sewage sludge not put in the actual Proposed Rule, but put in as request
for public comment.
3.My fields produce organic vegetables that are used in the production of a
very popular brand of organically produced salsa and marinara sauces. These
products have a large following in Europe. Because of the involvement of USDA
in the word organic and the consequential dilution of it's meaning, Will my
clients have to produce their products outside of our country to maintain
their labelling that uses the words "pesticide free and organically produced"
Comment: It is up to each individual country to decide how products sold in
their country are labeled. Exported products labeling is not controlled by US
labeling laws. Only if a product is labeled for sale or sold in the US does a
business have to conform to US law. Therefore, pesticide free, even
"organically produced" can be put on any product for export and as long as it
is not sold in the US, with impunity. The final judgement is not in on
whether the Final Rule will be a dilluted or meaningless standard. The public
has only begun to speak. If the Final Rule dilluted or meaningless, customers
will assert themselves to find healthy products.
4. My fields are too small to compete with what I see as a new type of factory
farm being hatched. I'm sure this forum is no place to cry about lost love.
But does anyone with a relationship with the word organic hear their hearts
breaking? My salutation has always been Organically yours, however I think
I'll try this new one. Living on crumbs,..
Comment: Yes, our hearts break, but we know that is nothing new after 20 years
being told we will starve the world and are unscientific. I know very few
organic farmers who will not fight for what they know by experience to be
correct. Take crumbs if you want, but there is no blame for failure until one
goes to work to correct what is illegitimate. The Proposed Rule is now open
to public comment and public actions, not the least being Congressional
investigation how an agency of government can propose a Rule inconsistent with
an Act of Congress. If citizens feel powerless, look around. There are many
approaches in the US to correct overzealous bureaucratic staff, not the least
being cutting appropriations for the National Organic Program, class action
suits and the Regulatory Fairness Act of 1994.
Donald W. Trotter Ph.D. The Organic Gardener's Resource Centre voice
1.888.514.4004 fax 00.760.632.8175 Email email@example.com or firstname.lastname@example.org
Donald Trotter The Organic Resource Centre 293 Neptune Ave. Encinitas, CA.
92024 email@example.com 1.888.514.4004 fax- 760.632.8175
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