February 20, 1998
Action Alert: Proposed U.S. Organic Standards Need Total
U.S. and International Comments Requested
In mid-December 1997, the U.S. Department of Agriculture
(USDA) released its long-awaited proposed rule to implement
the Organic Foods Production Act (OFPA) of 1990 and to define
uniform national standards for organic production and
labeling. After working closely with USDA for seven years to
develop strong national standards, members of the organic
industry were outraged to discover that the Agency's proposed
rules would greatly weaken existing organic standards by
permitting toxic synthetic substances and a range of
practices and processes that are fundamentally incompatible
with organic agriculture. The USDA is now asking for comments
on its proposal. Due to strong public interest, the comment
period has been extended until April 30, 1998.
Along with the organic industry, many consumer, environmental
and other public interest organizations have also declared
the proposed regulations unacceptable. "The USDA's proposed
rule would erode consumer confidence in 'organic' by blurring
the distinction between organic and conventional production,"
said Monica Moore of Pesticide Action Network North America
Regional Center. Harry Snyder, Senior Advocate at Consumers
Union U.S., said, "The proposed regulations are strongly
anti-consumer because they label as 'organic' products which
are produced by means the public does not believe to be
organic. A government approved label that is misleading will
only increase skepticism about U.S. agriculture and the USDA,
and create distrust of our food supply."
Organic industry leaders and the public interest community
alike condemn USDA for ignoring the recommendations of the
National Organic Standards Board (NOSB), which was created by
the 1990 legislation to assist USDA in developing national
organic standards. The NOSB, which includes representatives
of consumer and environmental organizations as well as
industry representatives, worked closely with USDA and
organized hearings throughout the U.S. to develop its
recommendations. The NOSB recommendations are widely
considered to represent a strong consensus between the
organic industry and consumer and environmental concerns.
The USDA proposals depart from existing organic standards and
NOSB recommendations on numerous points, including but not
*Synthetic substances. USDA has proposed new terms and
criteria that could allow a wide range of synthetic
substances to be used in organic production, including
chemical pesticides and fertilizers, antibiotics and
* Use of toxic "inert" ingredients. The proposed rule
redefines and allows use of toxic chemicals used as "inerts."
This would essentially force certifiers to accept many toxic
products in organic production, including chloropicrin,
piperonyl butoxide, toluene and xylene.
* Genetically engineered organisms (GEOs). Due to their
synthetic nature and a wide range of concerns about potential
health, ecological and social impacts, no respected organic
certification in the world permits genetically engineered
organisms in organic production. Despite NOSB's clear
decision not to allow GEOs, USDA has reopened discussions
that could allow these materials.
* Ionizing radiation (also known as "irradiation"). USDA is
soliciting public comments regarding irradiation within
organic production, a process prohibited by credible organic
certifiers and rejected by NOSB. According to Physicians for
Social Responsibility, irradiation of food destroys vitamins
and damages beneficial fatty acids and is associated with
dangerous radioactive isotopes.
*Bio-solids. USDA is asking for comments regarding potential
allowance of municipal sludge (bio-solids) in organic
production, yet NOSB strongly recommends that because sewage
sludge contains residues of heavy metals and other toxins, it
should be considered "unacceptable for use in organic crop
Other problems with the USDA proposal noted by organic and
sustainable agriculture advocates include allowing up to 20%
non-organic feed in organic dairy operations; loopholes
allowing farmers to pack livestock into factory farm-style
facilities; and a prohibition on eco-labels that undermines
consumers' right to know.
PAN North America urges all those interested in organic
integrity and the future of sustainable agriculture to send
comments to USDA urging the Agency to withdraw its proposed
organic regulations and adopt the recommendations of the
NOSB, and commenting on topics covered by the regulations
that are of special concern to you. The more specific and
detailed your comments are, the more effective they will be.
Comments from both within and outside the U.S. are important
(information on how the proposed standards conflict with
standards of other countries, likely market impacts and
consumer reactions to lower U.S. organic standards elsewhere
are key topics for commenters outside the U.S.).
Send comments by mail, fax or the internet to Eileen S.
Stommes, Deputy Administrator, USDA-AMS-TM-NOP, Room 4007-S,
Ag Stop 0275, P.O. Box 96456, Washington, DC 20090-6456; fax
(202) 690-4632; web site www.ams.usda.gov/nop
Specify Docket #TMD-94-00-2 at the beginning of your
comments. The deadline for comments is April 30, 1998.
For a sample letter -- and a listing of resources about the
proposed organic rules -- visit PANNA's web site:
http://www.panna.org/panna/networking/nop.html. If you do not
have access to the web, send your request to
Sources: This article is based on comments and articles by a
wide range of sustainable agriculture and organic
organizations, including the National Campaign for
Sustainable Agriculture, National Coalition Against the
Misuse of Pesticides, California Certified Organic Farmers,
Organic Trade Association, Organic Farming Research
Foundation, Organic Materials Review Institute, Pure Food
Campaign, Californians for Pesticide Reform, Organic Farmers
Marketing Association, Mothers & Others for a Livable Planet
Pesticide Action Network North America (PANNA)
116 New Montgomery, #810, San Francisco, CA 94105
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