Your observations are timely and though provoking. Comments on a few of your
points follow with a grass roots remedy to the USDA outrage.
<< These new regulations were not produced by the agency that was created to
eak: The NOSB was not delegated to perfect the Rules under OFPA. They were to
offer Recommendations for implementing OFPA and were mandated under OFPA to be
the first point of consideration of substances for the National List process.
In 1992, the USDA formed an advisory board to write these rules,
>The National Organic Standards Board. The NOSB met for years, did their job,
>and made a complete set of recommendations to the USDA that were acceptable
>to growers, processors and consumers.
Eak: This statement is not wholly correct. The NOSB Recommendations to the
Secretary of Agriculture, in violation of OFPA, included
-Allowing the use of synthetic substances in "organically produced" processed
foods as processing aids, food additives, colorings, flavorings and
-Allowing the use of active synthetic substances in organic crop production
that were not allowed.
-Allowing the use of synthetic inert substances in organic crop production
without proper petition, review and evaluation.
-Allowing the use of active synthetic substances in the feed of "organically
produced" meat, eggs and dairy products.
-Allowing the use of active synthetic substances as medical treatments in
livestock and the selling of such products as "organically produced" meat,
eggs and dairy products.
-Allowing the feeding of dairy animals for only 3 months "organically
produced" feed prior to selling milk or milk products as "organically
-Allowing processors to handle, package, process or store, "organically
produced" products without having the system utilized in doing so certified as
-Allowed the confinement of mammalian livestock and poultry without access to
-Not providing a methodology for the public to secure and see certification
documents and residue testing on specific farms and handling operations
producing "organically produced" food and fiber products.
-Not following the National List petition, review and evaluation criteria and
The USDA ignored the work of the NOSB
>and promulgated their own set of rules instead. >>
eak: The reading of the record indicates the USDA indeed did go much further
in violation of OFPA than the NOSB. However, in many cases the basis for the
USDA's deviations are the NOSB recommendations or non-recommendation. The
NOSB Recommendations have been used as the springboard for the USDA's "own set
of rules." In particular, regarding livestock healthcare standards, non-
certification of handling operations, synthetic substances in processed foods,
as inerts and in crop production, the NOSB set the format and tone that
allowed the USDA to introduce all manners of substances and categories of
>> There must be a story here, about how the interests that stand to gain,
>whoever they are, were able to re-write the rules that were already drafted
>by the NOSB, and get the USDA to promulgate them, in the face of all the
>contributions already made by the organic industry and the expectations of
>the American public.
eak: There is a story here, a very interesting story of how appointees by the
government of unqualified individuals destroy the credibility of the process.
Firstly, President Bush appointed the original NOSB contrary to the Senate
Committee Report's advice. "The Secretary appoints the members of the Board.
Prior to full implementation of the organic standards in September 1992, the
Committee recommends that the Secretary appoint farmers who have operated
organic farms under existing state or private standards. Such farmers will
have the insight and knowledge necessary to guide the Secretary in
implementing the title." Instead of appointing experienced farmers as an
interim Board, special interests and those with contacts in the Republican
administration were selected and seated.
And than as appointees terms were completed, many new appointees have been
selected based on a criteria of who one knows, what economic clout one has,
not on documented experience regarding the matters the Board is responsible to
Secondly, under the Clinton administration California appointee, Lon Hatamiya
(the former administrator of the Agricultural Marketing Service) the USDA
National Organic Program staff has never been lead by anyone possessing
expertise in organic farming, handling or certification. Simply, it has been
the blind leading the blind, while qualified participants watched off the
field. But a change has now occurred. Another administration appointee
originally from California has replaced Lon who has now become the USDA Under
Secretary for International Affairs. Enrique Figueroa is now the
Administrator of AMS and the National Organic Program. His first act
regarding the NOP has been the appointment of Keith Jones, perhaps the most
highly qualified administrative level person in the country regarding organic
programs, standards and certification.
The individuals and their organizational representatives that developed
organic farming, handling and certification have never had up to now and
presently do not have any positions of persuasion and decision making in the
National Organic Program process. How did this occur? This is symptomatic of
government run by politics, not criteria and qualifications. For a quality
National Organic Program, the situation must be reversed. The appointment of
Keith Jones is a quality first step. Now, it is imperative we, the citizens
take the following steps:
1. A call by all of us on our Representatives and Senators for a Congressional
investigatory hearing on how 3 million dollars, 5 years and tens of thousands
of volunteer organic farmer, handler, certifier and consumer hours can be
contributed to bring out a Proposed Organic Rule that is in stark violation of
an Act of Congress. It is time the USDA administration at the top and the NOP
staff faces the music. Answers are needed to prevent a repetition.
2. A call by all of us on our Representatives and Senators to contact USDA/AMS
and demand a new Proposed Organic Rule consistent with OFPA to be submitted
for public examination and comment by September 1, 1998. This is perfectly
doable. Start deleting in a computer the inappropriate sections, explain the
OFPA National List Process and change the fee structure to "be reasonable."
Hire a qualified consultant for less than $10,000 and get it done in 30 days.
Nothing short of this grass roots, massive public advocacy action will change
the Proposed Rule and make it consistent with the organic consumers perception
and the certified organic farmers commitment.
The USDA National Organic Program can be all we need and desire it to be, but
only if citizens decide to be part of the democracy and take to the phone,
fax, email and meeting with our Congressional Representatives and their staff.
Do we need a national referendum on what actions to take or can we
individually and organizationally understand that change in government only
occurs in a democracy when we individually advocate our position consistently,
with valid reason and reasoning and strongly. Certainly, we have no better
reason to speak up to our political representatives than in what we believe
in. It is time to do so now, individually and in-groups.
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