This former Oklahoma farm laborer and retired Navy man has been following
the little side debates here regarding the NOP and USDA Rules for a while
without commenting. But I think it may be time for me to enter my two cents
worth. Read the following comments by Douglas Johnson and then see my
response below.
Douglas writes:
>A day or two ago, I posted a note that said the USDA NOP standards will
>only set a new minimum that many entrepreneurial farmers and processors
>will soon choose to exceed. Craig Cramer then shared a website in which FVO
>announced there intent to exceed government standards. For those of you so
>inclined to review academic literature on how firms behave with regards to
>standards, here is an abstract of a recent publication on how firms respond
>to the establishment of minimum standards.
>
>--- begin forwarded text
>
>"An Empirical Investigation of Firms' Responses to Minimum
> Standards Regulations"
>
> BY: TASNEEM CHIPTY
> Ohio State University
> ANN DRYDEN WITTE
> Wellesley College
>
> Paper ID: NBER Working Paper No. 6104
> Date: 1997
<snip>
I cut the rest of it off in the interest of brevity. All of you sanwe it
in the original post.
Let me state here and now: this is not meant to be an attack on Douglas or
what he had to say. Read on.
First, we have at least two representatives from the USDA saying that the
new rules will allow existing and future certifying agencies (who becoem
registered) to continue to set standards that are higher than the "minimum"
set by the USDA rules. Then we have a few saying it is their intent to do
so. NOW we have a University study that says when standards are set low,
many companies will exceed those standards.
Did I miss something along the way? Did Congress suddenly change the law?
The way I read it, USDA cannot permit anyone; certifying organization,
farmer, procesor, or retailer, to do anything of the sort. The law
specifically forbids any establishment of any higher standards. It forbids
any use of words or phrases on the labels of products which state or imply
that a product exceeds the established standards. How can the USDA say they
will permit something the law specifically forbids?
And how can any company get away with violating that law? Is the
government going to ignore the law and allow these companiers to violate it
with impunity? What is going to happen when sellors who choose NOT to
exceed the standards file complaints against thsoe who ar violating the law?
And this old country boy has been to two or three goat ropins, a rodeo or
two, and I even was allowed to go around the block by myself just this last
week. I don' thave ten sets of initials to go behind my name, but I know
enough to realize that the quoted university study is pure male bovine
excrement. Oh sure, one or two companies may try to exceed the standards and
put out a quality product for a few months. But they will not and cannot
survive exccept as a small company filling a niche market. That is because
98% of the competition will be selling a product that just meets the minimum
standard but claiming to be just as good as the high priced brand.
It has happened in just about every industry that has been heavily
regulated by the federal government from telephone companies to airlines,
and a whole lot more.
I have noticed that the USDA reps have been relatively careful and have
been telling the truth. I have not seen the whole truth yet, from either
side. A lot has ben left unsaid.
`Course I suppose the law can be ignored. IMO it would not be the first
time a federal government agency ignored a law.
Disclaimer:
The above is my personal opinion, not intended to be taken as fact. Do
your own research and reach your own conclusions.
--Dan in Sunny Puerto Rico--
--dan.worley@icepr.com--
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