>>> owner-sanet-mg@ces.ncsu.edu@i 03/12/98 06:59pm >>>
Dear Sanet readers:
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.
SNIP---
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.
GG: I don't know what representative from USDA would have said this.
It certainly wasn't me. Please reread what I said and see if you got it
right.
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?
GG: You are quite correct, the law is pretty clear on this point, and
this is what we have been saying all along.
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?
GG: The proposed rule is pretty clear on this. Accreditation will not be
granted to any organization that violates the law.
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.
GG: Watch out for the confusion between individual producers or
handlers making production claims that exceed USDA standards (which
is fine as long as it's truthful), and certifiers claiming to be certifying to
different standards, which will not be permitted. Also try to understand
the distinction between certification (of farmers and handlers) and
accreditation (of certifiers). There is no process for registration in this
program.
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.
GG: Thank you. The proposed rule contains as close to the whole truth
as we could make it. I'm sure everyone agrees that it shouldn't have
been any longer.
`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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