In response to your short comments on what Patricia Dines had to say, here
are a few short comments of my own.
>GG: If one were to probe that position of being "against the rules," I
>think you would find that the understanding of what they were in fact
>opposing was quite different for many commenters (at least the ones
>I've read and listened to thus far). So, the simple "yes" or "no" question
>does not reveal the amount of confusion and internal contradiction
>within the community.
There indeed may be some limited confusion amopnf members of the organic
community. And there certainly is a lot of differences between members on
many specific details of the proposed rules. But most of those differences
are in degree. Each individual and each group have their own priorities
list and will of course, compose their comments in accordance with that list
of priorities. So there wil be differences in the comments. But in
general, the entire organic community is in agreement on a significant
number of objections to specific items in the proposed rules.
An example I can give is on the subject of Irradiation. I personally am
not apposed to the use of irradiation in food processing for market. Many
on the organic community IS adamently apposed to its use at all. I think it
may have its uses in certain cases and under special cirmustances. But I
also am apposed to it being allowed to be used on food that will ultimately
be sold as "Organic".
Just as most farmers producing organic meat will not with hold medication
form a sick animal, those same farmers will not then attempt to sell that
animal or its meat as "Organic". It will be set aside to be sold as
regular, conventionally produced, meat.
Under the Proposed Rules, both would be "Organic". That is unacceptable
to every one in the organic community that I have heard from. Of course, I
am not in the position to see as many comments as perhaps you are. But I
have not seen ONE member of teh organic community thaty would accept either
meat that has been irradiated or that was treated with certain drugs, as
>GG: This is in fact the first time that the general public has been asked
>to comment on a set of proposed rules. The NOSB's recommendations
>were not proposed rules, and were used along with public comments
>received at NOSB meetings, existing certification programs, consultation
>with stakeholder groups, etc. to draft the proposed rules.
In pure truth, this IS the first time the public has been asked to comment
on a "Set of Proposed Rules". But this is just a tiny bit of "hair
splitting". The NOSB prepared "Recommendations for Rules" and did ask for,
and received, public comment, along with inputs from the other sources named.
In looking at the NOSB recommendations and comparing them to the Proposed
Rules issued by USDA, it does not appear that the USDA took very much of the
NOSB recommendations to heart. There sure doesn't seem to be very much
simularity between the two from my viewpoint. As a mater of fact, I think
Patrica said soemthign very similar to what I just wrote. ...Looking back
in her note, I find:
>So the USDA has had their input from a remarkably unified industry, and
>have gone against it. Sure, we're giving feedback now in the official
>process. But given the way that the USDA disregarded the industry's
>feedback, it's reasonable to think beyond this official process to ask
>it will take to get the USDA to respect the way the organic industry has
>defined itself - a definition that consumers have so strongly supported,
>even when it cost them more money for their food!
>To me, the point is that the organic industry has a right to define itself.
> They came up with this idea. What they do isn't harmful, in fact it is
>healthier. The government wasn't authorized to change the definition of
>organic, only to put it into law. In fact, the value of organic is that it
>comes from a more purist perspective than mainstream ag. To impose
>values of mainstream ag ("a little poison is ok") on organic is to miss the
>point and value of organic entirely.
And you commented on that as follows:
>GG: The law did not provide a definition of organic, and so we had to
>construct one based on what the law says, as well as the prevailing
>definitions used by the industry. I think we did pretty well on that
>one--please refer to the proposed definition of "a system of organic
>farming and handling."
The definition of "a system of organic farming and handling" you refer to
is not really a definition at all. It is a circular statement, defining
nothing. A term, word, phrase, or system, cannot be defined in terms of
itself in a circular manner like that. You must use a well defined starting
point outside the item being defined for it to have any meaning at all.
Especially a menaing that can be understood by outsiders such as the
consumers of food products. and after all, that is the target audience.
Those in the organic movement already know what it means.
>GG: Good analogy. The answer is that USDA has as much intention of
>redefining organic to mean what it isn't as it has of trying to make kosher
It may not have been the intent of the USDA to redefine organic as
something it isn't. But that is the result. The proposed rules are so far
away from the orginal purpose and definiton of organic that it is
unrecognizable other than the fact the word "Organic" is in the name.
In closing, please do not assume that because I limited the numbers and
types of my examples in this short response, that those are the only items
in the proposd rules to which I object. They were included here merely as
examples to clarify the points I was attempting to make here.
--Dan in Sunny Puerto Rico--
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