These are comments from Dan Worley to Grace Gershuny
>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 certifies claiming to be
>certifying to different standards, which will not be permitted.
Left unsaid here is the fact that, under the law and the rules, no
producer or handler making production claims that exceed the USDA standards
will be permitted to be "Certified" and cannot use the "Organic" label nor
any words that imply organic production on their labels.
Eric: Under OFPA any farm or handling operation can make any claims they
want--I suggest they be truthful, as you have noted elsewhere, there is a
bright line between misleading the customer and telling the truth. Exceeding
the "USDA standards" is a subjective determination when there is no public
forum with criteria, review and transparent evaluation, therefore such
conclusion have long been felt the right of the individual purchaser to
decide. As an organic farmer I might go around saying my organic vegetables
are better than anyone else, produced to a higher ecological standard, a
higher biological standard, a higher "organic" standard than anyone else.
Most farmers and handlers even now know this kind of sales propaganda is not
very effective or beneficial at building markets. What makes people think it
will work well when there is a USDA National Organic Standard. Only one
reason I know of--that is if the USDA Organic Program Standard does not
conform to OFPA, is so weak, consumers do not trust the standard. Always, a
certified organic farmer or handler can print or emphasize the practices and
systems, even the substances they do or do not use. It is just absurd and
arrogant to emphasize that ones organic product is better than a neighbors.
This entire issue appears to be more talk than substance when one gets down to
applying it in farm wholesale sales or selling dairy products or cotton. I
suggest getting for real and understand that everyone so choosing will still
be able to describe the practices, systems and substances they do not use or
do use in farming or handling.
What I read from your statement is that they can make all the claims they
want. But when I read the rules, I find they will not be allowed to SELL
their products as organic because they can't label them with their claims.
Eric: Please reference Section 205 number of the rule you find this
But they don't want to bother
with the labor intensive practices that is required to produce true organic
products. So now they are pushing for a watering down of the standards to
allow for all kinds of in-organic practices, but yet be allowed to call it
Eric: "Labor intensive practices" are no more required in organic farm
production or handling than in conventional farming and handling. In organic
there are practices and systems. Virtually all the mechanical and labor
management systems transfer from conventional to organic. What is really
different in organics is the biological management systems. However, most of
them are only very marginally "labor intensive" over conventional systems and
many of them employ the identical mechanical and labor management tools of
conventional. Marketing of organic products is just as frought and some times
much more so with anxiety and problems as conventional. Organic farmers are
simply committed to a different set of principals than conventional farmers
and are willing to learn and make their systems work. It is time to stop
mystifying organics and get out on the efficient certified commercial organic
farm for an experience. Inefficiency is not going to be tolerated in any
market. Why, because someone will always come along and be able to be more
efficient and sell cheaper. The reason for such high standards in OFPA is to
create permanent trust and committment with the customer.
For instance after all the work and management producing an organic product is
done, OFPA states no synthetic substance can contact or be part of a
processed, packaged or stored organic product. Both the NOSB Recommendation
to the Secretary and the USDA Proposed Organic Rule call for the use of
synthetics processing aids, food additives, enzymes and ingredients in
contradiction to OFPA. The USDA proposal for use of such substances is
consistent with their Proposed Rule use of GMOs, irradiation, any FDA approved
synthetic medicine or parasiticide in livestock. The public needs to come to
realize that a general tenet of OFPA--no synthetics--eliminates a very large
list of unacceptable substances from being used in organic farming, processing
and packaging. If the public does not understand organic farming and handling
principals as embodied in OFPA, the USDA will pollute the term "organic."
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