Date: Thu, 12 Mar 1998 18:53:20 EST
From: Aquatfs <Aquatfs@aol.com>
Subject: Re: "Organic" and copyrights -Reply
In a message dated 98-03-12 17:15:18 EST, Grace_J.Gershuny@usda.gov writes:
<< One of the clearest analogies I've seen is - what would we say if the
USDA
redefined kosher to include pork? Same thing. They don't have the
authority, and they miss the point.
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
include pork. >>
Comments of Eric Kindberg:
A very interesting analysis. OFPA is a set of generally agreed upon farming
standards based on the principal of enhancing biological activity in the soil
and health of livestock without synthetic chemicals. All natural substances
are allowed in organic farming, unless through the OFPA National List
technical and scientifically based review and evaluation process, they are
publicly petitioned, found inconsistent with organic farming by the NOSB and
the Secretary, and are prohibited. All synthetic substances are prohibited in
organic farming, with the possible public petition for consideration of
substances in 14 explicit categories. These must be itemized by specific use
or application and be considered following the National List review and
evaluation procedures by the NOSB and the Secretary.
Under OFPA, all synthetic substances are prohibited in organic handling
operations, that is processing, packaging and storing of organic food and
fiber. The National List process does allow for public petition of non-
synthetic, but not organically produced ingredients for inclusion on the
National List, after applicable review and evaluation by the NOSB and the
Secretary.
In effect the USDA/NOP staff has redefined, organic inconsistent with OFPA,
the principals of organic farming and handling and worse proposed to open the
door for complete destruction of the trust organic farmers and handlers have
created between us and our customers. The rational: simply to increase the
market share for "organically produced" raw agricultural products and
processed food and fiber. Is it that the USDA/NOP staff really has not
understood the principals of organic farming and handling? It is clear the
USDA/NOP staff had OFPA before them for years. They have heard the statements
of experienced organic farmers and handlers, know very well that consumers of
organic products are looking for pure and unadulterated food and fiber
products and yet the staff chose to expand the supply of organic products
through violating OFPA and basic organic principals. Why would the staff do
such? I know only one reason. More money comes into what they conceive as
"their" National Organic Program, creating enhanced job security.
Warning!!!! Please don't fall into the "Organic is like Kosher" trap. This
knife cuts both ways and here's why. Let's assume that Kosher laws have
nothing to do with food safety and food quality, and that they are a set of
abstract concepts defined by religious belief. Is this what we want the term
Organic to be based on? Last time I checked, people are marketing and buying
organic food at a premium because they believe that it is safer, better
quality, and produced more ecologically. The only good news about making
Organic based on abstract concepts is that it would allow the industry to
define what can and cannot be included in Organics without worrying about
coming under scientific or government scrutiny. But again, the bad news is
that conventional ag will now be able to show that Organic is not worth the
money since there are no benefits to Organics other than it satisfies some
group's beliefs.
Eric's comments: Organic is scientifically and technically valid to achieve
the desired objective(s). And if one examines any agricultural practice or
system, I would propose, it is only in light of and in relation to attainment
of the desired objective that the validity of a technical and scientific
practice and system can be evaluated against. For instance, the objective of
achieving almost instantaneous control of pests validates synthetic pest
controls. Elimination of erosion validates establishing sod. By setting
forth the principals of organic farming and handling, a criteria is now set
for the organic community to scientifically and technically evaluate its
effectiveness in attaining through specified practices and systems. Comparing
the effectiveness of organic farming and handling to conventional objectives
is absurd. Both methods do not have the same objectives. Only in those
instances where both organic and conventional have the same objectives, is
comparison possible or worthwhile. And so the term "belief group" applies
just as much to chemically intensive farming as to organic farming. Check.
On the flip side, if we assume that Kosher laws are related to food safety and
quality (which I believe that they are), then you run into an even bigger
monster. Organic regs become based on practices that are considered to produce
safe, wholsome, ecologically produced food. However, the ag industry and the
government have already defined what is considered safe food ie. "acceptable"
levels of pesticide use, "safe" use of biosolids, "safe" use of irradiation,
"safe" use of GMO's, etc. How can the government have two standards for "safe"
food: one produced without pesticides and one produced with pesticides, etc..
Eric's comments: The reason those interested in passage of a national organic
standard chose to not identify such as a "food safety" issue was for this
reason. As you say, there cannot be two standards for "safe." So, for the
government to save face and the rest of the country to continue believing (do
we really believe this) their food is safe, we will just call "organic" a
marketing label based on the institutionalized standards for organic farming
and handling. This is OFPA. The approach has worked well up until the new
objective was introduced by USDA/NOP staff in the Proposed Rule--to increase
market share of "organic" faster than OFPA institutionalization of a national
standard would allow. The USDA/NOP staff upset the organic applecart. It is
time to get back to the only way politically that organic can institutionalize
a national standard, by following the Organic Foods Production Act of 1990, an
act of Congress that unless proven unconstitutional, mandates USDA to
implement as written.
Best Regards, Eric Kindberg, organic farmer
This gives the ag industry and the government the opportunity to challenge
some of the "contrary" practices of organic farming in the court of science.
Do you have scientific proof to show that the present methods of ag are
unsafe, or that the methods for organics are more safe? Do we really want to
get into this kind of debate? Will the ag industry be happy with government
approved regs that run contrary to their existing practices? Let us not forget
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