Dan writes:
In addition, the entire program is an unfunded program requiring almost
all farmers and processors to pay what will become an outlandish, and way
over-priced, fee to get the label. One of the biggest problems with the law
itself is the untenably low exemption level.
Eric:
How does a $5000 annual income from farming exemption consititute an
"untenably low exemption level." Under OFPA, all handling operations have to
be certified. Farms were allowed the under $5000 exemption for begining
farmers or those experimenting with low acerage. In fact, to ensure that
organic customers are getting products produced to the national organic
standards all farms so labeling must conform to the standards. Assurance to
every organic customer they are getting what they are paying for is the only
way to create permanent trust in the organic label.
An annual gross sales of under
$5,000.00 is simply unrealistic. No farmer can exist with that level of
income; certainly no organic farmer. So even the poorest of the poor,
smallest of the small, farmers will be required to pay for certification at
the federal level. they aer laready paying for state certification in most
cases and that will not change.
Eric: In the US the vast majority of certified organic farmers are not paying
state certification fees. You are correct, that the issue is reasonable fees.
And further more, if the job description of the USDA/NOP is not explicit and
limited to those responsiblities granted under OFPA and done efficiently, we,
organic farmers, handlers and consumers are just paying for another
inefficient bureacracy. After the length of time to publish the Proposed Rule
and the quality of job done, it is clear, there must be new efficient
management (it appears we have it in Keith Jones) and newcompetent and
efficient staff.
Many are also paying a second certifier now
and THAT will not change. All that will happen is they will ahve to pay for
additional federal certification to get a label which actually means nothing.
Eric:
The final USDA/NOP standard will mean exactly what OFPA says or the Act will
be repealed. We, the organic community, hold the trump card and it will be
used.
There aer already a number of European countries that are looking at rthe
new standard in disgust.
Eric:
I would not refer the first try at a Proposed Organic Rule as "the new
standard." It is not.
Some are threatening to not permit US certified
organic materials to be sold inside their borders because of the lack of
standards and the proposed allowance of not only sewage sludge, irradiation,
and pesticides/drugs, but the severe lowering of requirements across the
board.
The OFPA needs a bit of work. It should be ammended to correct several
serious flaws.
Eric:
It appears to be time to discuss those flaws again in light of a second
proposed rule. What are they?
But any law is only as good as the government agency or
agencies empowered to enforce it. And the manner in which USDA wrote the
proposed rules shows a total disregard for the provisions of the exisiting
act.
The USDA needs to go back to the drawing board and start over. One very
good place to start is with the National List. Get out of the business of
writing that list and put it back in the hands of those it was instrusted
with by the law. They need also to appoint people to appropriate positions
who hacve actual experience in organic farming and handling of organic
products; not a bunch of chemical farmers and former employees of chemical
companies. The Secretary then needs to instrcut eveyone at USDA to get back
to work and comply with the law to formulate a set of rules that comply with
the law and have meaning; that are in fact a set of STANDARDS for organic
farming, processing, handling, and distribution.
Eric is correct in wanting the rules to comply with the law. He falls
short in not advocating ammendments to the law to correct the current
deficiencies.
Eric:
The only issues brought forward for amendments I have heard is rewriting to
allow a larger exemption for small farms and perhaps allowing private
certifiers the same ability to have their certification programs approved by
the Secretary as States may choose to do under OFPA.
Is that it?
Why don't we get down to a serious discussion of the principals governing a
national organic program, the pros and cons and real suggestions for language?
--Dan in Sunny Puerto Rico--
--dan.worley@icepr.com--
--dan.worley@mindless.com--
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