> Not if OFPA were successful in providing a minimum national definition
> w/o requiring certification. Verification could be contested by
> interested parties, rather than required Carte Blanche.
I see, it could be enforced by civil litigation.
> Most if not all distributors already require certification and the
> differences between one major certifiers practices and anothers are
> not as great as some have maintained.
Okay, I understand now (pardon my ignorance). Then the easiest path for
the USDA would be to adopt the rules of the least stringent of the major
certifiers, and continue to to let these private parties do the actual
certification. Certification agencies could be designated on a
bioregional basis. The USDA could take bids to find the most
cost-effective private certifier in the region or state.
> The major problem as I see it, is that the revised Rule may not
> revising OFPA itself to remove mandataory certification, in which this
> will go to court.
I think I see why this is an issue. If certification is not mandatory,
and is expensive, no one will buy it. The bureaucratic domain would
shrink. The big players would like to make it mandatory, to help grind
their Mom and Pop competitors into the dust. So there is an alignment
of interest between the regulators and the big players.
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