I have a few comments on points you have brought up.
Cook Organic Garden Club wrote:
> Douglas M. Hinds wrote:
> > I hate to say this but - I tried very hard to sound the alarm
> > regarding this type of thing - that the danger of OFPA goes far
> > beyond the GMO's, the sewage sludge and the irradiation.
> I have read your many warnings, but what remains is still:
> How is a retail purchaser to know if something is "organic" as
> I mean "organic" if those who are not certified can advertise
> their produce as "organic"?
Good point. It is a relationship that rightfully should be resolved between
buyer and seller. A retailer or distributor must know and apply the same
criteria as their own clients. There are many ways of verifying and I am
NOT opposed to certification - just mandatory, blanket certification, which
is often in appropriate and subject to abuse.
The Organic Food Production Act passed as an Act of Congress in 1990 is
mandatory for all domestic and imported products labeled or sold as
"organically produced." There are no exceptions for intrastate, within the
State, sales. The only two exemptions are for those farmers with less than
$5000 gross farm sales and for those handlers, those who process, package or
store, who choose to only label the ingredients of their products as
"organically produced." The label "organic" was created for consumers, the
customer, to clearly differentiate products that are produced and handled to
agreed upon national organic standards. Our national representatives creating
national organic standards without a method to enforce them would be
worthless. Thus, with respect for the existing private and State organic
certification systems OFPA established a national accreditation of certifying
agents that they would meet publicly agreed upon criteria for certifying farms
and handling operations. Lastly, the OFPA provided for "equivalency" of all
imported products labeled and sold as "organically produced."
As we now are familiar with, laws passed by Congress can be manipulated by
"interests" (those "interests" can just as much be the USDA/NOP staff, Office
of Management and Budget, FDA, EPA as well as multi-national corporations or
organic handlers or certified organic farmers.) It is clear that democracy in
the US demands active participation by all citizens and their representative
organizations. The recent public comment period on the first Proposed Organic
Rule clearly illustrates the public has a direct and immediate interest in
high quality national organic standards and the continuing of a high quality
organic certification system. Nothing stops now. The second public comment
period is approaching quickly. "Interest" always expresses themselves through
making personal contact and organizational representation to the agency
issuing the Proposed Rule. That is what the public comment period is for: to
correct a governmental agency's proposed rules that are inconsistent with law
and the public's expectations. We did it the last time and we will have the
opportunity to do it again. Democratic governance is a refinement process in
which the public has the greater role, forever, if they will only take their
allocated responsibility. Facisim, dictatorship appears to be based on a
limited number of individuals demanding decision making power and assuming
power without public oversight. SANET as an open forum expands democracy.
But to do so, open inquiry and speaking factually must be its foundation. I
appreciate both Douglas's and your input to this subject.
Truth in advertising laws would be applicable, once a national legal
definition exists. But that relates to production methods, not verification
methods. USDA / NOP certification MAY be the best option - but in many
cases it won't (i.e. CSA operations).
-Truth in advertising is based on clear public knowledge of what the truth is.
-And secondly, so called "truth in advertising" laws up to the passage of OFPA
have been largely ineffective (although most assuredly some will disagree),
with the exception of the recent Nutritional Labeling Act and the long term
FSIS prelabel approval program for meat, poultry and processed egg products.
-Thirdly, after seven years of being involve with implementing a quality
National Organic Program, it is clear very few people outside of long term
certified organic farmers really know what "organically produced" means today
and will mean under OFPA. However, public knowledge is expanding rapidly.
Fortunately, in the US the Federal Administrative Procedures Act, etc give an
aware public the right to have visible and profound impact on implementation
of Congressional Acts, US law. Implementing OFPA is having a profound affect
and will continue to do so on every aspect it touches.
We, organic consumers, certified organic farmers and handlers, organic
certifying agents, the "organic community," are now in the process of
implementing an extremely far-reaching and profoundly effective Act of
Congress. Using antiquated "truth in labeling" laws to assure consumers they
are truly purchasing "organic" products that are "organically produced" would
leave the "organic community" ill prepared to deal with "market forces" and
exploiters. OFPA institutionalizes quality organic standards, certification
and importation equivalency. Public transparency, discussion and action must
prevent any misuse of its authority by any individual, governmental agency,
corporation or "interest."
> > ORGANIC CERTIFICATIONS SHOULD NOT BE OBLIGATORY
> How would you feel about only international or interstate commerce
> as demanding mandatory certification? I ask this since I, as a
> consumer, am in a pretty good position to check up on the produce
> of my own (admittedly small) state.
I think my comments above apply here too. And I agree that greater distance
may be a factor that influences whether certification is needed - but that
already is true, without it being compulsory. The CUSTOMER will decide what
fills his/her needs.
> > and arriving at a consensus regarding a national standard - and legal
> definition - does
> > not require that.
> That is true. The argument is, of course, the problem of causing
> confusion in the marketplace, which has some truth but I don't really
> buy it.
> However, at least one poster seems to want to be able to sell
> ingredients to a formulator who WILL be nationally certified, while
> simultaneously opposing mandatory certification. This seems
> contradictory. Are you one one side or the other of that?
If his buyer requires it, he'll have to respect that if he want's to sell to
that buyer - but it's between them.
> > Let OFPA / NOP / USDA organic certification stand on it's own merit.
> Forgive me if you have already covered my concerns, but I am taking the
> viewpoint of a retail consumer, since the whole point of labeling is to
> provide information to the customers, IMO.
A retail client may only buy or ask his retailer to handle only certified or
even USDA certified organic products - but he'll know a lot more by sampling
the product himself.
Also some labels (like some certification organisms) carry more credibility
than others. There is no valid blanket solution , and to think there is is
not only naive, it leads to abuses that I (and many others) believe will be
greater than those that exist today.
> > INSIST THAT MANDATORY CERTIFICATION FOR ORGANIC PRODUCTS > BE REMOVED
> FROM OFPA.
> It seems that a simple exemption for produce which does not cross state
> lines (or some geographic distance, preferably) would address both the
> problems of the small farmers selling their own produce and the needs of
> the customers of such produce. Would that suit your needs as well?
No Loren, it wouldn't , I am not against certification; just any and all
compulsory certification, unless it's motivated by the buyer &/or consumer.
Organic standards SHOULD be legally defined, and truth in advertising laws
And if OFPA certification standards (and certification itself) are not up to
IFOAM standards (as was and still is in danger of happening), true organic
farmers will not be locked out of the validation resources they already
For clarity: the only "true organic farmers" are certified organic farmers.
The same goes for "true organic handlers," they are either certified or they
are not "true." Individually, we can believe and state whatever we want, but
least we forget, government does serve and is there for a purpose--to
institutionalize fulfillment of the generalized "citizens' needs" with respect
for "minority citizens' needs."
Certified organic farmers, handlers and certifying agents have sought
compulsory certification to create a level playing field for each party--that
is to set a public standard that everyone must meet to label and sell as
"organically produced." Consumers have sought to know they are in fact
getting what they are paying for. Domestic organic handlers have desired
imported products to be produced and handled at least equivalent to the
standards US organic farmers and handlers are required to meet. These are the
reasons for OFPA. IFOAM is not a US organization and does not represent US
certified organic farmers and handlers. They are free to develop their
organic standards. We learn from each other, but are not governed by IFOAM,
but by our US governmental institutions, which we each have the right to
participate within. In a sense, the issue of "organic" is an issue of grass
roots democratic governance balanced against governmental and private sector
Eric Kindberg, Iowa certified organic farmer
> Loren Muldowney
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