>A few comments follow:
>From: Edna M Weigel <email@example.com>
>To: firstname.lastname@example.org <email@example.com>
>Date: Friday, November 13, 1998 11:46 AM
>Subject: Organic Standards
>.> About decertification, I am torn between the need to let a
>>certifier withdraw certification (and maybe even recall product) as soon
>>as violation is discovered and the need to provide "due process" in case
>>some certifying agent has an axe to grind (or maybe even accepts a bribe
>>from a competitor). I have no idea how to handle this administratively.
>Let me begin by stating that it is completely insufficient for
>Organic Program and USDA/Office of General Counsel to not supply a clear
>administrative plan for handling both the authority to certify and to
>decertify and the authority to stop the sale of products mislabeled
>"organically produced" (whether mislabeled "organically produced" on
>or mislabeled because a "substantial" violation of the requirements for the
>farm or handling operation to be certified organic have been identified and
Don't let chicken little scare you the certifiers are doing a good job now
and it is not worth what we have to give up like Inerts and Synthetics in
Processing . The customer should be made aware of what they are giving up
to by letting the USDA take over CCOF and other certifiers. There are not
that many growers saying they are organic and are not to make every one that
is not lying pay fees and be burdened by paper work on top of paper work.
every time you add more layers of buracratic bs there is another layer the
poor grower has to wade through. enough already. how many pencle pushing
buracratics does one have to pay off just to grow a crop organic. each
adding their own buracratic bs that has nothing to do with if you are
organic or not. An organic grower can be stopped if he does not pay the
fees. what is that all about. and you want to add even more fees and take
away due process. whats up with that .. take away our rights because
someone else may be lying. I feel if someone is lying let them pay for the
investagation and those that are telling the truth let them grow organic
free. They have not done anything wrong so why burden them. I am talking
about those that don't deceive and that don't mislead . Its not worth it..
putting us through all this bs becuse some one may be lying.
>We, as organic customers are concerned about being deceived or mislead when
>purchasing "organically produced" products. We, as certified organic
>and organic handlers are concerned about unfair competition that occurs
>farm or handler in fact is "substantially" not meeting requirements to
>and sell products as "organically produce," and yet is allowed to continue
>labeling as such
Lets talk about the customer . In CCOF there is no inerts and Synethetics
in Processing like they will have when the USDA takes over CCOF and destroys
all our good work.
>The USDA/OGC and NOP proposal for perpetual certification is contrary to
>existing organic certification norm. However, "due process" as you point
>beyond limiting liability for the USDA, also provides a certain security to
>certified farmer and handling operation from pernicious decertification, a
>security that does not now exist in private and State certification.
I think it is the only good idea that has come out of this mess. perpetual
certification what a great idea you pass once and as long as you are still
organic you in. Right on USDA! Dont let erroganic talk you out of this
one. I wish the states and the certifiers would pick up on it. Due process
and it is that certain security that is missing from all the other
regulators Giving the farmer protection against pernicious decertification
what a great idea. and you want to strike that down. Whats up what that.
>However, to me as a certified organic farmer and consumer of "organically
>produced" products, what is most important to me is bringing swift action
>stopping mislabeling "organically produced" purposefully mislabeled or in
>face of "substantial" violations of a certification program.
If you kill off one inocent organic grower with you power hungry laws we all
>But, there are solutions, don't ask me why USDA with all its staff and
>interagency contacts can't figure them out and present a coherent program
You are right there are other solutions I am supprised you have not thought
of them . We don't need any USDA at all . there are laws on the books now.
we don't need the extra fees and the extra paper work. as you have pointed
out there are law on the books now.
>First, on the State level, there are laws against mislabeling that cover
>"organic." We are only now finding their usefulness and much needs to be
You allready know what I feel about the states . they are ripping us off
and we get no due process.
>Second, on the Federal level, there is FDA compliance labeling officers and
>programs that cover consumer labeling of processed food products, dairy,
>shell eggs and animal feed. There is FSIS compliance labeling officers and
>programs that cover consumer labeling of meat, poultry and processed eggs.
>Each of these agencies is required to respond to citizen complaints and
>investigate mislabeling. In international trade equivalency, regarding
>imported "organic" products; there is the Ag Marketing Service, the Foreign
>Agricultural Service and the Federal Trade Commission to take action.
>In other words, there already exist ways to enforce labeling of
>I am extremely concerned that 7 years after the USDA/NOP staff and the NOSB
>began work, we still have no public policy development for enforcement of
>domestic and imported labeling of "organically produced" products.
WE have our certifiers ,inspectors , growers we have imported certifiers
(like IFOAM) we can get it together with out having to give up so much up
like we would with the USDA law. Big goverment should let bussiness take
care of bussiness it has and it will . It is doing a good job ... Get big
>> I have lots of sympathy for the argument that big government
>>should stay out of the organic certification business and the
>>criminalizing of certifying to higher standards is absolutely repulsive
this OFPA being the single standard is nuts and
it is making us all sick ,
+>The statement from USDA has been and is that under OFPA there is a single,
>consistent and uniform standard and requirements for labeling and selling a
>product as "organically produced" in the US, whether domestically produced
>Under OFPA with the ascent of the USDA, any certifier, any one, can certify
>that any practice is being performed by any organic farm or handling
>operation. What a certifier cannot certify under OFPA is that the standard
>used on a farm or handling operation is a "higher" organic standard than
>national organic standard.
>The reason is clear, OFPA, an act of Congress, mandates a single, uniform
>consistent national organic standard. It think in theory that is fine.
>do you think?
What is the good of a single uniform standard if it is junk and if it cost
too much money.
>There are a number of ways to raise the OFPA organic standard,
>-the NOSB recommendation process,
>-the Congressional legislation route, and
>-the petition for amendment of the Code of Federal Regulations.
The NOSB had not been willing to research and confront the issues and stand
up for the rest of us and can be taken over easy by big bussiness and has.
I don't not trust them anymore.
all these other routes are not half as good as never entering into the
implementation in the frist place .we can see after 8 years how the USDA is
playing and now is the time to get the USDA/OGC/OMB monkey off our backs.
>There are also additional Federal Statutes that offer legal redresses for
>burden's on farms and businesses created by the implementation of agency
why ask for redresses when we can stop the burden now before the
implementation. I want redresses now. how many pencle pushers buracrates
does one small organic grower have to pay off just to grow a little organic
food for the people.
>The issues you mention above are important to be continually monitored.
>only effective way to monitor them is to understand the details of OFPA and
>proposed/final organic rule.
they are taking the word organic and making it a political football subject
to hard money,soft money and backdoor under the table money. get use to
synthetic food additives ,processing aids ,
coloring,presevatives,flavorings,enzymes etc because thats is what the USDA
will bring customers and they may sneak in some gene altered stuff too.
Keep organic certification independent from the USDA and the states. Abandon
implementation and go to an independent standard and regulatory.
>The major lobbyist seeking to water down OFPA are organic handling
>which are some existing organic processors and marketers.
>The issue is simple. Some organic handlers, processors and some large
>supermarkets want the NOSB and USDA to consider to allow the use of the
>synthetic food additives, processing aids, colorings, preservatives,
>flavorings, enzymes and in some case synthetic ingredients now used in
>conventional food products in products labeled and sold as "organically
>The Organic Trade Association's processing, manufacturing and labeling
>committee made up of a many certified organic handlers backs the use of
>synthetic substances in processed organic foods.
>This is in direct contradiction to OFPA which states that once the
>"organically produced" product leaves the farm, no synthetic substance
>contact or be part of "organically produced" products.
>At the most recent NOSB meeting in DC, Kathleen Merrigan, a member of the
>proposed that probably the only legitimate way to allow the use of
>in processed "organically produced" products is to amend OFPA.
>Very large numbers of the 285,000 comments on the Proposed Rule rejected
>synthetics in "organically produced" processed foods
over 300,000 comments say the USDA after 8 years doesn't know organic food
from shine-o-la and are the last people we want to set the standard. Abandon
the implementation and go to an independent standard and regulatory. Get
the USDA/OGC/OMB monkey off out backs.
Best regards Sal
It is up to interested citizens to protect their sorce for organic food and
unadulterated food and fiber and protect the grower from the burden of all
this bs. Get the USDA/OGC/OMB and COP monkey off our backs.
>It is up to interested citizens to assert their right to pure and
>unadulterated food and fiber products.
>Best regards, Eric Kindberg
>>Best regards, Edna Weigel
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