> From: Grace J Gershuny <Grace_J.Gershuny@usda.gov>
> USDA National Organic Program Staff
> One thing that should
> be clarified is that.....
> (1) ...the proposed rule did not, in either its "draft" form sent
> to OMB in June of 1997 or the one that got published, allow for the use
> of biosolids in organic agriculture.
> (2) What we did was to consider biosolids to be a synthetic product,....
> .... which
> would have to appear on the National List in order to be allowed to be
> used by organic producers. The NOSB recommended against placing
> biosolids on the National List, and USDA agreed with that
I cannot allow these false statements to pass unchallenged. This is a
matter which can be, and should be, resolved by a simple appeal to the
facts, which, happily, are available to everyone via the Internet.
In the NOP proposal, anything which was "not considered synthetic" was
allowed, thus, by failing to specifically exclude biosolids, they WERE
in fact allowed under the proposal, in contrast with statement (1),
On page 65873 of the Federal Register of 12-16-97, column 2, it says
"plant or animal materials that only have been treated or mixed with
synthetic substances, but not chemically altered by such treatment, are
not considered synthetic under the definition provided by section
2103(21) of the OFPA (7 U.S.C. 6502(21)), and are therefore not
prohibited under the Act."
This above line distills into one sentence the profound difference
between the English-speaking organic consumer and US citizen, and the
crafters of this proposal. With this line of reasoning, I could take my
totally clean-stream backyard leaf compost, mix it with PCBs (PCBs being
admittedly synthetic) and this mixture will not be "considered
synthetic." After all, PCBs are not considered "active" under FIFRA,
and anyway, their presence is not intentional!
If this was NOT intended by the USDA-AMS in the writing of this
proposal, I am truly at a loss to provide any alternative and more
Biosolids are the primary example of "plant or animal materials that
only have been treated or mixed with synthetic substances," and as such,
would have been permitted under the proposal. Thus, statement (2) above
appears false as well.
The proposal made use of a lot of terminology which served no purpose
other than to obscure the very simple categorization of natural vs.
synthetic. This resulted in a proposed rule wherein synthetic
substances appeared to be excluded (this is simple, and it is what the
public believes and wants)...
...except if these synthetic compounds were extraneous, incidental,
necessary, unintentional, unknown, unidentified, undetectable,
non-active, inert, or non-agricultural! To further complicate and
obfuscate the issue, the foregoing adjectives were not used in any way
which would be understood by the competent speaker of the English
language. Instead, peculiar regulatory definitions were used, which in
many cases actually contradict conventional usage. Applying Occam's
razor to my analysis of this situation, I must conclude that this usage
is in fact intended to mislead the public into thinking that they are
getting what they asked for, while reserving the legal right to give
them the opposite of what they want without their knowledge. That is
simply fraud, and this is why the public, myself included, is so angry.
I welcome any alternate explanation, provided that it includes the
actual language used in the proposal.
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