One hundred percent of the information available to the public (that
would be me) is contained in the written words of the proposal. It is
not possible for me to evaluate what you meant; we citizens and
consumers are absolutely limited to what is printed on the pages of the
I would love to believe that your original statements are true. I just
wish you would support your assertions with specific quoted text out of
the proposal, so I can better understand my error. It would save me a
great deal of time if I were able to believe them; I have not read
hundreds of pages of technical documents pertaining to the NOP, sludge
use, FIFRA, etc. for the sheer joy of doing so. I felt it was essential
that I undertake this unanticipated and unwelcome task in self-defense.
Growing all of my own food sounds like a real pain, and I would much
prefer having organic standards in which I can have some confidence.
> In the case of biosolids, the original materials clearly are chemically
> altered by their treatment,.....
Other than bacterial digestion and mineralization, which would apply
equally to all composted materials, what makes you say that "the
original materials clearly are chemically altered by their treatment?"
I can think of no other processes common to sewage treatment which would
necessarily entail chemical alteration of the original materials.
> .......and cannot be chemically or physically
> segregated from the synthetic substances with which they are
> combined. Whole new compounds may be created in this soup. This
> DOES fit the definition of synthetic.
If this is what you think you said, I can understand your unhappiness
with the negative response to the proposal. Unfortunately, unless you
will also contend that compost fits the definition of synthetic, which I
assume you do not, I still can point to no specific process which would
make biosolids synthetic by definition. Please point out what I have
> You can further verify that we did
> not intend biosolids to be considered 'natural' substances by referring to
> the list of substances that were reviewed and categorized as natural
> (non-synthetic), and therefore permitted for use in organic production.
> This list appears on page 65888 of the Federal Register of 12/10/97, and
> does not include biosolids.
You are referring to the list directly below where it says "This list is
not intended to be inclusive of all non-synthetic substances allowed for
use." Thus, the fact that biosolids do not appear on the non-inclusive
list offers no assurance that the substance would not be considered
> In any event, the Secretary of Agriculture has already promised that
> sewage sludge will be explicitly prohibited in any future proposed
> regulations. I don't know how much clearer that could be.
It was not clear to me in December 1997 that Mr. Glickman would make
such a promise in May 1998.
My intention in pursuing this conversation is not to impugn your
intentions or hamper your future efforts in crafting a good NOP rule. I
do believe there is an important disparity between what you meant to
say, and in fact apparently believe you did say, and what was actually
written in the NOP proposal. You may, because of long familiarity with
this task, find it difficult to read the proposal with the outsider's
literal perspective, seeing these words for the first time. I hope that
my explanations of what I read in the proposal will provide insight into
better ways to phrase the final rule.
You said "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."
I maintain that your statement does not find support in the text of the
proposed rule. I sincerely hope that the revised proposal will remedy
all the shortcomings of the original, and that we can eventually find a
way to capture the nutrients in household waste without introducing
industrial toxins into the food chain. We can probably agree that there
will be no sustainable agriculture unless we succeed.
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