>Date: Wed, 18 Nov 1998 14:01:00 -0500
>From: Grace J Gershuny <Grace_J.Gershuny@usda.gov>
>Subject: Re: national organic standards and sewage sludge -Reply
>Since I drafted a lot of the language that you cite, and was also closely
>involved in the discussions that led up to it, I think I can claim to have
>more knowledge of the intent behind it than you can. Both of the
>statements that you quote are true, even if you don't want to believe it.
>The major criticism that can rightfully be leveled at our language is lack of
>clarity. There are nevertheless some good reasons for the confusing
>definitions that were developed, many of which relate to the fact that the
>difference between 'synthetic' and 'natural' is hardly as simple and
>clearcut as you claim.
>In the case of biosolids, the original materials clearly are chemically
>altered by their treatment, 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. 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.
>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.
>USDA National Organic Program staff
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