Re: sanet-mg-digest V1 #672

Matt Arant (matthew-arant@uiowa.edu)
Thu, 19 Nov 1998 06:53:17 -0600

Grace,
Here's the thing: Say what you mean in the first place. Don't
claim afterwards that it isn't what you meant. "Lack of clarity" is by no
means a minor criticism with respect to a document whose contents could
become law. Don't refer the reader to some obscure footnote reams away
from the text by way of "clarification." The realistic reader knows damn
well that the reason that "clarification" is in an appendix is so the
appendix can disappear, unnoticed, when the time is ripe.
It's true that we can quibble about the meanings of "synthetic" vs.
"natural," but the distinction is hardly as vague as /you/ claim. There
are a few gray areas, but those areas are, by and large, outside the
scrutiny of the public. The consuming public has a pretty clear idea about
the distinction, and is really only concerned with those things that are
either clearly synthetic or clearly natural. For instance, I think any
member of that public would agree with you that chemically treating
biosolids renders them synthetic.
Lastly, I'd really have to see the text of this promise from the
AgSec to be quite sure that it delivers what you say it does. These
Washington types sure can weasel out of their promises, no matter how
"explicit" they appear to be at first glance.

Matt Arant

>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
>
>Dear Loren,
>
>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.
>
>Grace Gershuny
>USDA National Organic Program staff
>

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