ACRES, USA: A JOURNAL OF REGENERATIVE AGRICULTURE
T R A N S I T I O N S
December, 1998
Organizations from sixty countries attending the yearly conference of the
International Federation of Organic Farming Movements at Mar del Plata,
Argentina ratified a declaration against the use of genetic engineering on the
21st of November.:
" IFOAM is calling for governments and regulatory agencies throughout the
world to immediately ban the use of genetic engineering in agriculture and
food production since it involves:
Unacceptable threats to human health
Negative and irreversible environmental impacts
Release of organisms of a non-recallable nature
Removal of the right of choice, both for farmers and consumers
Violation of farmers’ fundamental property rights and endangerment of
their economic independence
Practices which are incompatible with the principles of sustainable
agriculture as defined by IFOAM".
While the GEO/GMO controversy continues unabated in Europe at high levels of
political and regulatory government, kindred spirits in the United States are
finally making some headway with the press and government officials. It was
reported frequently last month that USDA Secretary Dan Glickman was
concerned about the issues raised by Michael Pollan’s cover article " Fried,
Mashed or Zapped With DNA?" in the October 24 issue of the New York Times
Magazine.
Getting the mainstream media to cover this issue has been an uphill struggle.
Civil disobedience is one avenue that results in some coverage, whether its a
pie in the face for Robert Shapiro, the CEO of Monsanto, or an illegal potato
harvest in Scotland with the video cameras running. The destruction of GEO/GMO
test planting sites in the United Kingdom and Europe have been going on for
over a year. In California, protesters partially destroyed a University of
California GMO crop, and in India the Karnataka State Farmers Association has
begun "cremating" fields planted to genetically engineered cotton. Farm
leaders in Maharastra, Gujarat and Madhya Pradesh states had similar actions
underway in the last week of November.
Genetic engineering technology is going to be the biggest threat to
sustainable organic agriculture for years to come. Because it is molecular and
non-degradable it pervades, and invades forever, microbial soil technologies,
livestock feeds and supplements, raw and processed human foods and vitamins,
and should cause us to ask questions about sources of manures, seeds, and
organic fertility inputs like cotton seed meal and alfalfa meal. Corn gluten
is being hailed as a good potential herbicide in organic systems. Should we
use it if it comes from genetically modified corn?
On the 14th of December the Public Comment Period ended on the three Issue
Papers released by the USDA National Organic Program at the end of October.
Until the last few days, most organic farmers and consumers were not familiar
with the scope of these papers, nor how to respond appropriately, although
more than a few thought the best response was none at all. Having to construct
responses according to the awkward format proposed by the USDA and the Office
of Management and Budget provoked some of the dismay and repulsion. However,
after the dust had settled, officials from state certification agencies,
private certifiers and organic advocates responded with suggestions and
rationales that began to trickle out to the hinterlands and encourage
individuals respond on their own.
There were three papers that USDA requested comments on. They covered 1.
industrial agricultural feeding systems, known to us as " confinement", 2.,
the use of antibiotics and paraciticides in organic livestock production, and
3., the traditional role of certifiers in the enforcement of organic
standards.
" Confinement" would seem to have been a "no-brainer", but creating language
that would meet consumer expectations for organic livestock proved to be a
pretty thorny subject. There are a lot of gray areas. There are organic
livestock products on the market today that are produced in systems that
common sense-minded observers would call "confinement." Confinement is
required at certain times of the year to protect animals, which is obvious,
but some also argue that confinement is necessary because it is the most
economical method to produce target quantities. Confinement is at the same
time a difficult characteristic to measure: is it necessary to determine how
many square feet should be allocated for every turkey in order to assure that
they are not "confined"? Is an organic poultry system necessarily a pastured
poultry farm? Most organic small family farmers would answer affirmatively.
They respond: " Why ask this sort of question, when access to pasture for
poultry, cattle and hogs is the keystone of disease prevention strategies on
our farms?" Who wants to finesse this nearly sacred concept in organic
agriculture, and why?
Why? The USDA logically wants to know when the use of synthetic medications is
OK.( Paper No. 2).
" Never", say most farmers. " And don’t give us that business about how I am
going to let my sheep suffer instead of treating them. In the first place 400
healthy sheep have been raised here since the last time I used paraciticides
in 1993."
" Why would an organic farmer who has made an effort to provide an optimum
living environment for livestock have to resort to the use of antibiotics and
synthetic paraciticides when the reason that these substances are used so much
is because the animals are confined?"
Paraciticides. It may come as a surprise to some, but anthelmics, internal
pesticides like Abendiazole and Avermectin are yet allowed with restrictions
by some organic certification agencies. Those restrictions call for withdrawal
periods. Enter the consumer, whose expectation is that all organic meat, eggs,
and dairy have been produced without ever resorting to these poisons. When
consumers pick a product off the shelf that is labeled "organic", they can’t
be expected to make choices based on the labyrinthine variances of anonymous,
acronymic certifiers ( which is why uniform national standards were and still
are needed.). I love the people at the OCIAs, the CCOFs, the QAIs. OTCOs, FOGs
and FVOs. But what about Donna and Michele at the supermarket in Atlanta?
" Excuse me, Michelle, honey. Would you get my organic certification
compendium out and see if JJOC and the State of Georgia prohibit the use of
Abendiazole in organic dairy cattle? The last thing I want is another
miscarriage."
( Anthelmics are contraindicated during pregnancy, and approved by the FDA.)
In large measure, we continue to beat on this conundrum of acceptable
medications in organic farming because the Organic Foods Production Act of
1990 seems to give permission to farmers to use them, when and only when they
have been specifically petitioned to be included on the National List.
Unfortunately, these named substances have never been petitioned for by
specific use, as mandated by Section 2118 of the OFPA:
(b) CONTENT OF LIST. The list established under subsection (a) shall contain
an itemization, by specific use or application, of each synthetic substance
permitted under subsection (c) (1 ) or each natural substance prohibited under
subsection (c)(2).
In Santa Fe, New Mexico (1994) and in Austin, Texas ( 1995), the NOSB wrote
and then added to the organic livestock production standards eventually
recommended to the Secretary of Agriculture. The Board wrote standards
covering many production practices, even going so far as to describe an
organic definition of humane treatment of animals being transported. But they
did not entertain a petition for a single named synthetic paraciticide.
Instead, the NOSB adopted a blanket approval, using new criteria.
In their response to Issue Paper No. 2, research analysts at The Organic
Materials Review Institute ( OMRI) wrote, " The NOSB wrestled with the
difficult issue of the use of antibiotics and parasiticides in organic
production, as well as vaccines and other medications, basing their decision
on a review of standards currently in place domestically and internationally
and input from the public, organic growers, and the broader organic
community."
In a word, the medications were "grandfathered."
Herein lies not just the clue to why we are once again embroiled ( with
honest gratitude to the USDA) in the debate over whether or not animals
treated with synthetic medicines and internal pesticides are part of organic
agriculture, but why the original Proposed Rule was so flawed in the first
place, why there is such confusion still and why this process is taking so
much time to complete when the task should have been much more efficient. The
wrong road was taken, and instead of taking two or three years it has consumed
seven, and the end of our journey seems still far distant.
Many folks have wondered: " I thought we were already done with paraciticides
a long time ago?" There is a precedent setting distinction which few
certifiers have adopted: the NOSB recommended that " The use or application of
synthetic parasiticides in organically produced slaughter stock that is
labeled or sold as organically produced is prohibited. (Adopted on June 4,
1994 in Santa Fe, New Mexico)
Please compare the following two distinct statements on animal medication and
observe the paradox:
NOSB ( 1995): Antibiotics (Terramycin) - (Oxytetracycline calcium complex) To
be reviewed again in two years.
A consumer responding to the Issue papers on the NOP website, November, 1998:
" I demand that the USDA abide by the NOSB recommendations regarding the use
of animal medications. I demand that there be a ban on the use of antibiotics
on all animals which are considered organic. As a consumer, I want to know
what is in the food I eat, and I expect the USDA to act in accordance to the
wishes of the public and not the desires and incentives of big food business."
Do you all see something a little bothersome in these two examples? First of
all, we could assume that the consumer correspondent is aware that the NOSB
reversed it’s recommendation on antibiotics in Ontario of this year. But I
don’t believe that is the case. That consumer, just like many of the other
280,000 who responded earlier this year, were under the impression that the
NOSB had always acted in accordance with the law and had never compromised
consumer trust. Now, if you were Keith Jones, the Director of the National
Organic Program, what would you make of it? It seems to me that consumer
expectation and the ability of the organic livestock production sector to meet
that expectation are miles apart on this. Remember, antibiotics, even a
hormone ( oxytocin) and the paraciticides Abendiazole and Avermectin are still
on the restricted list for more than one organic certifier in 1998. Though the
NOSB, and those certifiers, ask for much more time in the withdrawal period
than was mandated by the Food And Drug Administration, if you are reading
ACRES you probably haven’t too high a regard for what the FDA decides is safe.
NOSB: " Should a synthetic paraciticide be administered for whatever reason to
otherwise organically produced dairy stock, milk or milk products derived from
that dairy stock may not be sold or labeled as organically produced for 90
days following the date of application or use."
They then go on to say immediately thereafter: "Any deviations from the above
standards shall be species specific and be set forth in a separate document.
Such review shall include, but not be limited to, sheep, goats and swine."
I know that this may not have been intended, but milking pigs is just not
going to turn out to be a real money maker. This whole deal sometimes seems to
have been written backwards while looking into a fun house mirror.
Much to their credit, OMRI is so far the only resource I have found that has
identified by name the internal pesticides which we have continually glossed
over by using a word that is so hard to pronounce that it gives us a motive to
say it even less:paraciticides.
If, when the next Proposed Rule on the National Organic Program is released,
you find that there is not a strict prohibition against the use of antibiotics
and paraciticides in organic livestock production ( with the exception of
breeding stock), please focus your energy on prohibition. That is what
consumers expect. As the authors of the OMRI response wrote: "......organic
farming is based on more than not using prohibited materials. However, the
standards themselves should not be flexible or allow for variances.
Flexibility does not benefit consumers who seek a clear standard that
distinguishes organic food from conventional. Conscientious producers are
undermined by flexible standards that permit unscrupulous competitors to
exploit the lack of clarity. Certifying agents and their inspectors find
verification of such standards difficult if not impossible. While we recognize
the need to not penalize producers and handlers who act in good faith, and to
give the standards time to evolve, we ask that the USDA strive for clarity and
consistency in setting the standards."
The confusion on the livestock medication issue is based on new criteria
invented in 1994 and 1995. We are on the cusp of another discussion which will
be played out soon on the use of synthetics in processing which also will
revolve around a new set of criteria being created by the NOSB’s new
Interdisciplinary Committee on Processing. At some point during the national
dialogue on organic standards this year the USDA’s Office of General Counsel (
OGC) came to the NOSB and said " You folks have placed some processing aids
here on your National List that don’t meet the criteria in the legislation."
A farmer who attended the most recent NOSB meeting in Washington, D.C., asked
the members of the committee: " When OGC asked you to fix this, why didn’t you
just vote to rescind your recommendations, like you did on animal medications
back in April?"
Some committee members just shrugged, some raised their hands and said "
That’s what I wanted to do!" and the representative from the "Organic
Manufacturers and Packagers Association" looked up with eyes as big as pie
plates at the mention of such heresy.
In the federal law, "need" and "want" are pretty well tempered by criteria. If
a farmer or a manufacturer needs a substance because they want to produce
something, and the criteria doesn’t allow for it, the answer has to be: Then
don’t call it "Organically Produced". Call it " Made With Organic
Ingredients". Let consumers make the decision at point of purchase.
Its difficult to organize this column based on what is most important to lead
off with. For everyone, genetic engineering always has to lead off. But for
farmers, particularly the ninety organic soybean farmers I visited this fall
working for OCIA as an organic farm inspector, I would say " Hold on to your
beans!"
This season was a real challenge, from field preparation to planting to
harvest. And now, with so much wet weather behind them, organic soybean
producers in the Midwest have a lot of dirty soybeans in their bins. Farmers
"mudded in" their beans, farmers had to cultivate wet ground, throwing clods
of dirt into the rows, and even then the weeds came in, chiefly amaranthus and
foxtail grass, which will discolor the soybeans just like those dirt clods
will if they go into the combine. That is, if the weather dried up enough to
even get back in with a combine: some folks are waiting for a hard freeze so
they can harvest.
So hang on to those beans. Don’t sell short when brokers want to discount your
product because of discoloration. I have heard that some think they have to
sell at seven dollars a bushel when contract prices ranged between
$16.00-23.00 this year. If cosmetic appearance is an issue, you might try to
buff the beans up by running them through a seed cleaner with some organic
grain like wheat or oats mixed in. In any case, this year’s crop has a home
for it that will pay well, because the market for non GMO soybeans overseas
adds to demand. Trying to locate the appropriate distribution channel is the
challenge we hope to cover in the next issue.
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