My name is Eric Kindberg and I am speaking on the behalf of Organic Farmers
Marketing Association or OFMA.
I would like to start off by stating that OFMA has developed a public policy
position calling for total prohibition of Genetically Engineered substances
and their derivatives in organic farming and handling.
Also, I would like to notify the NOSB that OFMA has released a public comment
worksheet on the Issue Papers indicating our position on these issues.
As certified organic farmers, the Organic Farmers Marketing Association
actively supports the National Organic Standards Board in carrying out its
role, as stated in the Organic Foods Production Act, as the consensus builder
and single forum for advising the Secretary and the National Organic Staff on
implementing OFPA.
The last two years have been hectic for all in the organic community.
Expansion in demand, both domestic and international is tumultuous. OFMA
members' that were present at a number of recent NOSB meetings are expressing
a very real concern about the way the NOSB is operating. Perhaps, we are all
a little overworked and certainly overscheduled.
These are our concerns.
1. We must read the language, intent and detailed relationship of subsections
and sections of the Organic Foods Production Act, in order to conform to the
Act of Congress. The two areas of overwhelming public concern are the OFPA
directed National List procedures and OFPA's prohibition on synthetic
substances contacting or being an ingredient in "organically produced"
processed foods. The outcome of failure to conform to the act leaves the
Board's recommendations to the Secretary open to legal challenge.
2. We must review the extensive committee and Board minutes accomplished by
previous sessions of the NOSB. It is imperative to review the NOSB's Final
Recommendations to the Secretary as every issue comes up, to properly build on
the organic community's collective consensus to date. The outcome of the
Board functioning without applicable historical review is repetition of prior
work along with contradictory signals sent to the NOP Staff.
3. Without following the Board's well developed and field proven procedures
for receiving public comment on draft recommendations to the Secretary, the
larger organic community of farmers, handlers, certifiers and customers are
left out of the recommendation development process. The outcome of this
omission of procedure is organic community disillusionment and ultimately
possible rejection of the NOSB and the National Organic Program.
Beyond any particular issue, the NOSB members and the public, in managing and
making decisions, must understand the language and intent of OFPA, the
authority for consideration of an issue. Of parallel importance, the public
must understand and be able to use the NOSB developed draft recommendation
process and procedures by which the issue is considered and decided. The
draft recommendation process and procedures are not functioning properly and
have not been functioning for over a year.
The Organic Farmers Marketing Association does not want the NOSB's
recommendations open to legal challenge, or the Board to spin it's wheels and
confuse the NOP staff, or organic community disillusionment and rejection of
the Board and the NOP.
OFMA believes the NOSB is the critical public/private sector partnership to
assure a National Organic Program is developed in concert with the national
organic consensus.
We are looking forward to working with the NOSB in the development of the
following very important issues remaining for Board recommendation:
· Implementing the NOSB National List petition process
· Developing a criteria for determining whether a substance is "consistent
with organic farming and handling,"
· Developing a numerical rating system for using the National List evaluation
criteria Section 2119(m) to allow or disallow substances in organic farming,
· Developing clear evaluation procedures to determine a non-synthetic, but not
organically produced substances proposed for inclusion up to 5% in
"organically produced" foods "is necessary to the production or handling of
the agricultural product because of unavailability of wholly natural
substitute products" Section 2119(c)(A)(ii),
· Developing a criteria for certifier and NOP determination of "unavoidable
residual environmental contamination,"
· Developing criteria for imported organic product equivalency determination.
· Developing standards for aquaculture and bees and the content of an organic
plan for wild crop sites,
· Developing a numerical rating system for certification decision making,
· Developing a criteria for determination of organic inspector qualifications,
· Developing methodology for public access to certification documents and
residue testing,
· Reviewing of accreditation procedures and recommendation of USDA
accreditation fees, and
· Recommending on how to prevent Genetically Engineered seed, plant, input
substances and GE derivatives being used in organic farming and handling.
Thank you,
Eric Kindberg, OCIA certified organic farm, erorganic@aol.com
Co-Chair Communication/Telecommunication Committee,
The Organic Farmers Marketing Association, www.iquest.net/ofma/
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