The misinformation about the proposed organic standards continues
unabated, and Ronnie Cummins is among the worst perpetrators. I have
heard that he is claiming to funders that all the people who responded to
the proposed rule are members of his organization.
Unfortunately, the particular issue that John emphasizes is one that has
been outrageously twisted to imply all sorts of things that are totally
false. I have been working on a long rebuttal to the charges made by the
Pure Food Campaign in an article published in the fall issue of The
Ecologist. What follows is an excerpt from that (still ufinished) letter,
which represents my own knowledge and experience as one of the
authors of the proposed rule that was pubished last year, and as a
twenty plus year veteran of the grassroots organic movement (not an
official USDA position or communication). I wrote it because of my own
need to set the record straight, and will be glad to post the whole thing
once it goes out.
organically yours,
Grace Gershuny
USDA National Organic Program staff
[segment of letter to The Ecologist magazine]
Confusion about label claims and *higher* standards
Another issue cited by the authors as contradicting the NOSB*s
recommendations is the prohibition against certifiers using their seals to
represent *higher* standards. In fact, this provision agrees with the
NOSB*s recommendations about use of certifier seals. One of the main
purposes of the Organic Foods Production Act is to facilitate interstate
trade by establishing consistent national standards for organic
production. There continues to be a lot of confusion about what is
meant by *standards,* especially when the standards reflect a whole
management system approach. Making comparisons between whole
systems according to how strict they are about one provision or another
turns the whole concept on its head. For example, one important organic
principle is to establish nutrient cycling systems, most commonly by
integrating livestock and crop production. A program that requires only
100% organic feed for livestock may appear to have *higher* standards,
but in effect it may discourage crop producers from keeping animals
because of the difficulty in obtaining enough organic feed at a
reasonable price. Is it better to be *stricter* or to encourage integrated
nutrient cycling practices?
Perhaps one reason for confusion about *floor* versus *ceiling*
in standards is that environmentalists and activists are unaccustomed to
the kind of market development regulations represented by this program,
as opposed to the kind of regulations that protect the public from
pollution. It makes a great deal of sense for states to be able to enact
stricter standards for air and water safety than those enacted at the
federal level. Regulations that set standards to facilitate interstate
commerce are a different can of worms. In this case the fight among
certification groups who want to promote their programs by marketing
their certification seals based on differences in standards is misguided,
and has created a more nightmarish bureaucracy than anything the
government could dream up. This is one of the situations that the federal
law was enacted to try to remedy.
To characterize the requirement that products labeled as
*organic* comply with the USDA*s regulations as giving the agency a
*monopoly* on the word is idiotic, as is the claim that it would either limit
free speech rights or *criminalize dissent.* The preamble to the
proposed rule clearly states that individual producers or processors can
continue to make any truthful label claims they wish, and that any
accredited certifier can verify that these claims are accurate. Any
organization that wishes to establish *higher* standards for its members,
owners, or products can do that, and market this claim as it sees fit*fair
labor practices is one I would personally like to see gain in popularity.
For example, if a baby food manufacturer wants all of its ingredients to
be tested to show no detectable pesticide residue it could do so, make
that claim on its product labels, and request its organic certifier to verify
that this standard is being met. The manufacturer*s label could be
promoted as meaning *no detectable pesticide residues.* Under the
proposed regulations, however, the USDA accredited certifier could not
market its logo as a claim of *no detectable pesticide residues* if that is
not a requirement of the federal organic program.
Unfortunately, this is one issue in which deliberate misinformation
has been spread, and which has succeeded in further confusing things
for the public The so-called *eco-labeling* prohibition is also a case of
interpreting a request for public comment as an intent to do something
that nobody wants. The examples we gave of phrases that may
possibly imply that a product was organically produced was included so
that people would know what we were talking about, in hopes that they
would give us specific terms that should or should not be considered the
same as making an organic claim.
[end of segment]