A few comments on your reply follow:
Your statement is:
"If the intent in establishing organic standards is simply to facilitate
interstate commerce, why treat the USDA organic label any differently from
the label for USDA Choice Beef -- or other existing USDA grades and
There are actually three purposes stated for the Organic Foods Production Act.
It is the purpose of this title
(1) to establish national standards governing the marketing of certain
agricultural products as organically produced products;
(2) to assure consumers that organically produced products meet a consistent
(3) to facilitate interstate commerce in fresh and processed food that is
"Organically produced" is not a grade, a description of texture, a percentage
fat or single word or two description of how a product was produced.
"Organically Produced" is a label provided to those who utilize a system of
organic farming and handling as described by the Organic Foods Production Act
(OFPA). Under OFPA, the systems of organic farming, wild crop harvesting and
handling of the products (processing, packaging and storing) are of such
detail and depth as to hopefully provide the customer with assurance of pure
and unadulterated food and fiber. The organic systems authorized in OFPA
begin with the use of land for 3 years prior to harvest of the raw
agricultural product to the final purchase by a customer of a raw or processed
product. To reduce "organically produced" to a grade would be inconsistent
with OFPA and the depth and breadth of organic farming and handling. .
"No one has to have an USDA meat grader certify their claim
that their beef is "lean" or "grass fed" to protect USDA Choice beef from
disparagement. For most individual producers, certification of any claimed
difference is tantamount to prohibition. The customer can decide for
themselves if the claim of "lean" beef is valid or whether being "grass fed"
means anything. Let the producer prove their claims to their customers -
they are the ones who matter. Having the USDA Choice grade certainly
facilitates interstate commerce in beef - and reduces the dollar and cent
cost of marketing for those who are satisfied with the USDA Choice standard
- -- but it doesn't keep anyone else from claiming their beef is "different"
from USDA Choice. Individuals and producer organizations have their own
standards and labels - such as Laura's Lean Beef and Certified Angus Beef.
The beef market isn't in chaos because of the looseness of its grading and
labeling requirements. So, why do we need fundamentally different language
for organic? It's illegal to stamp beef USDA Choice unless it has been
graded by a USDA grader, and it would be illegal to label anything USDA
Organic unless it has been certified by a USDA approved certifier, period."
The organic market has been and is in chaos because of the diverse and
inconsistent use of the term "organically produced." Everyone suffers:
customers, certified organic farmers, certified organic handlers and potential
customers. The purpose in certified organic farmres and handlers developing a
national organic standard is to assure the customer they are getting what they
are paying for. The organic community needs a consistent and uniform national
organic standard, either by its own consensus and oversight or by the Federal
government regulatory process, to allow the market to expand with integrity.
An organic certifier must have a standard to certify to. Certifiers have done
very well, so far. Presently, there are dozens of organic standards. The
last 6 years of discussing national standard, prompted by working to implement
OFPA have helped synthsize them into a more coherent whole. As of January 1,
1999, the organic community is at a crossroads. The NOSB is not operating as
a public consensus body as it did previous to 1996; the USDA/NOP is not
providing the historical record or administrative support it should to the
NOSB; the USDA/NOP staff are as has always been the case unacquainted with the
the techniques and systems of organic farming, handling and certification.
And yet, the NOSB and the USDA/NOP have the authority to advise and implement
a national organic program.
The organic community
-who have been forging every enlarging markets, ever breaking new ground, not
only in farm food and fiber production techniques and systems, but in
marketing and distribution systems; -who have developed the most sophisticated
standards for food and fiber production in the world;
-who have developed a system to verify utilization of those standards;
-who have spent the last 6 years educating the USDA, the general public,
conventional farmers and businesses about organic farming and handling is not
seeing adequate results from its time, energy and money investment.
What would you do if this was your conclusion? Perhaps, rethink the path we
have taken and see where we might have improved our affectiveness?
In my opinion the two greatest error made in development of the USDA/NOP were:
1. Secretary Madigan not appointing the first NOSB as directed to by the
Senate--"The Secretary appoints the members of the Board. Prior to full
implementation of the organic standards in September 1992, the Committee
recommends that the Secretary appoint farmers who have operated organic farms
under existing state or private standards. Such farmers will have the insight
and knowledge necessary to guide the Secretary in implementing the title."
2. The NOSB not retaining qualified, independent legal counsel to provide
continuing guideance on the the authorities and responsiblities granted under
It appears to me, now is not too late to correct these faults. Since, it is
unlikely, the Secretary of Agriculture is going to correct such faults, it
falls on the organic community to do it themselves and present the USDA/NOP
with the organic community consensus results.
In reviewing the historic growth of organic farming, handling, certifying and
marketing, the organic community can say with pride, we did it ourselves,
without government assistance, without government support. How we choose to
entwine ourselves with the government sector is up to us to decide, even right
to this day. We owe the government nothing. We owe ourselves and our
customers mutual respect and to continue our independent but cooperative
farming and business tradition.
On the marketing side, domestically and internationally, the organic market
expansion is so dramatic, the affect on existing certified organic farms is a
strong pressure to expand. The affect on handling operations is pressured
expansion of diversity of product and supply of product. Conventional food
and fiber processors are beginning to keenly invest. A quality national
organic standard and a strong certifier, private and State, regulatory program
are the tools of managed expansion. Everyone is welcome to join the organic
community for the standards and integrity of the organic community are well
stated and formed. Organic farmers and handlers are not fearful of
conventional and its practices and systems. Organic farmers and handlers are
constantly reacquainting themselves with conventional farming and food and
fiber business history. The questions are simply: Who does set the standards?
and Who does secure adequate enforcement of organic standards? The anwers are
experienced organic farmers, handlers, certifiers and our customers must do
Best regards, Eric Kindberg, certified organic farmer