She says that USDA's rules will not monopolize the word "organic," and that
certification involving additional requirements is allowed, although some
people have argued heatedly to the contrary. I think her argument fails on
three points:
1. She offers as an example that an organic baby food label could also say "no
detectable pesticide residues" (assuming, of course, that the claim was
verified by an independent certifier -- but not the organic certifier).
However, this is not an additional *organic* criterion; it is a different
*kind* of criterion, since "organic" doesn't say anything about pesticide
residues. Thus this example does not put to rest the question at hand, which is
whether "organic" may be interpreted more strictly than the USDA standards. A
more relevant question would be, for example: If two years of transition are
required, may a particular certifier who requires three still use the term
"organic"? I think the answer should be "yes", because a three-year requirement
fulfills the two-year requirement. (Does a triangle have two sides? Answer:
yes. Sure, it also has three sides, but that doesn't change the fact that it
also has two sides.)
2. Correctly noting that "organic" refers to a whole system, not a single
provision, Grace questions whether one standard (set of standards, actually)
can meaningfully be said to be "higher" than another. The answer is clearly
yes. If every production system that meets the standards of A also meets the
standards of B, but not the other way around, than A can unambiguously be said
to be a "higher" standard. Sure, sometimes the first system will be stricter in
one provision and weaker in another. In that case, neither can be said to be
"higher," but that doesn't change the fact that sometimes, a set of standards
can be said to be higher than another. Grace confuses the issue by taking
"higher" to mean "more desirable." For example, a requirement of 100% organic
feed, an example she offered, might be undesirable because it unduly restricts
the development of the organic livestock sector, production, but it still is a
"higher" standard than a 90% requirement, say. "Higher standard" simply means
"more restrictive." Whether it is preferable is a separate question.
3. In contrast to additional *kinds* of standards, which Grace says are
allowed, she also says that allowing different standards under the term
"organic" -- all of which at least meet the USDA's -- would interfere with
interstate commerce and create a bureaucratic nightmare. Yet another
certification system functions very well and effectively, despite variation in
standards. That system is the one that certifies foods as kosher. Everybody
agrees on the basics, e.g., no pork or shellfish, no mixing of milk and meat,
etc. However, there is some leeway in exactly how these principles are
operationalized, just as there is some leeway in how organic principles. Some
kashruth certifiers are known to be stricter. Very observant people who want to
adhere to the strictest standards look for one of those certifiers' symbols.
Others are content with a somewhat less rigorous set of requirements, and will
look for any recognized certifier's symbol. Despite the multiplicity of symbols
and the variation in what it takes to earn them, the system works just fine.
So the question remains: May an organic certifier choose to impose stricter
standards than those of USDA (where "stricter" means requiring everything that
USDA requires, plus more)? I can understand limitng what they say to
characterize their standards (i.e., not calling them "better"). But if they
confine their characterization to a strictly factual, noncomparative statement
of their requirements -- e.g., "We permit at most 5% of livestock feed to be
nonorganic" -- I believe the answer should be "yes." Right now, though, it's
not clear what the answer is.
William Lockeretz
School of Nutrition Science and Policy
Tufts University
Medford, MA
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