Back after a 6 month e-mail fast (not a holiday - no phone, no local
ISP).
This is a medium long post
Hi Grace:
I read your letter to "The Ecologist" and would like to preface my
remarks about it by saying that it cleared up a few important points and
certainly didn't seem to me to be the work of the devil in disguise
(although perhaps the OMB deserves that honor). On the contrary, the
human being discernible behind the words appears to be a thinking person
who's had a decent preparation for the position she now holds. I say
this not out any intent or need to be condescending, but because I too
want YOU to be up front with any response that you may care to provide
(and that I do in fact, expect).
It seems to me that at the base of the confusion or conflict - or
whatever you want to call the diversity & divergence of opinions,
orientations & positions taken in relation to "the attempt by USDA to
regulate the labeling of organic products", lies a simple question:
Does certification (by the USDA or anyone else) make it so? I will NOT
call the USDA to account regarding the validity or lack of same for a
rule that doesn't yet exist. (As you clearly point out, what's coming
down is a "proposed" rule, and not even quite the one that WAS proposed
by the USDA National Organic Program staff, thanks to the OMB).
Let's assume for discussions sake that the final rule will in fact be
congruent with the intention, spirit and tradition of organic farming in
the deepest sense of the word. This issue that concerns ME, and one
that I feel was NOT adequately addressed in your letter can be
demonstrated by the following quote from it: "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
[emphasis added], as is the claim that it would either limit free speech
rights or “criminalize dissent.”
I will accept your apology beforehand (if you like) for your poor
choice of words (your use of the word idiotic here was stupid - there,
we're even). The problem is THIS: Compliance with the USDA's
regulations for products labeled as “organic” means COMPULSORY
certification (which of course according the terms of the OFPA, means
USDA certification). Linking certification for goods sold as "certified
organic" within the U.S. to USDA oversight for the "consistent national
standards for organic production" that OFPA pretends to establish is
fine (once again, assuming the standard established is congruent and
supported consensually by the existing organic community).
However, evidently you, others and OFPA equate "organic" labeling with
"certified organic" labeling, when I and others believe that the need
(or lack of need) for certification itself is a matter best left within
the buyer / seller relationship. There are valid reasons to certify.
There are also valid reasons to NOT certify, depending on a number of
variables that either are not taken into account or are de-emphasized,
by both OFPA itself and the USDA National Organic Program staff.
You may claim that your authority originates with OFPA (since the USDA
National Organic Program itself was born from it), and are powerless to
evaluate anything beyond the scope of your job description). If so,
although I can understand and appreciate that, it's not my problem, it's
yours (however, you can count on me for any help you feel I may be able
to supply, as long as my own principles aren't violated by it), and my
principles tell me that compulsory certification invalidates any
benefits that an OFPA without compulsory certification could well
provide.
Once again, the distinction between claiming a given product is
"organic" (which could still be subject to being in conformance with all
aspects of OFPA except compulsory certification - assuming once again,
that an adequate rule is forthcoming) and claiming that it has been
"certified" as organic, is important here. How important? Enough so
that if OFPA requires compulsory certification in order to function
(which is a premise I do not accept), I'd say we're better off without
OFPA.
Lastly, I felt your remarks in the paragraph about "the so-called
“eco-labeling” prohibition" did not fully clarify the "misunderstanding"
(although maybe the divergence in our respective positions is
responsible for that perception on my part - which doesn't make it less
true). I still see an intent to prevent an true organic grower who may
choose to not certify and / or not need to certify, from proclaiming
that his product meets organic (even USDA organic) standards, when it
isn't certified organic. If a valid rule is in the works, let the USDA
supervise the certification process for goods sold within the U.S. -
without mandatory certification. If that means modifying OFPA, so be
it. Make it a valid choice (not compulsory) by giving a valid rule and
it may well do what it was meant to do.
I for one don't question your intentions (just some of your
assumptions). Nor do I assume that this issue can't be resolved, at
least as far as YOU are concerned (for starters). However, it hasn't yet
been resolved and won't be, until it IS resolved. Until then, I don't
anticipate any change in my position, which is one of total opposition
to implementing OFPA as it now reads.
If that is of little concern to you, we'll have to see what happens a
little farther on down the road. OFPA won't work with compulsory
certification. It'll never get off the ground. The divisions are
already too deep.
Feel free to respond directly if you prefer, or consider that the
interest of the majority of Saneters in this issue may be lacking. And
thanks in advance for your response.
--Douglas M. Hinds, Director General Centro para el Desarrollo Comunitario y Rural A.C. (CeDeCoR) (Center for Community and Rural Development) - (non profit) Petronilo Lopez No. 73 (Street Address) Apdo. Postal No. 61 (Mailing Address) Cd. Guzman, Jalisco 49000 MEXICO U.S. Voice Mailbox: 1 630 300 0550 (e-mail linked) U.S. Fax Mailbox: 1 630 300 0555 (e-mail linked) Tel. & Fax: 011 523 412 6308 (direct) e-mail: dmhinds@acnet.net, cedecor@acnet.net, cedecor@ipnet.com.mx
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Back after a 6 month e-mail fast (not a holiday - no phone, no local ISP).
This is a medium long post
Hi Grace:
I read your letter to "The Ecologist" and would like to preface my remarks about it by saying that it cleared up a few important points and certainly didn't seem to me to be the work of the devil in disguise (although perhaps the OMB deserves that honor). On the contrary, the human being discernible behind the words appears to be a thinking person who's had a decent preparation for the position she now holds. I say this not out any intent or need to be condescending, but because I too want YOU to be up front with any response that you may care to provide (and that I do in fact, expect).
It seems to me that at the base of the confusion or conflict - or whatever you want to call the diversity & divergence of opinions, orientations & positions taken in relation to "the attempt by USDA to regulate the labeling of organic products", lies a simple question: Does certification (by the USDA or anyone else) make it so? I will NOT call the USDA to account regarding the validity or lack of same for a rule that doesn't yet exist. (As you clearly point out, what's coming down is a "proposed" rule, and not even quite the one that WAS proposed by the USDA National Organic Program staff, thanks to the OMB).
Let's assume for discussions sake that the final rule will in fact be congruent with the intention, spirit and tradition of organic farming in the deepest sense of the word. This issue that concerns ME, and one that I feel was NOT adequately addressed in your letter can be demonstrated by the following quote from it: "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 [emphasis added], as is the claim that it would either limit free speech rights or “criminalize dissent.”
I will accept your apology beforehand (if you like) for your poor choice of words (your use of the word idiotic here was stupid - there, we're even). The problem is THIS: Compliance with the USDA's regulations for products labeled as “organic” means COMPULSORY certification (which of course according the terms of the OFPA, means USDA certification). Linking certification for goods sold as "certified organic" within the U.S. to USDA oversight for the "consistent national standards for organic production" that OFPA pretends to establish is fine (once again, assuming the standard established is congruent and supported consensually by the existing organic community).
However, evidently you, others and OFPA equate "organic" labeling with "certified organic" labeling, when I and others believe that the need (or lack of need) for certification itself is a matter best left within the buyer / seller relationship. There are valid reasons to certify. There are also valid reasons to NOT certify, depending on a number of variables that either are not taken into account or are de-emphasized, by both OFPA itself and the USDA National Organic Program staff.
You may claim that your authority originates with OFPA (since the USDA National Organic Program itself was born from it), and are powerless to evaluate anything beyond the scope of your job description). If so, although I can understand and appreciate that, it's not my problem, it's yours (however, you can count on me for any help you feel I may be able to supply, as long as my own principles aren't violated by it), and my principles tell me that compulsory certification invalidates any benefits that an OFPA without compulsory certification could well provide.
Once again, the distinction between claiming a given product is "organic" (which could still be subject to being in conformance with all aspects of OFPA except compulsory certification - assuming once again, that an adequate rule is forthcoming) and claiming that it has been "certified" as organic, is important here. How important? Enough so that if OFPA requires compulsory certification in order to function (which is a premise I do not accept), I'd say we're better off without OFPA.
Lastly, I felt your remarks in the paragraph about "the so-called “eco-labeling” prohibition" did not fully clarify the "misunderstanding" (although maybe the divergence in our respective positions is responsible for that perception on my part - which doesn't make it less true). I still see an intent to prevent an true organic grower who may choose to not certify and / or not need to certify, from proclaiming that his product meets organic (even USDA organic) standards, when it isn't certified organic. If a valid rule is in the works, let the USDA supervise the certification process for goods sold within the U.S. - without mandatory certification. If that means modifying OFPA, so be it. Make it a valid choice (not compulsory) by giving a valid rule and it may well do what it was meant to do.
I for one don't question your intentions (just some of your assumptions). Nor do I assume that this issue can't be resolved, at least as far as YOU are concerned (for starters). However, it hasn't yet been resolved and won't be, until it IS resolved. Until then, I don't anticipate any change in my position, which is one of total opposition to implementing OFPA as it now reads.
If that is of little concern to you, we'll have to see what happens a little farther on down the road. OFPA won't work with compulsory certification. It'll never get off the ground. The divisions are already too deep.
Feel free to respond directly if you prefer, or consider that the interest of the majority of Saneters in this issue may be lacking. And thanks in advance for your response.
--
Douglas M. Hinds, Director General
Centro para el Desarrollo Comunitario y Rural A.C. (CeDeCoR)
(Center for Community and Rural Development) - (non profit)
Petronilo Lopez No. 73 (Street Address)
Apdo. Postal No. 61 (Mailing Address)
Cd. Guzman, Jalisco 49000 MEXICO
U.S. Voice Mailbox: 1 630 300 0550 (e-mail linked)
U.S. Fax Mailbox: 1 630 300 0555 (e-mail linked)
Tel. & Fax: 011 523 412 6308 (direct)
e-mail: dmhinds@acnet.net, cedecor@acnet.net, cedecor@ipnet.com.mx
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