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June 11, 1999
Sorry for any duplication of this paper and the response from Small Planet
Foods (Cascadian, Muir Glen and Fantasy Foods) this is coming in subsequent
email. The third paper in this series will be a response from Organic 4UM to
The mixing of organic farm products with "synthetic" processing aids, food
additives, enzymes, ingredients, colorings and flavorings during the
processing of such products and the potentially subsequently labeling those
processed food products as "organically produced" goes to the heart of
maintaining trust between organic farmers and consumers. Much potential
"synthetic" substances used in food processing could be genetically
engineered or derived from genetic engineering. The potential allowed use of
conventional food "ingredients" as part of the 5% potentially allowed under
OFPA provides a loophole for genetically engineered or derived from
genetically engineered "ingredients" in "organically produced" products.
These are the reasons for understanding OFPA, which states that ONLY
non-synthetic, but not organically produced ingredients can be considered for
petition, review and inclusion on the National List of allowed substances
used in processing "organically produced" food products.
Kate Clancy and Fred Kirschenmann have brought these issues to stage front of
the organic community.
Keeping it "Organic": Making Sense out of the Processing of Organic Food
Kate Clancy and Frederick Kirschenmann
What constitutes an organic farm is now generally agreed upon by
practitioners in the international organic community. This is largely due
to the fact that organic farmers and philosophers, going all the way back
to Sir Albert Howard, Rudolph Steiner, J.I. Rodale, and Mokichi Okada,
have generally accepted a common philosophy of organic agriculture.
While there are still arguments over the extent to which "input
substitution" should be allowed in an organic system, there is overall
agreement that an organic farm is a holistic, agroecological unit,
functioning as a self regulating, natural organism that recycles nutrients
and keeps pests in check. There is a general recognition that introducing
"silver bullet" inputs to insure fertility or pest control
can, at best, provide short term relief while exacerbating the long term
Unfortunately, the organic industry has not yet developed a comparable
understanding of "organic" processing. The absence of such a philosophy
has led to considerable disagreement and debate. The purpose of this essay
is to begin the process of crafting such a philosophy.
Much of the debate has centered on the use of synthetics in processed
foods. The federal Organic Foods Production Act of 1990, which outlines
the framework for the national definition of organic production and
handling in the USA, states that no certified organic "handling operation"
may "add any synthetic ingredient during the processing of any post harvest
handling of the product." [6510 (a) (1)]. The National Organic Standards
Board, on the other hand, specifically allowed synthetic ingredients to be
used in 5% of certified organic processed food so long as the synthetic
ingredient was listed as an "allowed synthetic" on the National List.
(Recommendation adopted October 31, 1995, Austin, Texas).
However, because the legal prohibition on synthetics was emphasized by the
law's lack of criteria for deciding "which" synthetics to allow, the
National Organic Standards Board was reduced to permitting synthetics based
solely on their "essentiality" for the manufacture of the intended product.
During the public comment period on the USDA proposed rule, consumers made
clear their expectation that synthetics would not be allowed in food
labeled "certified organic." When the National Organic Standards Board
revisited the issue at their February 9-11, 1999 meeting in Washington D.C.
the Board, in a deeply divided vote, refused to reconsider its previous
position of allowing synthetics in processed foods labeled "organic."
Back to Basics
Understanding the philosophical basis for any disagreement requires a
return to fundamentals. Arriving at a common understanding of organic
processing requires that we return to the fundamental meaning of "organic."