Recognizing this fundamental principle of organic farming Rodale objected
to the notion of defining organic agriculture as farming without
synthetics. The issue, he said, was not one of synthetic vs.
natural. The reason that organic farming generally rejects synthetic
inputs, he said, is not that they are of themselves bad. Rather, it is that
synthetic inputs, as a rule, are used to circumvent, rather than
enhance natural systems.. Synthetics are usually used as a substitute for
organizing the parts of the system into a productive, self-regulating
whole. (Rodale, 1949) The use of synthetics, therefore, tends to create an
artificial system of individual parts, rather than a natural system
integrated as a functioning whole.
Defining "Organic" Processing
If the word organic defines a farming system, what relationship does it
have to food processing? We believe this is the fundamental question that
is not often asked as part of the organic food processing debate.
On the face of it the answer to the question appears simple. If "organic"
is an adjective that describes a particular system of farming, then the
only food that can be called organic is food that comes directly from such
farms. Since processing is not a part of the farming system that "organic"
describes, technically there can be no "organic" processing.
But one might still conceivably call a mode of processing "organic" if
there were analogies to ecological farming practices in the processing
system. Are there such ecological relationships in processing? In one
respect there may be.
For example, Nichols Fox argues, persuasively we think, that escalating
food borne illnesses are directly attributable to the uniform mediocrity
that we have imposed on our modernized food system. "Whenever there is a
lack of diversity, when a standardized food product is mass-produced,
disease can enter the picture." (Fox, 1997)
In other words Fox is proposing that there is an ecology of food and that
retaining its original integrity may therefore require that its original
wholeness and complexity be preserved. One could argue, then, that
processing which retains the original wholeness and complex ecological
character of food is a kind of "organic" processing.
In any case we argue that processing which fails to retain the original
integrity of the food produced on organic farms should no longer be labeled
as organic food. Such foods should be labeled "made with organic
ingredients." That label would truthfully recognize that some of the raw
materials that went into the food were produced on organic farms, but the
processing used to manufacture the food did not meet the requirements of
retaining its overall original wholeness and complex ecology.
Unfortunately the argument has, until now, turned largely on which, if any,
synthetic ingredients were added.
In other words the organic industry currently defines "organic" processing
in a manner analogous to the way some segments of the industry once defined
organic farming. In some circles farms were once considered organic simply
because they avoided using synthetic inputs. Eventually organic farmers
agreed that an industrial, monoculture farming system, even one that uses
no synthetic inputs at all, is still not an organic farm. Farms that are
not organized as whole, self-regulating natural systems, farms that rely on
off-farm inputs and use therapeutic interventionist strategies to control
pests, cannot be called "organic" just because they use natural or
biological, instead of synthetic inputs. Such farming systems are still
industrial farms. (Rosset and Altieri, 1997, Lewis, Lenteren Phatak and
Tumlinson, 1997, Lampkin, 1990)
Whither "Organic" Processing?
How can our philosophy of organic farming help us clarify the issues
concerning the processing of organic food? Clearly the ingredient list
approach to determining "organic" processing is no more satisfying than the
"input substitution" approach to organic farming. Even if no synthetics at
all are added, do we label as "organic" foods manufactured from raw
commodities produced on an organic farm, but changed so dramatically that
they cannot be recognized as real food? Current rules, focused as they are
on the ingredient list, would require that we say "yes" to that question.
In the certification of organic farms we have now moved fully away from the
ingredient list approach. In order for farms to be certified organic they
must conform to numerous nutrient cycling and natural systems management
requirements. Simply refraining from using synthetics or feeding 100%
organic feed will not suffice. A whole, integrated, natural system must be
in place before a farm can be certified "organic." We need a similar bench
mark for processing.
The National Organic Standards Board obviously agonized over the issue of
defining "organic" processing. But in wrestling with the general standards
for certified organic handling as outlined in the OFPA, it missed an
opportunity to give more substance to the processing debate. The Act
states that "If a production or handling practice is not prohibited or
otherwise restricted under this chapter, such practices shall be permitted
unless it is determined that such practice would be inconsistent with the
applicable organic certification program." (6512) (emphasis ours) In other
words the Act avoided any attempt to specify a particular kind of
processing as "organic," but created an opportunity for the NOSB to
determine what kind of processing practices would be consistent with
organic certification and what kind are inconsistent with an organic label.
The NOSB started down the right track by mandating that a food, to be
certified organic, must be handled so as to "prevent the 'loss of organic
integrity'." (April 25, 1995, Orlando, Florida) But in its final
recommendations six months later (October 31, 1995) the Board failed to
seize the opportunity to delineate the kind of processing practices that
were consistent with organic certification.
Instead, when the Board determined ways in which "organic integrity" might
be lost, it limited itself to the issue of preventing "commingling" and
"contamination" with non-organic product. The NOSB
failed to use this occasion as an opportunity to include certain processing
practices among the ways that food produced on an organic farm could lose
its "organic" integrity.
We believe that "retaining the integrity" of food produced on organic farms
will require us to take this additional step. If the definition of
"organic" is derived from the farming practices that produce the food, then
food can lose that label once its original character has been fundamentally
changed. As soon as food produced on organic farms loses its original
wholeness and complexity or is combined with other ingredients that were
not produced on such farms, then such food should no longer be called
"organic." Foods from organic farms that are used as ingredients in such
altered, processed foods could, and should, be labeled as "made with
Retaining Original Integrity
Of course few organic foods that we eat remain in exactly the form they
were when they were harvested from organic farms. So what changes do we
allow? How do we judge whether a food has been significantly changed? By
what criteria shall we determine whether the "original integrity" of
food produced on organic farms has been retained?
Federal Trade Commission (FTC) staff tackled this question 25 years ago.
Although the rule they proposed was not adopted because of political
interventions, over a seven year period the FTC crafted standards, with
input from many thoughtful experts, that would have established the
requirements for the use of the claims "organic" and "natural" in
advertising. Their work resulted in a framework for claims with four major
(1) organic and natural are two different concepts---one describing a
production system, the other a processing system;
(2) only some foods can be expected to be handled and
(3) the standard for a natural food must incorporate limits on both
processes and additive ingredients;
(4) to meet consumer expectations, commercially produced natural foods
should be similar to those produced in home kitchens. (Raj and Clancy, 1992)
This framework makes it clear that the FTC intended that the requirements
for labeling processed organic and natural foods constitute a two-pronged
standard, limiting both additives and processing.
With respect to labeling organic foods we have the additional burden of
making clear that "organic" is a term that describes a farming system, not
a processing system. We think it is confusing if not misleading,
therefore, to use the phrase "organic processing."
Yet, as Nichols Fox (1997) reminds us, food has its own ecology, and we
ignore that ecology at our peril. We believe that one way to move us to a
more ecological type of food processing is to maintain the wholeness of
food to the full extent possible, and that it is especially imperative that
we retain this integrity in organic food. Processing is what most affects
a food's integrity on the manufacturing side (and the type of processing
then frequently determines what additives are used).
However, even if the processes used do maintain a food's wholeness, we do
not argue that food processing can be described as an "ecological system"
as we do on the farming side.
Because processed foods have become such a large percentage of the food
supply over the last 50 years, a standard that seeks to maintain the
integrity of foods, using the two-pronged requirement, is likely to apply
to a very modest percentage of the supply. That is, the number of foods
expected to meet the standard is fairly small. This logic seems to have
escaped many food manufacturers, a sign that these businesses are not
necessarily interested in maintaining the differentiation or integrity of
natural or organic foods. We seem determined to hammer most of our food
into standardized mediocrity.
The two-pronged standard is essential to maintaining the integrity of
organic food. When the FTC started its work, claims of "natural" were for
the most part intended to convey the perception that the foods contained no
synthetic additives. However, the staff recognized that this did not in
any way capture what manufacturers were doing which greatly diminished the
integrity of foods-processes that dramatically changed the food's wholeness
and particularly affected its nutrient content.
Interestingly, several consumer surveys done around that time showed that
most consumers thought that natural foods were not processed much, if at
all. In fact, a significant percentage thought, not illogically, that only
raw commodities could be described as natural. (Federal Trade Commission,
In light of these facts, it was imperative that the FTC propose a standard
that addressed processes as well as additives. We note here also that a
survey done several years later for the Organic Foods
Production Association of North America (now the Organic Trade Association)
found that natural foods industry members felt that the
processes/operations meeting acceptability guidelines were limited to those
that entailed the use of steam, heat, and a number of mechanical actions.
Those operations using synthetic chemicals as processing aids, additives,
and preservatives were deemed unacceptable. Furthermore, members felt that
there was a clear interaction among processes and additives. (Raj, 1991)
Accordingly, the task before the FTC became one of identifying acceptable
processes---those that would maintain the integrity of foods. On a
continuum these could range from no processing to processes that caused
significant change in many food characteristics. There was recognition
that in most cases cooking, for example, destroys nutrients, and that
cooking was an acceptable process. Thus, there was a need to reach a
reasonable point between none and excessive. Those processes
identified were called "minimal", and by the time the final proposal was
published the list had been discussed and reviewed by chemists,
nutritionists, food technologists and many others.2
At the time there was widespread (and uninformed) consumer expectation that
any chemical additives were "unnatural". But there was a recognition by
all witnesses and commenters that there was a set of chemicals that had
been used in food preparation for hundreds of years, such as salt, baking
soda, baking powder, natural flavors, etc. that should be allowed. The
proposal included these additives, but excluded all others except for
nutrient additives that are added through government mandate for public
The two-pronged standard, which mandates restrictions on both, the degree
of processing and the types of additives allowed, accomplishes several
objectives. Together, minimal processing and limited additive use, come as
close as possible to maintaining the integrity and wholeness of foods and
traditional recipes. They separately and together exclude manufacturing
operations that (to use the language of organic farming) solely substitute
an input or technological intervention for a natural management system. In
essence, the commercially processed foods that carry a "natural" or
"organic" label are, in the main, those that would be prepared by cooks in
home kitchens, using the equipment and food ingredients available in retail
We hasten to add that the standards do not impose dietary restrictions on
consumers. They do impose labelling restrictions that insure that
consumers get what they expect. This means honey as sweetener, whole grain
flours, cold pressed oils, and only natural colors and flavors. It means
fermented foods produced in natural and traditional ways; without
synthesized enzymes or other aids. It means a limited number of naturally
processed or extracted preservatives.
If this two-pronged standard was established for the use of the "natural"
label 25 years ago, can the organic food industry subscribe to a standard
that is any less strict today? We believe that with respect to processing
the same criteria apply to both "natural" and "organic". What distinguishes
organic food from natural food is the farming practices by which it was
The argument on the part of some that we cannot safely produce processed
foods by following the strict two-pronged standard proposed by the FTC is
hollow. In fact, one of the oldest, and largest, organic food
manufacturers in the United States has recently argued passionately for
maintaining just such a strict standard. (Organic and Natural News, April
1999) We suspect the reason that some argue for including additional
processing and additives has more to do with the food system, than it does
with food safety. Several years ago, Susan Hussey, vice president of
marketing and advertising at Aubery Organics, argued that the only reason
synthetic additives were necessary in natural cosmetics was that most of
them had "been developed and used to solve problems of mass production and
distribution." (Natural Foods Merchandiser, November, 1996) We suspect
the same may be true of organic foods.
Finally, there is also an important market reason for adhering to the
strict two-pronged standard proposed by the FTC. Organic foods are
attractive in the marketplace precisely because they are
differentiated. Consumers buy organic because it is "different"---raised
differently, processed differently. The more that differentiation is
accentuated, the more attractive the food is to consumers who shop for it.
The more that differentiation is lost the less attractive it becomes.
Federal Trade Commission. 1978. Proposed Trade Regulation Rule on Food
Advertising: Staff Report and Recommendations. Washington D.C.: US Gov.
Printing Office. September 25.
Fox, Nichols. 1997. Spoiled: The Dangerous Truth About a Food Chain Gone
Haywire. New York: Basic Books.
Lampkin, Nicolas. 1990. Organic Farming. Ipswich, UK: Farming Press.
Lewis, W.J. et.al. 1997. "A Total System Approach to Sustainable Pest
Management." National Academy of Sciences, Proceedings, Vol. 94,
November. Available online at http://www.pnas.org.
Raj, Sudha. 1991. Attitudes of Processors and Distributors Towards
Processing and Processing Guidelines in the Natural/Organic Foods
Industry. Syracuse, NY: Syracuse University. PhD dissertation
Raj, Sudha and Kate Clancy. 1992. "Development of Standards for Natural
Foods." Cereal Foods World. 37:4
Rodale, J.I. 1949. The Organic Front. Emmaus, PA: Rodale Press.
Rosset, Peter M. and Miguel A. Alrieri. 1997. "Agroecology versus Input
Substitution: A Fundamental Contradiction of Sustainable Agriculture."
Society and Natural Resources. 10:283-295.
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