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Facilitated by Eric Kindberg, certified organic farmer
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Second installment on the premier debate over allowing "synthetic" substances
in "organically produced" products or relegating such "synthetic" treated
"organically produced" products to the "made with organic ingredient"
labeling category as designated under OFPA.
To offer examples: some yogurt processors desire to use a texturizer, some
hotdog processors desire an amino acid like monosodium glutamate, some tomato
sauce makers desire a pH adjuster, some juice processors desire a flavor
enhancer, some bread bakers, mayonnaise makers, chocolate manufacturers
desire an emulsifier like lecithin, some frozen confections and foods desire
a color enhancer, some farmers desire a wax for apples.
Any of these FDA designated "food additives," which includes the category of
"processing aids" can be natural and are allowed under OFPA for use in
"organically produced" food processing.
Federal law does not direct FDA to require that any food processor provide
the consumer with label information on "processing aids" used on a food
All "synthetic" food additives, processing aids, colorings, flavorings,
enzymes and for that matter "ingredients" are prohibited to contact or be
part of an "organically produced" food under OFPA.
OFPA clearly defines SYNTHETIC: The term "synthetic" means a substance that
is formulated or manufactured by a chemical process or by a process that
chemically changes a substance extracted from naturally occurring plant,
animal, or mineral sources, except that such term shall not apply to
substances created by naturally occurring biological processes.
Under OFPA, "organically produced" stands for pure and unadulterated food and
What is your choice?
June 12, 1999
A Response from Small Planet Foods to
'Keeping it "Organic:" Making Sense out of the Processing of Organic Food'
We at Small Planet Foods (Cascadian Farm, Muir Glen, and Fantastic Foods) are
strongly opposed to the changes in organic processing standards suggested in
this essay by Kate Clancy and Fred Kirschenmann. The authors' logic and
supporting arguments are severely flawed and would, if adopted, cause a major
decline in the growth of the organic industry and our ability to change world
Our company goal is to market organic food products as a means to transform
agriculture from conventional production to organic production. We believe
that organic agriculture offers the best solution to the problems of
conventional agriculture: food safety; pesticide contamination of air,
groundwater, and waterways; nitrate contamination of groundwater; and farm
worker safety. We believe that our company goal is consistent with that of
the organic community: to change chemical agriculture to organic agriculture.
Small Planet Foods has been engaged in the production and sales of organic
foods for more than 27 years. Our company and our staff have contributed
greatly to the development of State, private, and National organic standards
that are both strong enough to preserve the integrity of the term "organic"
and practical enough to encourage the conversion of farms and processing
facilities to organic production and processing methods. This response is
grounded in our experience in production scale organic farming, in organic
marketing, and in organic standards development and is motivated by our
belief that the changes in organic processing standards suggested by Clancy
and Kirschenmann would be detrimental to the organic industry if adopted.
The philosophical foundation of Clancy and Kirschenmann's essay is that
organic farming is not only well defined, but that there is widespread
agreement within the organic industry regarding this definition ("…an organic
farm is a holistic, agroecological unit, functioning as a self regulating,
natural organism that recycles nutrients and keeps pests in check"; "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'…"). The authors' logic follows that
because organic processing does not fit this "holistic" philosophical view it
is both inconsistent and incompatible with organics. We challenge this
romantic, idealistic definition of organic farming. In truth, organic
farming as a philosophy or as an ideal is probably well defined and agreed
upon. But, as a practice, organic farming is not so well defined nor agreed
upon. While we concede that such "holistic" farms probably do exist the in
world today, it is clear that they are the rare exception and certainly not a
basis for either definition or for standards setting. We have worked with
hundreds of organic farmers in several
countries and have rarely seen such a farm. The authors' description of
organic farms may be the "ideal" but it certainly does not describe the "real
world" norm. The authors' idealization of reality is detrimental to the
process of organic standards development because it creates a false
impression of the true state of the art. If organic standards are to change
the agricultural world, they must acknowledge the fact that organic farming
and processing have not reached the ideal state described in the
authors'essay but, rather, are in a constant state of refinement and
improvement as they move from the current state of the art toward the
theoretical ideal. Basing organic standards on the theoretical ideal
prevents those who would otherwise convert to organic and work to improve
their farms and processing operations from doing so. The highly restrictive
standard suggested by Clancy and Kirschenmann is counter productive to the
goals of achieving adherence to organic production and processing practices,
of creating a safer food supply, and of improving the environment. Crafters
of organic standards must continue to recognize that both organic farms and
organic processing operations are on a continuum of improvement that leads to
the more "holistic" world of agriculture that the authors view as "generally
agreed upon." Organic standards must continue to provide reasonable
exemptions and variances for organic farmers and organic processors that can
be phased out as the state of the art improves over time.
The basic premise of the Clancy/Kirschenmann essay is that the organic
industry has not yet developed an understanding of organic processing and
that the purpose of their essay is to begin the process of crafting a
philosophy for organic processing. We believe that the organic industry has
a very clear understanding of organic processing and the principles that
govern organic processing practices. The process of internal debate by the
organic industry on the principles of organic processing does not begin with
the writing of this essay, as suggested by the authors, but began over a
decade ago as private and State certifying agents first began to create
standards to govern the certification of organic processors. The development
of such standards generated much internal scrutiny, disagreement, and debate
within the organic community. This debate, like the decades of debate over
organic farming standards by these same certifying agents, has continued to
the present and will continue into the future as our industry standards are
necessarily revised and upgraded through time.
The continuing development of organic processing standards was further
facilitated when the OFPA was passed into law. The development of organic
processing standards that resulted in the recommendations of the Charter
National Organic Standards Board was a result of unprecedented discussion and
debate over organic processing by all stakeholders of the organic community.
For the authors to state that the NOSB did not define organic processing
standards is simply a denial of the facts of the NOSB process from 1992
A key argument of the authors is that synthetic materials are inconsistent
with organic philosophy and should not be allowed in organic processed foods.
But the standards of every U.S. and international organic certifying agent
allow synthetic materials to be used on certified organic farms (synthetic
inert ingredients in crop & livestock materials, soaps, oils, pheromones,
etc). These synthetic materials must be consistent with organic philosophy
or they would be prohibited. If some synthetic materials are consistent with
organic farming philosophy, then, logically, some synthetic materials are
consistent with organic processing philosophy. So, given the fact that some
synthetic materials are internationally recognized as consistent with organic
philosophy, to argue that all synthetic materials should be prohibited for
organic processing is ridiculous.
The current organic processing standards of the vast majority of U.S. and
international organic certifying agents allow the use of some synthetic
materials in certified organic foods. The international organic community
recognizes that some synthetic processing materials are consistent with
organic philosophy. The Charter NOSB was well aware of this fact and worked
to assure that its recommendations for National Organic Standards for
processing would be consistent with the prevailing standards and materials
lists of the organic industry. The authors' assertion that the "NOSB was
reduced to permitting synthetics based solely on their 'essentiality' for the
manufacture of the intended product" is an insult to the NOSB, USDA, and the
organic community. The NOSB procedures for evaluating processing materials
represent the most thorough and comprehensive scientific review of processing
materials ever conducted by any body in the international organic community.
Every processing material reviewed by the NOSB was subjected to the review of
a Technical Advisory Panel which thoroughly evaluated data concerning the
material's environmental impact, the food safety implications of its use, its
consistency with organic principles, and other criteria required by the OFPA.
In addition, the NOSB has adopted additional criteria for evaluation of
synthetic processing materials and has recommended "sunset" provisions that
require review and removal from the National List of any materials deemed to
be unsafe, harmful to the environment, inappropriate for organic processing,
To further their argument against synthetic materials in organic processed
foods, the authors state that consumer comments received by USDA during the
comment period on the proposed rule show that consumers do not want
synthetics in certified organic foods.
We believe that, with regard to consumers' comments about synthetic
materials, we must examine all the data, examine how data were collected,
interpret the results, and then formulate a conclusion. During our many
years in the organic marketplace and during the eleven combined years that
members of our company have served on the NOSB Processing Committee, we have
had the opportunity to discuss synthetic processing materials with many
consumers and many representatives of consumer groups. Generally, we have
found that most consumers are scared by the word "synthetic" and think,
initially, that synthetic materials should not be used by organic farmers or
processors. After explaining to consumers that soaps, oils, and pheromones
are "synthetic" but consistent with organic farming practices, we have found
that they agree that some "synthetics" are OK. When it is explained that
some common food ingredients such as baking powder (found in everyone's
kitchen) are "synthetic," we have found that consumers agree that some
"synthetics" are OK in organic processed foods.
The authors also challenge the types of processing methods that should be
permitted for organic processing stating that organic standards should not
allow processing methods other than those typically used in home kitchens.
They further argue that food processing which fails to retain the original
integrity of the food produced on organic farms should not be labeled
"organic" and that when food produced on organic farms is combined with
non-organic ingredients it should not be labeled "organic." The authors'
position that consumers of organic foods do not want to eat foods that could
not be processed in the home kitchen is analogous to the position that
consumers will only eat foods that are produced on farms using horses or
mules for power. (Do the authors support the use of fossil fuels on organic
farms? Clearly tractors and the use of non-renewable resources are not
consistent with "self regulating natural systems.") Oil expeller presses,
concentrators, and other basic processing equipment used in the most
rudimentary food processing are not found "in the kitchen." To argue that
their use should be prohibited in organic processing is unreasonable.
In defining organic processing the authors state: "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." This statement
is tantamount to saying that if an organic crop is grown in California and
then cooled, packed, and shipped to Boston it is no longer "organic" because
cooling, packing, and shipping are "not part of the farming system that
We also object to the authors' position that acceptable organic food
processing methods should be based on some measure of the retention of the
original integrity of the food produced on the farm. We believe this
approach is fatally flawed because all food processing, from the most basic
processes such as cleaning, removing the outer coat of a seed, grinding, and
cooking to complex processes such as enzyme conversion of starch and expeller
pressing of oil, affect the integrity of the food produced on the farm. We
point out that the negative effect on the integrity and nutritional quality
of food is quite often more severe when mechanical processes and processes
that have been traditionally used "in the kitchen" are used to process food
than when non-mechanical processes such as enzyme, high vacuum-low
temperature, and high temperature-short time processing are used. The
authors' approach to restricting organic processing methods is inconsistent
with international organic industry standards, is off-target with respect to
consumer expectations, and is completely impractical. We support the
current, widely accepted organic industry methods for evaluation of
processing practices that are consistent with organic principles. These
evaluation methods have served the organic industry well by allowing
processing practices that make foods more digestible, more palatable, less
prone to spoilage, and safer while maintaining the basic nutritional quality
of the food.
The authors have, again, failed to recognize existing organic processing
standards and the work of the Charter NOSB by suggesting a "two-pronged
standard" for organic processing based on an old FTC model. In fact, all
current organic processing standards and the recommendations of the Charter
NOSB constitute a "two-pronged standard" as there are restrictions placed on
both materials (ingredients and additives) and processing methods. The NOSB
did, in fact, make recommendations to prohibit certain processing practices
such as irradiation, chemical extraction, chemical peeling, and other types
of chemical processing which are all inconsistent with organic philosophy.
The authors' suggestion that foods labeled as organic should not contain any
non-organic ingredients is unreasonable and inconsistent with the OFPA.
Domestic and international organic standards recognize the use of up to 5
percent (by weight) of non-organic ingredients in organic processed foods.
These standards place significant restrictions on the types of non-organic
ingredients that can be used. This "exemption" in organic processing
standards recognizes that certain ingredients (water, salt, minerals, etc.)
cannot be organic because they are not farm products. This "exemption" is
also consistent with longstanding organic philosophy which recognizes that
organic farmers need certain production "exemptions" such as those granted
for pesticide treated seed, non-organic planting stock, synthetic inert
ingredients, synthetic micronutrient sprays, emergency provisions for use of
non-organic feed, and pesticide residues.
Finally, the authors state in the last paragraph of their essay that:
"Organic foods are attractive in the marketplace precisely because they are
differentiated. Consumers buy organic because it is "different" --- raised
differently, processed differently." We agree completely with this statement
and firmly believe that consumers are endorsing multi-ingredient organic
processed food products every day. This consumer endorsement is based on
actual retailer and distributor organic processed food sales volume not on
speculative opinion regarding what consumers want. While the authors use the
above statement to argue that organic processed food products cause a loss of
market differentiation, consumers' widespread acceptance of organic processed
foods proves that their argument is wrong. Organic processed food products
are highly differentiated and the only real possibility of this changing
would be if the authors' proposed organic processing standards prevailed.
As an industry committed to changing the face of agriculture, we must not be
influenced by the kind of thinking that would only marginalize our
capabilities. We must use logic and reason to assure that organic food
production, which includes processing, packaging, shipping, marketing,
distribution, and other non-"eden-like" pursuits, is not relegated to a small
niche. At the same time, we need to provide encouragement to improve organic
farms and organic processing operations rather than a philosophical approach
that discourages them or, even worse, denies them participation in our
opportunity. Please join us in sending a resounding vote of "nonsense" to
the authors of "Keeping it 'Organic:' Making Sense out of the Processing of
Organic Food." Thank you.
Gene Kahn Craig Weakley Steven
Chief Executive Officer Vice President, Agriculture Director, R &
Charter NOSB Member Charter NOSB Member NOSB Member
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