Grace Gershuny wrote:
>
> Actually, the preamble to that proposed rule included requests for public
> comment about what conditions should be considered "necessary" in this and
> a couple of other cases. The intent was to use the public comment as the
> basis to put more specific restrictions into the final rule. The organic
> plan would also have to include a justification that was acceptable to the
> certifier. Overall, there was never any idea that a determination of
> necessity would be totally up to the producer.
It seemed like a real bind, because the two issues were uncoupled. For
example, imagine I agree to the "if necessary" wording, and make
recommendations about circumstances which seem reasonable to me. But
nobody wants to be limited to what I think are reasonable exceptions,
and the result is that those things considered necessary by others but
not by me are now allowed, and I have lost my opportunity to object to
the "if necessary" wording. Everything in the rules were dependent on
15 other things, and could not stand alone, so the commenters' only
guarantee against the egregiously unacceptable was to adopt the "purist"
posture.
I'm afraid the public is conditioned to be suspicious by seeing
"emergency" exceptions allowed every year for 10 years straight with
respect to pesticide registrations, and other such things that they are
not inclined to believe that an "if necessary" clause would ever be
implemented properly. (Yes I know that's EPA, but they did inherit a
lot of the pesticide nightmare from the days when the USDA was in charge
of pesticide registrations.) Plus there was also the use of the wording
"economically necessary" which made the whole term highly suspect. The
public, by necessary, would mean, "this cow will die if untreated"
whereas "economic necessity" can and has justified all kinds of
wrongdoing. So treating an udder infection by cutting back on the feed
and hand stripping 12 times per day and the kind of personal treatment
might be physically possible and be proper treatment for the cow, but
nobody would do it because it would be "economically necessary" to keep
that cow producing at a high level plus nobody has time to fuss over one
cow like that.
Also, There was the underlying problem of the whole conflict of
interest. The EPA and USDA were both actively pushing land application
of sludge, for example. And of course the Ag Sec was going all over the
world telling everybody about how great GMOs were and how it would
unfair not to let them into other countries. That made the agency
suspect from the top down. So anything left up to the approval of the
Secretary seemed like a really bad idea. Not the fault of the NOP, but
not the public's fault either. There was plenty of good basis for
suspicion.
I did imagine that an inspector would be able to inspect itemized lists
of products purchased, which apparently is not possible. But it's not
physically impossible either.
> As for consumer expectations, most consumer groups we heard from
interesting. When I think of consumers, I never think of consumer
groups. I don't think most people belong to any consumer groups. I
only picture the people I know and talk to about consumer issues. I'm
afraid these people go largely uncounted and unrepresented.
> This is also one
> of those cases that erects a barrier only to honest people--with one or two
> inspections a year, it would be very easy for anyone caught in a bind with
> a sick animal to get away with it. It also goes back to the question of
> whether it is better to reassure consumers with rules that are hard to
> enforce, or to take the trouble to educate and inform them.
This is difficult. I tend to favor the type of rules which make it
unprofitable to cheat as a sort of self limiting structure. For
example, if a dairy farm doesn't even have room for the animals to be
pastured nobody can argue that the animals are on pasture. If they do
have good quality pastures, then it would make sense to use them. So
although it would be possible to "cheat" and keep the animals in a
closet all the time right next door to a beautiful, well-maintained
pasture, there isn't much incentive to avoid using an asset you actually
possess. It would be easy and quite unambiguous to verify that a fenced
pasture is there and nutritious forage species are growing.
Anyway, maybe we'll all see a greater use of local food supply, even if
the national organic program totally goes up in flames. That would be a
good thing.
I am sorry for everyone who entered into this process genuinely wanting
something good to come out of it, but maybe the heightened public
awareness is the real payoff. I think that real headway has been made
here.
Thanks for responding.
Loren
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This archive was generated by hypermail 2b29 : Wed Apr 05 2000 - 20:00:33 EDT