I'm just going to respond to the reference to "economically necessary." No
such concept was ever part of the first proposed rule. You may be thinking
of "commercially available." This is something the organic industry has
used for quite some time, and that is retained in the new proposal for good
reason--but it has nothing to do with the rationale for *practices*, just
organic inupts such as ingredients or seeds. Even here, the claim of
commercial unavailability has to be backed up by documentation.
Grace
At 11:35 AM 3/23/00 -0800, Loren Muldowney wrote:
>
>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.
>
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