Thursday, March 23, 2000, 10:14:49 AM, you wrote:
CH> d hinds argues that:
Actually, d hinds *predicts*:
CH> OFPA is doomed to fail unless the compulsory certification aspect is
CH> i would argue on the contrary that ofpa is doomed to fail if the
CH> compulsory aspect is removed . . .
CH> part of the problem here is that this is regulatory territory
CH> where we do not have a lot of previous experience . . .
That is a valid basis for mandating obligatory USDA Organic
Certification for any product sold as organic (an area in which "we
do not have a lot of previous experience")?
CH> most of our previous experience is with certifying and labeling
CH> the material content of products (e.g., fat-free) . . . in
CH> contrast, organic is about certifying and labeling the process by
CH> which a product was produced
Organic is one thing OFPA is another. Read it and you'll see that
organic is whatever is OFPA / USDA Certified Organic. This is very
dangerous, particularly when the head of agency responsible states
that this in no way supposes that organic food is healthier than
conventional supermarket fare. If there are no shared values, no
sympathy with or understanding of the principles involved; what makes
you think that the results will be anything than another costly and
muddled bureaucratic boondoggle - even if and when a consensus is
reached regarding the Organic Rule. I fear your point of view is
<I snipped a highly hypothetical example>
CH> i would argue that not regulating against these kinds of similar
CH> labels permits the chaotic situation that the law was designed to
CH> it is my understanding that ofpa and the proposed rules do allow
CH> labels of organic food to make additional content or process
CH> claims so long as they do not overlap with the organic claim,
CH> e.g., "organic and free-ranging" meat, "organic and sulphur-free"
CH> fruit cheers,
Not everyone wants, needs to or is willing to be relegated to
"organic" (meaning obigatory OFPA / USDA Certified Organic, with all
the costs, excesses and contradictions that will entail), before
stating the facts regarding their product.
Others will be more than glad (or resign themselves) to go through the
rigmarole involved, as a another cost to pay. But for many, it won't
be appropriate, and some of those won't kowtow to it.
I also suggest you read the Bill of Rights. As Bart pointed out, ample
legal precedents exists for shooting down the kind of police state
legislation you seem to think is called for.
OFPA is doomed to fail, all right - in practice and in court.
It could work in practice if and when a consensus is reached within the
organic community and the organic rule is congruent with that - but
only as an option that's available through free choice (i.e for those
that need, want or value that). It will sink or swim on it's own hook.
As written, it's unenforceable. (And maybe it shouldn't be).
I'm being quite candid and want to get right to the point, but respect
your right to hold a distinct (if weak) opinion.
Time will tell.
CH> -----Original Message-----
CH> From: Douglas Hinds [mailto:email@example.com]
CH> Sent: Thursday 23 March 2000 9:28 AM
CH> To: Loren Muldowney
CH> Cc: sanet
CH> Subject: USDA Organic Certification (was: being a heretic/antibiotics)
CH> Hi Loren,
CH> Thursday, March 23, 2000, 8:11:56 AM, you wrote regarding Graces'
>>> USDA's attempt to provide flexibility for antibiotic use only "if
>>> necessary" was attacked as contradicting consumer expectations,
LM>> How do you think the "if necessary" idea could be implemented? I recall
LM>> that the circumstances under which "necessary" might be determined were
LM>> not specified.
CH> But they *could* be - antecedents for this are found in most organic
CH> certifier's regulations for organic honey (for example), where only
CH> certain antibiotics can used, and only for certain bee diseases. Other
CH> conditions could also be specified, such as the preliminary
CH> precautionary measures that must be taken prior to treatment with
CH> antibiotics, with a given minimum time interval stipulated between the
CH> time those preventative measures are taken and the time the treatment
CH> is applied, possibly along with alternative treatments methods that
CH> must be tried prior to resorting to antibiotics.
CH> However, my main point regarding OFPA is this: I have no quarrel with
CH> the USDA's getting into the organic certification business as another
CH> additional option for farmers (or processors) and consumers, since the
CH> actual trade relationship occurs no where else - it's present only in
CH> the buyer / seller relationship, which in turn can be subject to legal
CH> This means that (on the one hand) the USDA can compete on a level
CH> playing field along with everyone else, offering a "value added"
CH> service for those who feel there's value in it and are willing to pay
CH> for it; and / or (on the other hand), in conjunction with the
CH> traditional organic community, reach a consensus that establishes a
CH> minimum, national standard for what is and what isn't organic, one
CH> that's also congruent with international organic standards, so that US
CH> certification processes remain credible or regain credibility.
CH> That's ALL that's required and all that can be legitimately done.
CH> BUT - that's NOT what OFPA sets out to do. Instead of doing the latter
CH> and relying on "Truth in Labeling" laws along with provisions for
CH> invoking a specialized organic review and appeals process, it's a
CH> labeling law itself; thereby establishing a monopoly on the use of the
CH> word "organic" - a word currently in the public domain, whose use is
CH> supported by many more years of effort and much more philosophic basis
CH> than went into (or came out of) developing OFPA. (Just ask Grace,
CH> Bart, Chuck, Steve or Eric).
CH> OFPA is doomed to fail unless the compulsory certification aspect is
CH> removed. It spells the END of the organic market, as it has come to
CH> exist. It simply achieves the opposite of what it supposedly set up to
CH> do: Simplify and clarify the organic certification process, making it
CH> more accessible to both growers (+ processors) and consumers.
CH> Instead, OFPA drives a bureaucratic wedge between the organic buyer &
CH> seller, between the organic and conventional markets (favoring those
CH> in the latter with lower costs, in spite of the relative lack of
CH> socially and ecologically conscious criteria applied to conventional
CH> ag production and distribution systems), between the big and small
CH> organic grower and between the public and the governmental bureaucracy
CH> foisting this GMO (made of incongruent bits and pieces that don't fit
CH> together) type, shoddy example of a piece of legislation.
CH> The end result betrays EVERYBODIES best efforts and intentions. Is
CH> there anyone as yet not convinced of that?
CH> There you have it. Where do the comments have to go? (On the USDA /
CH> NOP website, I assume). We're now in the second 90 comment period for
CH> the Organic Rule?
LM>> It seems safe to say that every time anybody gives an antibiotic to a
LM>> cow, it has been decided that it is necessary to do so. There were and
LM>> are a whole lot of people who think that methyl bromide is "necessary"
LM>> and daily sub clinical antibiotics is necessary and anhydrous ammonia is
LM>> necessary and the roundup ready trait is necessary too. So many things
LM>> are necessary.
CH> To some. What's necessary to organic milk production and under what
CH> conditions, is what must be defined,
LM>> And it DOES contradict consumer expectations. Does that count?
>>> and so the purist position that penalizes farmers
>>> like the Amish has won the day.
CH> There were so many hurt by things OFPA didn't foresee, that more harm
CH> than good is the result.
LM>> If I had a personal choice (perish the thought) between buying milk from
LM>> a neighbor I trust and buying certified organic milk from some big
LM>> store, I'd head to the neighbor's, for many reasons. Once that
LM>> connection is severed and the trust aspect is missing, then no
LM>> exceptions are possible, because that requires that I trust someone I
LM>> don't trust, or even know.
CH> Very true. The "label" mentality (let someone else decide), seems to be
CH> winning out over the "observe, become informed and judge for yourself"
CH> point of view. This is also exactly wherein lies the difference
CH> between sustainable and conventional agriculture, and well as standard
CH> and GMO seeds. The supposed equivalents - the proprietary, patented
CH> inventions and easily bottled & sold concentrated substances, are far
CH> removed from nature and the processes that gave rise to life as we
CH> know it, just as the reasons for them have been abstracted to ad
CH> nauseum and ad ridiculation.
LM>> If it is really true that antibiotics are seldom needed for a properly
LM>> managed milk cow, then the overall burden of removing from organic
LM>> production those animals which must be treated will be light, and
LM>> animals which have the lowest infection rate will be favored over those
LM>> with the highest production.
CH> The problem lies in defining seldom, if ever.
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