The deadline (June 10 or 12?) for comments on the latest proposed
National Organic Standards is fast approaching. I've faced the fact
that I will not find the time to even briefly scan the hundreds of pages
in the proposal.
Meanwhile, I've received a pre-printed comment card which makes the
following points (I've severely edited for brevity):
1. Prohibit forever GE, irradiation, and sewage sludge.
2. Eliminate loopholes that might allow animal factories.
3. Reduce fees for small family farmers rather than drive them out of
4. Allow higher standards that exceed the USDA standards. (Let USDA
standards be a floor, not a ceiling.)
5. Don't back down on banning feeding animals to animals, requiring 100%
organic animal feeds, recognize NOSB's authority over the National List,
and create the 100% organic Label.
MY QUESTIONS and COMMENTS:
I agree with #1 and #5. I think it is important that the USDA get lots
of comments to this effect or they might yet give in to high dollar
pressure and back slide.
I also agree with #2, although it is my understanding that individual
certifiers will be able (if they so choose) to prevent unreasonable
On point 3, I wonder what the realistic costs are for certification and
how much benefit the farmer will derive from contact with a knowledgeable
certifier. I don't want small farmers to be driven out of business (I'm
so small, I won't have to certify, but I do buy from slightly larger
operations). I wonder how much subsidy they require and from where it
should come? I'd appreciate comments.
On point 4, I'm under the impression that the new proposal DOES allow
higher standards and also allows certifying agencies to put their own
logo on the product. If so, my comment (as for #1) is that the USDA
should not back track to their previous stand.
On a subject not on the preprinted card, I recall some discussion on
SANET about composting methods which do NO Tallow vermiculture. As I
recall (and I can't seem to locate what I thought I saved of those
discussions) they reference some other standard by which any compost must
be made and that standard addresses ONLY high temperature compost. On
the other hand, the proposal allows raw manure to be applied if certain
time and other constraints are met which, in effect, amounts to sheet
composting and could be stretched to cover vermiculture. If I'm
remembering this correctly, my comment would be that they should update
that standard to include sheet composting and vermicomposting and similar
methods with appropriate safeguards.
I'd appreciate any SHORT comments on this subject to help me finish my
comments before the deadline despite this very busy planting and watering
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