While the new USDA organic standard is a significant improvement over their
original disastrous proposal, there are some remaining problems that require
citizen input to get fixed.
Problem: Higher standards may not be allowed.
Solution: Tell USDA that 205.501(b)(2) and 205.501(a)(12) should be changed to
explicitly state that the federal organic standard only specifies the minimum
requirements that must be adhered to, not the maximum, and certifiers are not
only allowed but encouraged to implement and enforce stronger standards
without permission from government and regardless of whether others do likewise.
We need to leave the door open to continual innovation and a free market of
superior standards above the federal floor to make progress toward true
sustainability. Also, we don't know what a future administration may do to the
federal standard; if it is lowered, certifiers must be able to maintain the
existing level of quality which would then be above the federal level.
Problem: Growers may use certain forms of sewage sludge even though it
contains heavy metals and other toxins.
Solution: Tell USDA that 205.2 should be changed to prohibit any form of sewage
sludge, and that sewage sludge should be defined as synthetic so that the
National Organic Standards Board (NOSB) and the public will have legal authority
to analyze any proposals to change the sewage sludge prohibition in the future,
otherwise changes could be quietly slipped in later.
Problem: Use of certain types of genetic engineering is in limbo, and could be
quietly slipped in later without public oversight.
Solution: Tell USDA that 205.2 should be changed to restore the NOSB definition
of genetic engineering, including their full list of "excluded methods", and
to specify that all forms of genetic engineering are synthetic, so that the NOSB
and the public have legal authority to be involved in any changes, otherwise
weakening changes could be sneaked in later.
Problem: The proposed rule holds organic farmers responsible for the polluting
actions of others and fails to address the economic consequences of gene
pollution, chemical drift, and mandatory spray programs.
Solution: Tell USDA to guarantee that all damage from genetically engineered
and pesticide products, including genetic pollution damage to organic farmers,
is fully compensated by those making and using them, not by organic farmers nor
by the public. This requires that makers and users of genetically engineered products
post a bond to ensure the money is there, and provide public notification of
their use so the locations of potential genetic pollution sources are known to
farmers in the area. Genetic pollution is especially serious since reproducing
genes can cause an irreversible, continually growing problem over time, while
chemical pollution fades away over time.
Problem: Food handlers are allowed to use toxic pesticides if they decide
organic methods are "not effective", while still calling it "organic".
Solution: Tell USDA that 205.271(c) should be changed to unconditionally
prohibit any use of a synthetic substance not approved for organic production.
Problem: Irradiation is not defined and could be slipped in later.
Solution: Tell USDA that 205.2 should be changed to define irradiation to
include all techniques using ionizing radiation, and that irradiation should
be defined as synthetic so that the NOSB and the public will have legal
power over any attempts to weaken the prohibition in the future.
Problem: The fee structures are burdensome for small farmers.
Solution: Tell USDA that the costs of the organic program should not be borne by
organic farmers but by those involved in destructive practices such as use of
toxics, soil erosion, etc. People should not be penalized for doing the right
thing by moving away from practices that can undermine the long-term health of
Problem: USDA may get pressure to undo the things they got right.
Solution: Tell USDA to refuse to weaken the standard's good provisions for:
Ecolabels allowed; Certifier ability to de-certify; 100% organic feed provisions
with no antibiotics or animal parts; Detailed percentage labeling, including
100% organic; NOSB's authority under the law for the National List; USDA as
accrediter, not certifier; Flexible organic plan format; Commitment to reduce
costs on the first round; No antibiotics allowed either in animal feed or in
fruit production; Includes mediation in the appeals process; and Emphasis on
resource conservation and a process-based approach.
You can comment in 3 ways (deadline June 12, 2000):
via the Internet at: www.ams.usda.gov/nop/,
by fax to: 703-365-0760,
by postal mail to:
Keith Jones, Program Manager, National Organic Program,
USDA-AMS-TMP-NOP, Room 2945-So, Ag Stop 0275,
P.O. Box 96456, Washington, D.C. 20090-6456.
Whichever way you comment, be sure to refer to Docket Number TMD-00-02-PR2.
For more info and to get involved:
These have more detailed explanations and language you can cut & paste from:
www.purefood.org/newsletter/biod26.cfm (BioDemocracy News #26 April 2000)
BioDemocracy Campaign/Organic Consumers Association
6114 Highway 61, Little Marais, Minnesota 55614
phone: (218) 226-4164, Fax: (218) 226-4157, email: firstname.lastname@example.org
To subscribe to the free Organic View electronic newsletter, send an email to:
email@example.com with the simple message: subscribe
National Campaign for Sustainable Agriculture
P.O. Box 396, Pine Bush, NY 12566
phone: (914) 744-8448, Fax: (914) 744-8477, email: Campaign@magiccarpet.com
The Center for Food Safety
666 Pennsylvania Ave, SE, Suite 302, Washington DC, 20003
Phone: 202-547-9359 Fax: 202-547-9429 E-Mail: firstname.lastname@example.org
If you're very short on time, download
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