California Certified Organic Farmers' (CCOF) official response reads thus: "The proposed rules as they stand, are so unworkable that we feel they must not be implemented. They would decimate general organic standards; and they are contrary to organic principles, the recommendations of National Organic Standards Board and CCOF's own standards."
"As we see it, the USDA's proposed rule blurs the lines between conventional and organic agriculture. The Organic Foods Production Act of 1990 was originally enacted because Congress recognized that organic production is different enough from conventional agriculture to justify its own clear definition," said a spokesperson for the Organic Trade Association (OTA).
The OTA, after its study of the lengthy and complex proposed regulations and after analyzing the significant input from the industry, cites eight key areas of concern that, if left unchanged in the final draft, would force the OTA and other organizations in the organic industry to "take a serious look at the validity of these federal regulations," according to the spokesperson. "We must insist on national standards that stick to the true meaning of organic. The proposed rule does not accomplish that objective."
Here are the eight most serious threats to organic integrity, taken from lists of over100 points in the rules that would undermine organic standards. The rules are a farce and a real slap in the face:
1. Missing the "Big Picture" by eliminating key concepts - The definition of organic as written in the proposed national organic standards lacks the holistic approach central to organic practices. The proposed rules take a reductionist approach to organic food production that eliminates key concepts such as the health of the agro-ecosystem and biodiversity on the farm;
2. Ignoring the recommendations of the National Organic Standards Board - The USDA undermines the NOSB's authority in this draft of the proposed regulations. The USDA has ignored the clearly mandated authority the NOSB was given in the Organic Foods Production Act of 1990 to recommend the National List of Materials for Organic Practices;
3. Possible inclusion of genetically-engineered organisms (GEOs) in organic systems - The use of GEOs is an unproven technology that the organic system does not need in order to grow high quality and nutritious food. There is not enough scientific data documenting the long-term impact GEOs will have on the environment or human health.
4. Possible inclusion of food irradiation in post-harvest organic production - Food irradiation (ionizing radiation) as a synthetic process has never been allowed in organic production. The long-term effects of irradiation are still unknown and it is not a panacea to food safety concerns.
5. Possible inclusion of biosolids (sewage sludge) in organic farm practices - Sewage sludge from municipalities' waste may contain heavy metals and toxins and is not, therefore, appropriate for use on land where food is to be grown for human consumption. The use of sludge has never been allowed in organic food production and is completely unnecessary.
6. Weak livestock section - The livestock section is weak as currently written and gives too much leeway in the amount of non-organic livestock feed, types of living conditions and use of antibiotics and other animal drugs allowed in organic production. The organic industry expects the regulations to include the use of only 100% organic feed and consumers expect absolutely no antibiotics in organic meat and dairy production.
7. Unnecessary loopholes - Loopholes were created when the U.S. Department of Agriculture (USDA) eliminated the carefully worded restrictions on the use of materials common to the current organic standards, replacing them with new terms such as "active" and "non-active" synthetics and ingredients. There is no historic or legal reason to create new terms. These loopholes will allow synthetic materials and ingredients in organic production that have never been allowed before.
8. Weakened de-certification authority - Under the proposed rules, the authority to decertify growers, processors and manufacturers has been placed solely in the hands of the Secretary of Agriculture. As a result, there would be no efficient de-certification process and therefore products not meeting organic requirements may remain on market shelves longer. Enforcement of certification standards, currently placed in the hands of private certifiers, may be weakened through what will inevitably be a lengthy bureaucratic process.
Send comments to: Eileen S. Stommes, Deputy Administrator, USDA-AMS-TM-NOP, Rm. 4007 -So. AG Stop 0275, Box 96456, Washington DC 20090-6456.
For further information phone Tim Bates, (707) 895-2333.
Copyright Mendocino Environmental Center 1998
Permission granted to excerpt or use this article if source is cited