From: Debbie Neustadt, Terry Shistar, Rick Skillin, Doris Cellaruis

GMO's           Pesticides        Animal Factories       Family  Farms
Issues Sierra Club Cares About

ACTION NEEDED ** PROPOSED ORGANIC STANDARDS **
YOUR COMMENTS NEEDED THIS IS THE FINAL ROUND --
THE PUBLIC’S LAST CHANCE FOR COMMENTS ON ORGANIC STANDARDS
DEADLINE FOR COMMENTS IS JUNE 12, 2000

Tell Secretary of Agriculture Glickman:

1.      The BIG 3 are Not Dead!  -- LOOPHOLES STILL EXIST AND MUST BE
CLOSED!  A general
statement prohibiting GMOs ( "excluded methods") from all aspects of
organic production should be included in the body of the rule. Genetic
Engineering, irradiation, and sewage sludge could be allowed if current
loopholes are not closed.  Tell USDA
that: Genetic Engineering, irradiation, and sewage sludge  should be
prohibited from
all aspects of organic production because of their health and
environmental
impacts, and not be subject to future approval on a case-by-case review;

that
irradiation must be defined; and that burned sewage sludge (ash) should
not be allowed because it is still toxic. [205.2, 205.204(b),
205.206(f),
205.236(b)(3), 205.270(b)(2)]

2.      Keep Animal Factories out of organic agriculture-- Eliminate the

loopholes and require pasture-based systems for ruminants and true
outdoor access
for all farm animals.  Physical alterations of animals should not be
allowed
without formal NOSB review.  [205.238, 205.239]

3.--Keep pesticides out of organic food.  The proposed regulations would

allow residues of pesticides equivalent to chemically grown food.  Food
contaminated with pesticide residues determined to be average for the
nation will be labeled organic, despite the recommendation that residues
be no
greater than 5% of the legal limit. Tell USDA that Section 205.671(a)
ignores the National Organic Standards Board recommendation under OFPA
Section 2119(k)(5) and should be the lesser of 5% of the legal limit or
5% of the average.

4.      Don’t harm small farmers -- Lower the fees and provide a
cost-share -- Current fee structures are excessively high for small
farmers -- Meeting organic standards should be affordable for  small
farmers. Support small farmers in the global south: Use NOSB’s
recommendations on imports.
[205.236, 205.500, 205.640, 205.642]

Submit written comments with section numbers (bracketed nos.  above) 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; or
Fax comments to 703-365-0760, or comment directly on  the Internet at:
www.ams.usda.gov/nop/.  Be sure to refer to Docket Number TMD-00-02-PR2
in all comments.

View the Rule: March 13, 2000 edition of the Federal Register (available

at most libraries) or at www.ams.usda.gov/nop/.

For more information:
www.SustainableAgriculture.net, www.rafiusa.org; www.ucsusa.org;
www.hsus.org; www.ny.nofa.org; www.centerforfoodsafety.org.

Other issues you could discuss:

5. Don’t hold organic farmers responsible for the polluting action
of others: gene pollution, chemical drift, and federal and state
mandatory spray programs -- farmers cannot and should not have to
control
pollution that comes to their farm from outside -- make the polluter
responsible.
[205.201]

6. Specify Systems for Enforcing Organic Standards -- Spell out the
specific responsibilities and authorities of states, private certifiers,

federal agencies, and citizens to make complaints, investigate
violations, halt the sale of products, and impose penalties. [205.400;
205.404; 202.405; 205.660]

7.  Equalize the  public/private partnership --  allow for continued
higher standards and farmer innovation;  keep the private certifier
system;
keep strong public participation in the ongoing development of standards

and implementation of the program. Restore NOSB’s peer review
recommendations.
[205.400, 205.501, 205.505, 205.507, 205.509]

8.  Hold Organic Standards high for retailers, handlers, and
transitional products.  Meet consumer expectations for consistency and
clarity in an organic label. [205.101, 205.102, 205.301, 205.303,
205.606]

 9.  Don't backslide on high standards. MAKE SURE THE PRESSURES FROM
ELSEWHERE DON'T WEAKEN HIGH STANDARDS IN THE FINAL RULE.
SUPPORT USDA IN THE PLACES THEY GOT IT RIGHT!:
Detailed percentage labeling, including
100% organic; NOSB’s authority under the law for the National List;
USDA
as accrediter, not certifier;   Certifiers’ ability to de-certify is
recognized; Ecolabels are allowed;  100% organic feed provisions with no
antibiotics or
animal parts; 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.

9.      Don’t Backslide on high standards -- Support USDA in the places
they Got it Right!  Make sure that pressures from elsewhere don’t weaken

high standards in the Final Rule:  Detailed percentage labeling,
including
100% organic; NOSB’s authority under the law for the National List;
USDA as
accrediter, not certifier;   Certifiers’ ability to de-certify is
recognized;
Ecolabels are allowed;  100% organic feed provisions with no antibiotics
or
animal parts; 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.

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