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Approved-By:  Laurel Hopwood <[log in to unmask]>
Message-ID:  <l0313030ab524b3f4e4fc@[198.234.69.168]>
Date:         Thu, 20 Apr 2000 09:29:25 -0400
Reply-To: Biotech Forum <[log in to unmask]>
Sender: Biotech Forum <[log in to unmask]>
From: Laurel Hopwood <[log in to unmask]>
Subject:      ACTION ALERT:  Organic Food Standards
To: [log in to unmask]
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Deadline for comments to USDA on National Organic Standards;  June 12

email to  <[log in to unmask]>
or send your comments directly to the USDA via their web site:
http://www.ams.usda.gov/nop
or else make your comments by fax: 703-365-0760
or regular mail: Keith Jones, National Organic Program,USDA-AMS-TMP-NOP,
Room 2945-So., Ag Stop 0275, PO Box 96456, Washington, D.C. 20090-6456

Dear USDA National Organic Program,
re: Docket number TMD-00-02-PR

Although the USDA's March, 2000 proposed National Organic Standards are a
vast improvement over the first proposed rules issued in December, 1997, as
an organic consumer I am very concerned that the USDA adhere to the
following principles:

(1) Do not weaken or dilute any of the following proposed organic rules
published in the USDA's March 2000 document in any manner whatsoever:
Detailed percentage labeling, including 100% organic; NOSB authority to
compile the National List of allowed organic inputs; USDA as accreditor,
not certifier; certifiers' ability to de-certify; allowing ecolabels; 100%
organic feed provisions with no antibiotics or animal parts; flexible
organic plan format; commitment to reduce costs on the first round;
inclusion of mediation in the appeals process, and a commitment to resource
conservation.

(2) Private (i.e. non-governmental) and state organic certifiers must have
the legal right to exercise their free speech, maintain contract
specifications, and protect their trademarks and seals by certifying and
labeling products to higher or stricter standards than the minimum "USDA
Certified Organic" standards. Private and state certifiers must be able to
state on their label that this product "meets or exceeds" or "exceeds" USDA
organic standards. USDA organic standards should provide a "floor" not a
"ceiling" for certification and labeling.

(3) So-called "natural foods" with less than 50% organic ingredients should
not be allowed to use the word "organic" anywhere on their package or
product labels--given that the the non-organic ingredients of these
so-called "natural" products may be genetically engineered, irradiated,
derived from sewage sludge, or produced with pesticides, growth hormones,
or antibiotics. In addition the proposed regulations should  not exclude
retailers who process foods on-site from certification requirements.  The
final regulations should require handlers to attempt to source organic
minor ingredients prior to being allowed to use non-organic ingredients.
USDA rules should prohibit use of the word "organic" to modify an
ingredient that is not organic in a product name on a principle display
panel. The rule should establish new and consistent national standards for
"transition to organic" products, and require more transparency and full
public access to fees, standards, and appropriate records, in order to
maintain the honesty of organic certifiers.

(4)  Although the proposed regulations on organic animal husbandry require
access to outdoors, no clear definition of what constitutes "pasture" are
offered, nor does the USDA delineate exact space or spacing requirements
for humane housing and outdoor access for poultry, pigs, cattle, and other
animals. This proposed set of regulations, as currently written, actually
allows for animal factories. Contrary to its stated goals and international
norms, there are exemptions from the outdoor access and pasture
requirements that would allow for animals to be kept without outdoor access
for most of their lives. A) The exemption for "stages of production" from
requirements for outdoor access must be tightened to exclude major life
stages like milking.  B) Exemptions must not permit operators to keep
animals in dry lots for most of their lifespan. C) Dry-lots must be
excluded from the definition of pasture.  D) Inhumane mutilations of farm
animals that are counter to international norms such as debeaking and
de-toeing of poultry should not be allowed.

(5) Although the USDA claim they don't intend to impose economic hardships
on organic certifiers and farmers, the added costs of USDA oversight will
fall heavily on small certifiers and farmers. The USDA should provide
accreditation services to organic certifiers free of change as well as
subsidize 100% of the costs of any farmer who wishes to become certified as
organic. Beyond this the USDA should allocate funds to pay farmers a
premium price for their products during their "transition to organic" phase
as an added incentive for the majority of farmers to begin making the
transition to sustainable and organic farming practices. We need an organic
program designed the make organic farming the dominant form of American
agriculture, not merely a small niche market.

(6) Penalize the polluters, not organic farmers. Although genetic
contamination of organic crops by "genetic drift" from farms growing
genetically engineered crops is one of the most serious environmental
threats to organic agriculture, no liability provisions for genetic
contamination are delineated in the USDA's proposed federal regulations.
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. A) Manufacturers
of transgenic plants should be held responsible for the consequences,
including the economic impacts of genetic pollution on organic farmers. B)
USDA should seek mechanisms including compensation funds, notification
requirements, and buffer zones which would ensure this requirement. C) The
Rule should also be revised to require compensation for contamination from
government mandated spray programs that affect on-farm organic production.

(7) The USDA's proposed rule, for the most part, lives up to its claim of
prohibiting the Big Three -- Genetically Modified Organisms, Irradiation,
and Sewage Sludge. This is good, but the USDA needs to close the loopholes.
A) While placing a prohibition of genetically modified organisms (GMOs)
into many areas of the Proposed Rule, a general statement prohibiting GMOs
(i.e., "excluded methods") from all aspects of organic production should be
included in the body of the Rule. The USDA has left open the possibility
for future GMO use by narrowing the definition of GMOs and determining that
the allowance of future GMO technologies will be decided by the Secretary
of Agriculture without any clear public role. Furthermore, the USDA claims
that the prohibition on GMOs is based solely on consumer expectation and
not health and environmental concerns. Left unchallenged, this may allow
the USDA to on its own accord include certain GMO technologies in organics
once the consumer expectations have "evolved." The words "prohibited"
and/or "synthetic" need to be included in the definition of "excluded
methods".  B) Unbelievably, while ionizing radiation is prohibited, it is
not defined. This creates a potential loophole for its use.  C) Finally,
while sewage sludge is prohibited, the USDA proposal would allow the use of
toxic sewage sludge that has been burned (toxic sewage sludge ash).

(8) The USDA must respond to the many comments made in response to the
first set of proposed regulations regarding fair labor standards on
certified organic farms.

(9) Finally, while organic agriculture has been the best example of a
successful and sustainable agricultural system in United States agriculture
during the past 50 years, USDA has shown a disproportionate commitment to
biotechnology and conventional agriculture. Organic agriculture needs full
funding in proportion to its market share. Last year the USDA paid out $25
billion dollars to support conventional agriculture, including emergency
funds for farmers. To make the long overdue transition to organic
agriculture--which is the only thing that can save America's family
farms--the USDA must allocate billions of dollars, not a mere six million
dollars as the current proposed organic regulations call for, to ensure a
sustainable and equitable future.

Signed:
Your Name
Your Address
City, State, and Zip Code

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