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. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - For SC email list T-and-C, send: GET TERMS-AND-CONDITIONS.CURRENT to [log in to unmask]