We need to bury the USDA once again with thousands of comments to keep them
on track. Otherwise we may be confronted by a final set of federal
regulations early next year which restricts organic agriculture to a small
niche market and opens the door for biotech and factory farm special
interests to control the alternative food network which is rapidly
expanding across the US.
_________________________________________________________________
Comment Letter to the USDA on National Organic Standards (Docket number TMD-00-02-PR)
Dear USDA National Organic Program,
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.
(2) 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.
(3) 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.
(4) 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.
(5) 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.
(6) 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).
(7) The USDA must respond to the many comments made in reposnse to the
first set of proposed regulations regarding fair labor standards on
certified organic farms.
(8) 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
Ronnie Cummins
BioDemocracy Campaign/Organic Consumers Association
6114 Hwy 61
Little Marais, Mn. 55614
Tel. 218-226-4164
Fax 218-226-4157
email: alliance@mr.net
http://www.purefood.org
-- Margo (margos@bigisland.com), May 16, 2000