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Don't Panic - Save Organic



(text file also attached)

what's the deal with the new usda organic regulations? 

read on, forwarded comments from Steve Gilman, about what steps to take
next...

apologies for the inevitable cross posts


_Don't Panic - Save Organic_
         by Steve Gilman

The following is my personal response, somewhat starkly put, to recent E mail
positions by Steve Sprinkel _The Mouse That Roared_,  Mark Lipson -- _The
Rule Blues_, and Eric Kindberg's response to Rule Blues as well as phone
conversations with Elizabeth Henderson of the Campaign for Sustainable
Agriculture and articles in the national press. Since NOFA will be playing a
role in the upcoming retreat for the Northeast Interstate Certification
Committee I think it is important to get some talking points and other
contributions on the table from Interstate Council members and others for
discussion purposes.

1. By now, it is well evident that USDA's National Organic Program (NOP)
Rules bear little resemblance to the original 1990 Organic Food Production
Act (OFPA) and are insidiously cynical at best -- and fraudulently illegal at
worst. It is completely disingenuous and manipulative for USDA, at this
point, to put up the questions of allowing genetically modified organisms
(GMO'S), food irradiation, sludge, use of synthetics, inerts, antibiotics and
confinement operations in livestock, etc., etc., etc. to the public for
comment. This is a no-brainer -- not by any stretch are these Organic
practices as defined by the country's (and the World's) existing
certification programs, the OFPA or the years of work by the National Organic
Standards Board (NOSB) that was legally constituted to work out the
definitions of acceptable practices, procedures and products.

2. We've all known that this day would finally come, while all along the
release date of the NOP rules has been a running sick joke -- they were
originally due by October, 1993. Despite all the countless, good faith hours
and deeply considered input contributed by a lot of dedicated organic
supporters across the country -- THIS is all that USDA could come up with! 

The good news is that in the process our _Industry_ has tackled most of the
hard questions that have divided us organic farmers, handlers, processors,
advocates and consumers, etc. through the NOSB process and, in fact,we have
already all taken a series of collective giant steps together. It might not
be too difficult at this point to put together an overall, private,
industry-based National Organic Program of our own.

3. In terms of what action we should take next, the appropriate working
analogy is what happened to the proposed changes to the _Made in the USA_
legislation in early December. There, various industrial interests tried to
get the Federal Trade Commission to change their rules to allow a greater
percentage of foreign manufactured materials in American-made goods that
would still qualify for the federal _Made in the USA_ logo/label. The ensuing
stink was swift, sure and deafening from a large, previously unlikely
coalition of (U.S.) Businesses and Labor Unions and the measure was shot down
completely and definitively. 

4. It is incumbent on us all to now marshal as much vast public and media
support as possible and raise a Huge Stink of our own -- or _Organic_ as any
kind of a meaningful term/label will go down the tubes forever, and another
notch will get carved on the gun butt of Big Food. This time also presents a
huge opportunity -- the world is watching, many people care and alot of
others may be brought into the organic fold when they see it -- and their
freedom to choose via a trustworthy label -- being victimized and trashed by
Agribusiness and their Governmental minions.  At this point, given the total
insincerity of the NOP rule makers and their bosses, its hard to see how we
can possibly hope to salvage these Rules and convert them to Real Organic.
The same process which produced what we got now will most likely not be ABLE
to do any differently if and when the process is allowed to proceed to
fruition. It also will be next to impossible to rally support in the hopes of
fixing something so completely flawed -- from our own farmers and supporters
as well as a thoroughly confused public. No, these Rules must be completely
rejected NOW.

5. This has to be done with complete responsibly. The public should
understand that they are already well protected through the existing
certification programs. The media has already built up tremendous public
expectations based solely on the legitimacy of a USDA label -- the public has
to be told loud and clear what the USDA has done/is doing to the definition
of Organic and the public's freedom of choice.  Having some additional Big
Issues -- such as USDA's continuing discrimination against organic and lack
of research, programs, staff support,etc. is all demonstrable. It never hurts
to have a national forum to passionately state our case.

6. It is important to realize the position everyone is in. This comes at a
time when the Clinton Administration is vastly increasing funding for new
_safe food_ protections and USDA is beginning a major campaign to win the
hearts and minds of the public to the benefits and glories of bio and other
food technologies -- based on True Science -- while forcing open the doors of
foreign trade to our GMO exports. Agribusiness doesn't want any labeling of
anything, period (a la Bst in milk). The Nuclear industry  is looking for a
place to dump its cobalt (irradiation in the name of food safety) and the
Waste industry its sludge. And in the middle of everything here comes the
Organic label up for grabs, literally.  Secretary Glickman, a longtime friend
of Biotech, talks the old line that organic can't be officially considered
better, safer, etc. than anything else -- but the mere presence of organic,
so rapidly rising in the marketplace due to huge, widespread consumer demand,
is threatening in itself. Meanwhile, Agribusiness is famous for giving huge
and regular campaign contributions to Republicans and Democrats alike and
USDA officials themselves have been known to be treated kindly -- the system
is systematically corrupted. Since the 6, 7, 8 and 9 figure incomes of
Corporate managers and executives as well as stock values, etc. are
contingent on agribusiness as usual -- well, you do what you know how to
do.... its just business. The Government R US, however -- its up to us
citizens to reclaim it!  

7. Therefore what we need is a National Campaign to Save Organic, or
somesuch. An energetic combination of national, local and grass roots
initiatives is necessary to defend Organic. A good case in point, albeit on a
smaller scale, is the action over the Summer of 1997 conducted by NOFA-MA
against Baystate Organics, a Boston sludge processor. The purpose of the
action was to get them to change their name and stop labeling their
fertilizer products as _organic_.  A well organized, concerted campaign with
letter writing, media alerts, legislative lobbying and on-site public
protests proved ultimately to be very successful. In the process, a lot of
people were educated about organic and NOFA-MA gained a number of valuable
new members and supporters.

8. Our diverse organic groups across the country should individually and
collectively petition Senator Leahy to conduct an immediate Congressional
investigation of this whole mess. There may also be some additional recourse
through the Courts -- which should also be vigorously pursued. Currently, for
example, NOFA has joined with over 30 other farming, environmental and
advocacy groups under the auspices of Greenpeace's legal department to
petition/sue EPA to stop the field release of transgenic Bt in order to
prevent sure and immediate pest resistance to this important biopesticide
which has been in wide scale use by conventional and organic farmers alike
for 40 years now. Part of the legal case is based on the fact that EPA has
violated its own rules in its own processes. In addition, we need
professional expertise to go over the legality/illegality of USDA's NOP Rules
action. Not only has our Industry lost valuable time -- and suffered major
economic losses due to the extreme lateness of this Rule, but also we are now
 back at square one. To quote Secretary Glickman at USDA's Rules Press
Conference, _One, unified standard could clear the path and unleash even
stronger growth in the organic industry. National standards would clear a
similar hurdle on the international front. ...Greater income for small
farmers and ranchers, stronger exports, one high consistent standard for
consumers -- clearly we have a lot to gain from this rule._ In addition, the
propose they d Rules place extreme fee barriers on the certifying agents
which stand to drive many out of business and automatically disqualify a lot
of small farmers who can't ante up in USDA's high price game. 

9. Finally, as an Organic vegetable farmer I've been dealing with some of the
same restaurants in our area for some 22 years now, as well as a CSA since
1990 and if _Organic_ gets trashed and co-opted I'll get by fine on my own
earned reputation and I know many other farmers are in this position. I'm not
about to let _Organic_ go however. There's alot of good people out there who
have a true interest in rejecting such a perpetuated fraud. Any co-opted USDA
label would quickly become a laughing stock and a national _Real Organic_
label could quickly capture the marketplace... The truth is that we've all
bargained in good faith and actually have alot to show for it -- the OFPA and
the NOSB process still stand as a valid agreed-upon basis for Organic. USDA
is still legally bound to comply with its mandates. If it takes them another
7 years or more to try and put something out again, so be it -- its time now
that our national Certification groups rounded up the wagons anyway -- the
public deserves and is demanding an overall label that certifies the
certification programs and such an industry label could become as important
and legitimate in the marketplace as any USDA one, even more so.  From the
larger perspective, we've really struck the raw nerve at the heart of today's
overblown and declining industrial food system -- just by the nature of our
being. More and more they're having to resort to extreme, desperate and
dangerous mega-technological fixes (like irradiating our food) just to stay
in the same place. So -- here's this titanically huge agribiz/governmental
entity that has just run into the smallish-appearing tip of a what is really
an incredibly large iceberg...

Steve Gilman  
NOFA Interstate Council 
Ruckytucks Farm 
130 Ruckytucks Road Stillwater, NY  12170 
sgilman@netheaven.com
Don't Panic -- Save Organic         by Steve Gilman

The following is my personal response, somewhat starkly put, to recent E mail positions by Steve Sprinkel _The Mouse That Roared_,  Mark Lipson -- _The Rule Blues_, and Eric Kindberg's response to Rule Blues as well as phone conversations with Elizabeth Henderson of the Campaign for Sustainable Agriculture and articles in the national press. Since NOFA will be playing a role in the upcoming retreat for the Northeast Interstate Certification Committee I think it is important to get some talking points and other contributions on the table from Interstate Council members and others for discussion purposes.

1. By now, it is well evident that USDA's National Organic Program (NOP) Rules bear little resemblance to the original 1990 Organic Food Production Act (OFPA) and are insidiously cynical at best -- and fraudulently illegal at worst. It is completely disingenuous and manipulative for USDA, at this point, to put up the questions of allowing genetically modified organisms (GMO'S), food irradiation, sludge, use of synthetics, inerts, antibiotics and confinement operations in livestock, etc., etc., etc. to the public for comment. This is a no-brainer -- not by any stretch are these Organic practices as defined by the country's (and the World's) existing certification programs, the OFPA or the years of work by the National Organic Standards Board (NOSB) that was legally constituted to work out the definitions of acceptable practices, procedures and products.

2. We've all known that this day would finally come, while all along the release date of the NOP rules has been a running sick joke -- they were originally due by October, 1993. Despite all the countless, good faith hours and deeply considered input contributed by a lot of dedicated organic supporters across the country -- THIS is all that USDA could come up with! 

The good news is that in the process our _Industry_ has tackled most of the hard questions that have divided us organic farmers, handlers, processors, advocates and consumers, etc. through the NOSB process and, in fact,we have already all taken a series of collective giant steps together. It might not be too difficult at this point to put together an overall, private, industry-based National Organic Program of our own.

3. In terms of what action we should take next, the appropriate working analogy is what happened to the proposed changes to the _Made in the USA_ legislation in early December. There, various industrial interests tried to get the Federal Trade Commission to change their rules to allow a greater percentage of foreign manufactured materials in American-made goods that would still qualify for the federal _Made in the USA_ logo/label. The ensuing stink was swift, sure and deafening from a large, previously unlikely coalition of (U.S.) Businesses and Labor Unions and the measure was shot down completely and definitively. 

4. It is incumbent on us all to now marshal as much vast public and media support as possible and raise a Huge Stink of our own -- or _Organic_ as any kind of a meaningful term/label will go down the tubes forever, and another notch will get carved on the gun butt of Big Food. This time also presents a huge opportunity -- the world is watching, many people care and alot of others may be brought into the organic fold when they see it -- and their freedom to choose via a trustworthy label -- being victimized and trashed by Agribusiness and their Governmental minions.  At this point, given the total insincerity of the NOP rule makers and their bosses, its hard to see how we can possibly hope to salvage these Rules and convert them to Real Organic. The same process which produced what we got now will most likely not be ABLE to do any differently if and when the process is allowed to proceed to fruition. It also will be next to impossible to rally support in the hopes of fixing something so completely flawed -- from our own farmers and supporters as well as a thoroughly confused public. No, these Rules must be completely rejected NOW.

5. This has to be done with complete responsibly. The public should understand that they are already well protected through the existing certification programs. The media has already built up tremendous public expectations based solely on the legitimacy of a USDA label -- the public has to be told loud and clear what the USDA has done/is doing to the definition of Organic and the public's freedom of choice.  Having some additional Big Issues -- such as USDA's continuing discrimination against organic and lack of research, programs, staff support,etc. is all demonstrable. It never hurts to have a national forum to passionately state our case.

6. It is important to realize the position everyone is in. This comes at a time when the Clinton Administration is vastly increasing funding for new _safe food_ protections and USDA is beginning a major campaign to win the hearts and minds of the public to the benefits and glories of bio and other food technologies -- based on True Science -- while forcing open the doors of foreign trade to our GMO exports. Agribusiness doesn't want any labeling of anything, period (a la Bst in milk). The Nuclear industry  is looking for a place to dump its cobalt (irradiation in the name of food safety) and the Waste industry its sludge. And in the middle of everything here comes the Organic label up for grabs, literally.  Secretary Glickman, a longtime friend of Biotech, talks the old line that organic can't be officially considered better, safer, etc. than anything else -- but the mere presence of organic, so rapidly rising in the marketplace due to huge, widespread consumer demand, is threatening in itself. Meanwhile, Agribusiness is famous for giving huge and regular campaign contributions to Republicans and Democrats alike and USDA officials themselves have been known to be treated kindly -- the system is systematically corrupted. Since the 6, 7, 8 and 9 figure incomes of Corporate managers and executives as well as stock values, etc. are contingent on agribusiness as usual -- well, you do what you know how to do.... its just business. The Government R US, however -- its up to us citizens to reclaim it!  

7. Therefore what we need is a National Campaign to Save Organic, or somesuch. An energetic combination of national, local and grass roots initiatives is necessary to defend Organic. A good case in point, albeit on a smaller scale, is the action over the Summer of 1997 conducted by NOFA-MA against Baystate Organics, a Boston sludge processor. The purpose of the action was to get them to change their name and stop labeling their fertilizer products as _organic_.  A well organized, concerted campaign with letter writing, media alerts, legislative lobbying and on-site public protests proved ultimately to be very successful. In the process, a lot of people were educated about organic and NOFA-MA gained a number of valuable new members and supporters.

8. Our diverse organic groups across the country should individually and collectively petition Senator Leahy to conduct an immediate Congressional investigation of this whole mess. There may also be some additional recourse through the Courts -- which should also be vigorously pursued. Currently, for example, NOFA has joined with over 30 other farming, environmental and advocacy groups under the auspices of Greenpeace's legal department to petition/sue EPA to stop the field release of transgenic Bt in order to prevent sure and immediate pest resistance to this important biopesticide which has been in wide scale use by conventional and organic farmers alike for 40 years now. Part of the legal case is based on the fact that EPA has violated its own rules in its own processes. In addition, we need professional expertise to go over the legality/illegality of USDA's NOP Rules action. Not only has our Industry lost valuable time -- and suffered major economic losses due to the extreme lateness of this Rule, but also we are now  back at square one. To quote Secretary Glickman at USDA's Rules Press Conference, _One, unified standard could clear the path and unleash even stronger growth in the organic industry. National standards would clear a similar hurdle on the international front. ...Greater income for small farmers and ranchers, stronger exports, one high consistent standard for consumers -- clearly we have a lot to gain from this rule._ In addition, the propose they d Rules place extreme fee barriers on the certifying agents which stand to drive many out of business and automatically disqualify a lot of small farmers who can't ante up in USDA's high price game. 

9. Finally, as an Organic vegetable farmer I've been dealing with some of the same restaurants in our area for some 22 years now, as well as a CSA since 1990 and if _Organic_ gets trashed and co-opted I'll get by fine on my own earned reputation and I know many other farmers are in this position. I'm not about to let _Organic_ go however. There's alot of good people out there who have a true interest in rejecting such a perpetuated fraud. Any co-opted USDA label would quickly become a laughing stock and a national _Real Organic_ label could quickly capture the marketplace... The truth is that we've all bargained in good faith and actually have alot to show for it -- the OFPA and the NOSB process still stand as a valid agreed-upon basis for Organic. USDA is still legally bound to comply with its mandates. If it takes them another 7 years or more to try and put something out again, so be it -- its time now that our national Certification groups rounded up the wagons anyway -- the public deserves and is demanding an overall label that certifies the certification programs and such an industry label could become as important and legitimate in the marketplace as any USDA one, even more so.  From the larger perspective, we've really struck the raw nerve at the heart of today's overblown and declining industrial food system -- just by the nature of our being. More and more they're having to resort to extreme, desperate and dangerous mega-technological fixes (like irradiating our food) just to stay in the same place. So -- here's this titanically huge agribiz/governmental entity that has just run into the smallish-appearing tip of a what is really an incredibly large iceberg...


Steve Gilman  
NOFA Interstate Council 
Ruckytucks Farm 
130 Ruckytucks Road Stillwater, NY  12170 
sgilman@netheaven.com