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Organic Regulations- How to Comment




TO ORGANIC FOOD CUSTOMERS: 
from Margaret Clark, former Town and Country Organic Produce Manager 

The US Department of Agriculture has released proposed regulations for
Organic Foods. The USDA is now in a formal comment period, which is as
close as we get to democratic participation  in the administrative
rule-making process. It is very very important that everyone who sees
themselves affected by these regulations speak up now. The USDA is
accepting comments on the rule on a Website:
			http://www.ams.usda/nop

The site also contains a copy of the proposed rule and the NOSB
recommendations. You can view comments posted by others, by category. They
have received thousands of comments. Because of this they have extended
the comment period to May 1st.

Four public hearings on the rule will be held nationally, and one will be
in Seattle on  Thursday, February 26, at the Seattle Center Rainier Room,
from 9 AM to 4PM. You must pre-register to testify, and will be limited to
speak for 5 minutes. You may register on line with the Webmaster at the
site above, or by calling Karen Thomas at the USDA/NOP, 202-720-3252.

As you may know, these  rules have been a long time coming, as the statute
that enables them, The Organic Foods Production Act (OFPA), was passed in
1990. I was on the original National Organic Standards Board (NOSB), which
was appointed to make recommendations to USDA on the regulations. We spent
over 2 years taking and analyzing public comments in the formulation of
our recommendations, which were submitted to them in August of 1994. In
addition, a great deal of time was spent in research to enable us to make
informed recommendations on The National List, which outlines what
substances can and cannot be used in organic production. The
responsibility for the List was given to the NOSB under OFPA.

The proposed rule is a great disappointment to most of us who have worked
with organic certification for years. The standards it would allow include
practices and substances which have never been allowed in organic
production, and which contradict the recommendations of the NOSB. The
recommendations are so deficient in so many areas that rather than try to
fix it, so USDA can issue a Final Rule in the near future, both the
Organic Trade Association and the Committee for Sustainable Agriculture
have called on USDA to withdraw the rule. Some of the problems with the
proposed rule are that it would allow for: 

		Genetically modified organisms, municipal sewage sludge
			and food irradiation in organic food production
		Weakening of standards for pesticide residues
		Use of processing aids not approved by the NOSB
		Use of hormones and antibiotics in livestock


USDA proposes to collect $500,000. in fees from organic farmers and
handlers to run a program in Washington D.C. staffed with 14 people, to
accredit 45 certification agencies, with site visits every 5 years. The
largest certification organizations in the country, which inspect several
hundred farms and processors each year, do not have anything near this
sort of budget or staff. 

No provision has been made for meaningful participation of experts
experienced in organic production and certification to participate in the
site evaluations. This was called The Peer Review Panel in the OFPA. What
was envisioned as a public/private partnership at the time of OFPAa
passage is now looking like it has been taken captive by interests who
would like to ride free on the integrity of an organic label. No organic
producers I know are interested in using GMOs, irradiation or sewage
sludge, any more than consumers are interested in eating it. But if they
have to compete with companies who do use those things, and are not
allowed to tell you on their label how they are different, you will not be
able to know what you are buying.

The rule has a number of provisions which would restrict the types of
label claims that can be made, and the types of criticisms which could be
made of the USDA program. There are number of lawsuits and state laws now
which would make it a crime to say bad things about food. (Oprah and the
cattle industry.) The FDA seems to support this type of restriction in not
requiring labeling of GMOs  and hardly allowing labels to say they dont
use GMOs. (like bovine growth hormone.)

The Organic Trade Association has a Website with their latest comments on
the rule: http://www.ota.com  I will be posting my further comments to an
e-mail list. If you want to be included, please send me a message at
maclark@u.washington.edu.
	
Additionally, a public discussion of the regulation, sponsored by Seattle
Tilth and Puget Consumers Coops, will be held at the Good Shepherd Center,
Senior Center, on February 19th at 7:30 PM. I will be speaking, as will
Miles Mc Evoy from the Washington Dept, of Agricultures Organic Program.
	
Please use these opportunities to speak out. Organic food production is
hard work. Farmers and producers are doing us a public service. The
existing certification programs are doing a great job, with limited
resources. They need support and appreciation, not more fees and poor
standards.
		Thank you.