Home News & Events Action Alert: Time running out for organic rule comments

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Action Alert, Issued: 3/5/98
Time running out for organic rule comments


Make your comments to USDA by April 30.

USDA has proposed national organic standards regulations ("Rule") as required by the Organic Foods Production Act of 1990. Thousands of comments are needed by April 30, 1998 to ensure that USDA creates an acceptable program. The Rule needs a complete overhaul, and you need to tell USDA how to do it.

Tell USDA to:
  1. Adhere to National Organic Standards Board (NOSB) National List recommendations! Congress granted the NOSB special power to determine a small universe of synthetics (like insect pheromones) to be allowed in organic production. The NOSB includes organic, environmental and consumer reps and has expertise, credibility, and legal authority to make these important and often controversial decisions.

    But the proposed rule ignores NOSB recommendations, usurps its authority, and changes definitions to give USDA broad latitude to loosen the standards on what materials are allowed in organic production. Tell USDA to write the rule according to NOSB recommendations and recognize the NOSB's authority. [205.20-205.28]

  2. Eliminate unwanted materials from organic production! Broad categories of materials prohibited by the NOSB were allowed by USDA. Tell USDA that genetically engineered organisms (GEOs) and their products are synthetic prohibited materials and that you don't want them. Tell USDA that sewage sludge and ionizing radiation (irradiation) are unacceptable and would, along with GEO's, place U.S. standards in conflict with existing industry practice, consumer expectations, and international trade and standards.[205.2, 205.7- 205.9, 205.22, 205.26, 205.17]

  3. Require higher standards for livestock! USDA waters down standards recommended by the NOSB (which said that animals must have access to the outdoors, prohibits refeeding of animal parts and manure, severely limits the use of antibiotics, and requires organic feed). USDA would allow 20% non-organic feed, confinement operations, and liberal drug use. Tell USDA to adhere to NOSB recommendations. [205.13-205.15, 205.22, 205.24]

  4. Don't price small farms and small-scale certifiers out of business! Although NOSB recommended that USDA not penalize small farmers, certifiers, and processors, USDA proposes a regressive flat fee for certification and registration. This means that small-scale certifiers, farmers, and processors will pay a disproportionate share. Tell USDA to use a sliding fee system and reduce the impact on small operators. [205.421-205.424]

  5. Stay out of the eco-label business! Surprisingly, USDA proposes to prohibit an untold number of "green" labels in the name of protecting consumers. Such labels could include pesticide-free, no antibiotics or hormones, ecologically produced, humanely raised, IPM grown, etc. Tell USDA to stick with organic, as the law requires and leave other "green" labeling alone. [205.103]

How to Make Comments:

Identify all comments with Docket No. TMD-94-00-2

Write detailed comments on this Rule to USDA before April 30. The perspectives of consumers, farmers, and business are needed. Make comments as substantive as possible, and organize the comments into categories corresponding to the proposed Rule, including section nos. (bracketed nos. above).

Note who you are (farmer, consumer, etc.), and why you are making comments. Tell the Agency that this Rule lowers all standards for organic food in the U.S. and that it should be withdrawn and rewritten according to the NOSB recommendations, current international standards, and the Law, and resubmitted for public comment before going to a Final Rule.

Finally, send your Senators and Representative a copy of your comments with a letter requesting that they convey these concerns about this Rule to Ag Secretary Glickman.

Get a copy of the proposed Rule at http://www.ams.usda.gov/nop, or at your public library -- ask for Federal Register Vol. 62, No. 241, Part II, Tuesday, December 16, 1997.

Submit comments to: Docket No. TMD-94-00-2, Eileen Stommes, Deputy Administrator, USDA-AMS-TM-NOP, Room 4007-So., Ag Stop 0275, P.O. Box 96456, Washington, DC 20090-6456, or if possible, electronically at http://www.ams.usda.gov/nop.

See the links below for more information and analysis.

Source: News release from the National Campaign for Sustainable Agriculture, P.O. Box 396, Pine Bush, NY 12566, (914) 744-8448, Fax: (914) 744-8477, email: campaign@magiccarpet.com

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