Sustainable
Farming Connection |
Where
farmers find and share information. | 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:
- 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]
- 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]
- 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]
- 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]
- 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
For more information:
- Organic Standard in Our Time
-- Entertaining summary of the issues from the Midwest Sustainable Agriculture
Working Group's report from Washington, Inside The Beltway.
- Discussion on USDA's rule
implementing the National Organic Farming Act of 1990 -- Commentary by
Fred Kirschenmann, Hal Hamilton, Mark Lipson and other organic leaders at Chuck
Benbrook's Pest Management at the
Crossroads website.
- Organic Agriculture
Endangered -- Commentary by Fred Kirschenmann.
- USDA-AMS National Organic
Program Proposed Rule -- Read the proposed rule and make comments
online. You can also read
comments made by others.
- Organic Farmers Marketing
Association -- Trade group features side-by-side comparison of OFPA and
proposed rule, analysis, how to respond, sample letters, commentary, USDA
hearing schedule and more.
- Discussion groups -- Subscribers to the sanet-mg and
organic-certification eamil discussion groups have been actively debating the
forthcoming federal standards. Join in:
- Organic Farming, Marketing, and
Certification Resources -- Links for more online organic information.
- Proposed Organic Rule Announced
-- 12/15/97 story and links.
- Comment Period Extended for Proposed
Organic Rule -- 2/11/98 story and links.
.
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