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Re: Organic Foods Production Act Implementation



In Article <v02120d03ae7486d66595@[136.152.94.221]>,
ehansen@garnet.berkeley.edu (Pam Kasey) wrote:
>Finally inspired by Susan Jarnagin's appeal on Sanet last Tuesday, I wrote
>that letter about OFPA that I've been intending to write. If any of you can

It was well written and I enjoyed reading your letter. I also have a few
comments below. I agree with everything you have said to this point.

>The growers, processors, and distributors who have devoted resources to
>implementing high nutritional and environmental standards for their foods

Does the OFPA include language defining nutritional standards? Is there any
intention of such language? Does any certifying agency currently implement
any measure of nutritional standards? I don't think so.

>and to communicating those standards to consumers through private organic
>certification have made a considerable investment in the meaning of the
>word "organic." Federal regulation of minimum organic standards as proposed
>in the OFPA honors their good faith.

...as well as compliance with the wishes of consumers and growers. It's
important to note that the government did not simply decide to create an
organic foods production act out of the blue. It was demanded for years by
proponents of organic production and their certifying agencies.

>However, I do not agree with any interpretation of the OFPA that prevents
>private certifiers from establishing additional, more stringent guidelines
>for their seals.

As with any federal law, there are bound to be many complaints. Just how
many additional levels of certification do you think are needed? Is there
some implication that certain organic foods are somehow 'above' others? I
don't think organic foods need to have multiple levels of certification.
It's organic, what more is there to say? A multi-tiered system would just
create a regulatory mess. Maybe we never should have pushed for this
legislation in the first place? Then we could set our own standards, like
back in the 'old days'. You can't have your cake and eat it too. 

>The proposed implementation violates certifiers' right to free speech.

That isn't correct actually. I think you will need to come up with something
more substantive if you wish to evoke the protection of the law. This
complaint won't even get you into court.

>Further, the enforcement of maximum organic standards would
>make it impossible for growers to realize a return on any investment in the
>more ambitious standards that I and many other consumers value.

Ah, perhaps you can define those standards. What exactly is "more ambitions"
than organic?

>The Final Rules for implementation of the OFPA must not restrict private
>certifiers' rights to establish independent standards for food quality.

Oh, but they MUST! Otherwise, what's the point of this legislation?
Proponents of organic farming have essentially forced the US government to
adopt these laws regulating organic foods. You asked for it, you got it.
Soon, the only standards will be the US Federal standards. If we're going to
set our own standards, then this legislation is a waste of time and money.

>Such a restriction will only plunder our hard-won equity in the term
>"organic" for the short-term benefit of minimally compliant growers and
>processors. Please don't let this happen.

So is your real problem with "minimally compliant growers", or that the
proposed standards are too low? I think I get the idea. You want to be able
to say "we're REALLY organic, not just minimally compliant". I don't think
you need any certification if you want to make that claim, but I don't think
it carries much weight either.

Tracy (growing and consuming organic since 1981)


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