Caveat Emptor: Let the Buyer Beware of USDA "Organic" (fwd)

Lawrence F. London, Jr. london at sunsite.unc.edu
Tue Jan 20 10:18:43 EST 1998


---------- Forwarded message ----------
Date: Tue, 20 Jan 1998 03:50:51 -0600
From: Guy Clark <guyclark at socket.net>
Subject: Caveat Emptor: Let the Buyer Beware of USDA "Organic"

Caveat Emptor: Let the Buyer Beware of USDA Organic
	The USDA  published the proposed organic standards on December 16, 1997. 
Interested producers and consumers have been reacting with a mix of shock
and outrage.  We have until March 16, 1998 to inform USDA of our opinions.
	The main problems with the proposed standard are the following:
Free Speech Issue- The Act severely curtails producers right to accurately
state their production processes; by doing this it denies consumers the
right to be fully informed when making purchasing decisions.  This is a
violation of the First Amendment to the Constitution.
States' Rights Issue- According to this Standard, states cannot create
accreditation programs for certifiers; nor can they certify anyone as
organic unless the program is submitted to USDA and high fees paid. 
Further, a state may have stricter standards, but only for goods produced
within the state and after the Secretary approves.  There is no allowance
for holding other states or countries to a state's standard.  This is a
domestic version of NAFTA/GATT.  
The Cost Issue- USDA estimates of costs for initial certification are:
1.	Farmers and wild crafters- $878  2. Handlers- $1,910  3. Certifying
Agents- $30,131
Synthetics Issues-  The USDA's propose rule violates the general
prohibition on the use of synthetic substances in organic farming and
handling on at least six substances.
Genetically Manipulated Organisms (GMO) Issue-  The USDA's proposed rule
violates the National List procedure by opening for public consideration
the use of GMO's in organic farming in violation of National Organic
Standards Board recommendations.
Irradiation Issue- The USDA's proposed rule violates the National List
procedure by opening for public consideration the use of "ionizing
radiation" in organic farming and handling against NOSB recommendations.
Sewage Sludge/"Biosolids" Issue- The USDA's proposed rule violates the
National List procedure by opening for public consideration the use of
sewage sludge/"biosolids" in organic farming against NOSB recommendation.
Intensive/Perpetual Animal Confinement Issue- The standard violates the
organic practice of providing organically raised livestock adequate space
for movement and access to outdoors.  It also tries to sneak perpetual and
intensive confinement livestock operations in as organic by creating a new
category, "certified facility."
"Pressure-treated" Wood Issue- Contrary to most existing organic standards,
USDA has stated in Supplemental Information that it does not consider
"Pressure-treated wood" to be active in the agroecosystem; and therefore
allows its use even in contact with soil.
Equivalency Issues- As noted above, states with more restrictive rules
could not hold products from other states or countries to their standard. 
Further, this standard would not be accepted by many countries and American
products could not be shipped abroad.  This invalidates one of USDA's
arguments for the standard, that it would enhance access to foreign
markets.
Animal Cannibalism Issue-  The USDA's proposed rule does not prohibit the
refeeding of rendered, or otherwise processed, animal protein to livestock.
 This is the process which led to "Mad Cow Disease" in Great Britain.
Organic Feed Only Issue- Proposed rule violates the requirement of feeding
only organically produced feed to livestock raised for "organically
produced" meat, dairy, and egg production.
Organic Pesticide Ingredient Evaluation Issue- Violates OFPA requirement to
evaluate all ingredients in botanical pesticides, including undisclosed
"inert" but toxic substances. 
Extension of the Comment Period Issue- Is 90 days a long enough comment
period on a standard that took USDA 7 years to produce and runs to a couple
of hundred pages?  Why did USDA release this during the winter when
producers and consumers have little or no contact with one another?        
                                                        



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