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  • From: "Tradingpost" <tradingpost@gilanet.com>
  • To: livingontheland@lists.ibiblio.org
  • Subject: [Livingontheland] IFFS Conglomerate organics
  • Date: Sat, 24 Apr 2004 07:43:43 -0600


IFFS Conglomerate organics
Talking Points Major Issues
NOSB Meeting - Chicago, Illinois

National Organic Program (NOP) staff has illegally approved ingredients or
materials not included on the "national list." The law clearly states that
all materials must be approved by the National Organics Standards Board
(NOSB). This end-run around the NOSB has been done on a number of
occasions, most recently to approve preservatives in processed meat from
Applegate Farms. They have also approved feed with components not on the
list that have never been reviewed by the NOSB.

The industry and NOP have always operated under the precedent that
conventional dairy farmers could convert their herds to organic production
(whole herd conversion) one time, and one time only, after a phase-in period
on organic feed and under organic management. The NOP, without the approval
of the NOSB, decided to allow large organic factory dairy farms (Horizon and
others) to purchase conventional heifers and then phase them into their
organic production. This clearly puts sustainable family-scale farmers, who
make extra efforts to care for their animals (resulting in long, productive
lives), at a competitive disadvantage.

The NOP staff has disregarded the law requiring independent peer reviews and
awarded no-bid contracts for technical assistance to university groups with
little or no organic experience - including one that is
politically-connected and perceived as having anti-organic ties. The NOP
has denied access to documents preventing NOSB members from providing
oversight.

The NOP has accredited foreign certification agencies without ever visiting
the agencies or the countries. This was done purely by an exchange of
paperwork! As a consumer, do you trust organic products coming from China
and other Third World countries?

In at least one case, NOP bureaucrats overruled an accredited organic
certifier who denied organic certification to a factory farm raising
chickens because the birds lacked access to outdoors/pasture. This reversal
was done within one business day, without a hearing, and without
notification to the certifying agency. How many other actions like this
have taken place without anyone's knowledge? We should be demanding full
transparency and a formal appeals process.

The National Organic Program has institutionally been disrespectful of the
process and people who established this bureaucracy at the USDA (the organic
community) and to the individual volunteers who have been appointed to the
National Organic Standards Board. The NOSB needs to control their meeting
agendas - not the USDA staff! We need to demand that the law is followed
and the process respected.

We are asking that the current manager be reassigned to a different position
elsewhere within the USDA. He has established and condoned a tone that
allows NOP staff to be personally abusive, in public, to members of the
NOSB.

Furthermore, the Secretary of Agriculture will soon appoint five (5) new
individuals to the NOSB-we do not want this board stacked with
anti-organic/pro-corporate minions.
And finally, we ask that a staff position be created - an executive director
for the National Organic Standards Board - so that the 15 volunteer-members
on this body are provided with sufficient assistance to help leverage their
valuable and legally mandated contributions to the National Organics
Program.

How to Submit Comments

The upcoming NOSB meeting will be held at the Best Western Inn of Chicago,
162 East Ohio Street, in the Buckingham Meeting Room, April 28-30, 2004. A
public input session begins on Friday, April 30, at 8:00 am. There is also
a public comment input session at the start of the meetings on Wednesday at
8:30. You can submit comments at either session but we are targeting the
largest turnout for maximum impact and possible media coverage, on Friday.

Each speaker is given 5 minutes. You may have one proxy from another
farmer/consumer who can grant their time to you, for a total maximum of 10
minutes. We will help you get a proxy if you need more than five minutes
for you comments (please contact Cornucopia) or if you want to be a voice
for many farmers elsewhere in the country who will be unable to attend.
People need to sign a speaker list when they arrive. All persons making an
oral presentation are requested to provide their comments in writing.
Written submissions may contain information other than that presented at the
oral presentation. Persons submitting written comments at the meeting are
asked to provide 30 copies. (We believe this is overly burdensome to the
public and suggest that, if possible, you make copies for the 15 NOSB
members, plus one for USDA staff, and a few others for possible media use.
If you are unable to make copies, please don't let that silence you - we
have a right to express our opinions in this society.)

The Message
No matter which issues you choose, please mention some variation of this
central theme:

We are respectfully requesting Agriculture Secretary Veneman for regime
change at the National Organic Program! Program management has lost the
confidence of organic farmers and consumers.

This is our unifying message - things at the USDA's National Organic Program
need to change! Leadership needs to be experienced in organic agriculture
and universally respected.

Please remember that this message is for the AG Secretary and other
political appointees. Even though we are taking advantage of the National
Organic Standards Board meeting to air our concerns, NOSB members are not
our enemies! In most cases they are strong organic advocates and very
dedicated volunteers representing farmers, consumers, environmentalists and
processors. But their meeting provides an outstanding opportunity for
airing our concerns.

Directions to Meeting
Please note that the NOSB meeting is taking place at the Best Western Hotel,
an Ohio Street, just east of Michigan Avenue (at the corner of Ohio and St.
Clair). If any of you are old enough to recall, it is the former St. Clair
Hotel. Parking is not cheap but there is a ramp across the street that
offers a discount if you take your ticket and have it validated at the bell
stand in the hotel. If you have access to public transportation we are sure
that it will be the best bet. If you need it for any reason the hotel's
phone number is: 312-787-3100.


Other Issues of Concern at the NOSB/NOP

. Strengthening measures to keep slaughter byproducts and animals that have
consumed slaughter byproducts out of organic production

. GMO contamination of organic crops, including seeds used by organic
farmers

. The use of hydrosols (condensed stream) as "organic" food
ingredients

. The need for standards for organic personal care products, fiber,
fish and seafood and pet food

. The need for an ongoing peer review panel, as mandated by OFPA and
the Final Rule, to oversee the USDA's accreditation program

. The need to conduct on-site evaluations of foreign certification
agencies approved by USDA
. Recent actions by the USDA's NOP to allow companies to use
substances not on the National List (sodium lactate and potassium lactate as
processed meat preservatives and phosphoric acid to fortify aquatic plant
extract fertilizers). These actions were taken with no consultation of the
NOSB, who has authority under OFPA over the National List

. Actions by the NOP to undermine the NOSB's statutory authority over
review of petitioned substances and the National List

. NOP's "two track" dairy herd interpretation, which requires family
farms that convert their entire herd to organic production to raise all
replacement heifers as organic from the last third of gestation, while
allowing factory style operations to continually introduce conventional
heifers, so long as they are managed organically for one year prior to milk
production . this is wrong

. Lack of outdoor access for poultry, as evidenced by actions of the
NOP to mandate certification of The Country Hen

. The lack of NOP implementation of over 50 NOSB policy
recommendations

. The need for an NOSB executive director (staff to asset the 15
volunteers on the board

. The need for Technical Advisory Panel (TAP) contract announcements
to be publicly posted and for bids to be solicited in an equitable and
transparent manner

. The need for NOP enforcement actions, including suspensions and
revocations of certification, to be publicly posted - currently there is no
public record of NOP enforcement actions

. Bring your own issue(s) of concern to the attention of the NOSB and
NO

If you have any questions or need help in any way please contact Cornucopia
at the email address or phone number below. A sample letter is available
upon request.


The Cornucopia Institute

P.O. Box 126

Cornucopia, Wisconsin 54827

organic@cornucopia.org

608-625-2042





  • [Livingontheland] IFFS Conglomerate organics, Tradingpost, 04/24/2004

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