permaculture

["sal" <sals@rain.org>]

Fees and other charges will be assessed and collected from applicants for
initial accreditation and accredited certifying agents submitting annual
reports or seeking renewal of accreditation  organic farmer pays

When service is requested at a place away from the evaluator's headquarters,
the fee for such service shall include a per diem charge if the employee(s)
performing the service is paid per diem in accordance with existing travel
regulations. Per diem charges to applicants and certifying agents will cover
the same period of time for which the evaluator(s) receives per diem
reimbursement
organic farmer pays

The certifying agent may require applicants for certification to pay at the
time of application a nonrefundable fee of no more than $250.00 which must
be applied to the applicant's fees-for-service account.
organic farmer pays

When costs, other than fees-for-service, travel charges, and per diem
charges are associated with providing the services, the applicant or
certifying agent will be charged for these costs. Such costs include, but
are not limited to, equipment rental, photocopying, delivery, facsimile,
telephone, or translation charges incurred in association with accreditation
services. The amount of the costs charged will be determined
administratively by the Department. Such costs will become effective for all
applicants for initial accreditation and accredited certifying agents on the
effective date of subpart F.

the organic farmer pays

) Application and Administrative Fees. We have removed the provisions which
required certifying agents to pay application and administrative fees. These
fee provisions have been replaced with provisions for the assessment of fees
for service equal as nearly as may be to the cost of the accreditation
services rendered under these regulations. In other words, we will be
assessing fees and charges only for activities related to accreditation.
These fees and charges will be assessed and collected from applicants for
initial accreditation and accredited certifying agents submitting annual
reports or seeking renewal of accreditation.
organic farmer pays
We have retained the requirement, with modification, that certifying agents
reimburse the Department for travel, per diem, and related other costs
associated with providing accreditation services
organic farmer pays

State and private entities as accredited organic certifying agents are
similar to those used to certify other types of product or system
certification programs under the QSCP, we have decided to use this existing
program and its staff in examining certifying agents' operations and
evaluating their compliance with the Act and these regulations. Using the
QSCP and its staff will enable the NOP to provide the necessary services
without creating a separate bureaucracy. Hourly fees to be charged for
services under this program will be the same as those under the QSCP,
currently estimated at $95.00 per hour.

organic farmer pay

Certifying agents will be charged for accreditation service at the published
hourly rate on the first day of the nineteenth month following the effective
date of subpart F.

Over 15,000 comments were received on fees, with
organic farmer pays

The Act provides that each State may implement a certification program for
producers and handlers of agricultural products that have been produced and
handled within the State, using organic methods that meet the requirements
of this regulation

Such a State may request that its more restrictive buffer zone requirements
be established as the minimum buffer zone requirements of this regulation.


the organic farmer pay

Under the residue testing requirements of the NOP, we propose that all
agricultural products sold, labeled, or represented as organically produced
be available for inspection by the Administrator, State program's governing
State official, or certifying agent. Organic farms and handling operations
must be made available for inspection under proposed Subpart E,
Certification. In addition, products from the aforementioned organic
operations may be required by the State program's governing State official
or certifying agent to undergo preharvest or postharvest testing when there
is reason to believe that agricultural products to be sold or labeled as
organically produced have come into contact with prohibited substances. The
cost of such testing will be borne by the applicable certifying party and is
considered a cost of doing business. Accordingly, certifying agents should
make provisions for the cost of preharvest or postharvest residue testing
when structuring certification fees.



the organic farmer pays

) any harvested crop or plant part to be harvested that has contact with a
prohibited substance applied as the result of a Federal or State emergency
pest eradication or disease treatment program cannot be sold, labeled, or
represented as "100 percent organic," "organic," or "made with organic
(specified ingredients)"; and (2) any livestock that are treated with a
prohibited substance applied as the result of a Federal or State emergency
pest or disease treatment program or product derived from such treated
livestock cannot be sold, labeled, or represented as "100 percent organic,"
"organic," or "made with organic (specified ingredients)."

State programs' governing State officials and certifying agents may test
agricultural inputs used for organic production and require preharvest or
postharvest testing of any agricultural product to be sold, labeled, or
represented as "100 percent organic," "organic," or "made with organic
(specified ingredients)" when there is reason to believe that the
agricultural product has come into contact with prohibited substances. This
change allows State programs' governing State officials and certifying
agents to perform preharvest and postharvest residue testing on a
case-by-case basis
Drift is defined as the physical movement of prohibited substances from the
intended target site onto an organic production operation or any portion
thereof. The National Organic Standards Board (NOSB or Board) recommended
that agricultural products exposed to drift not be sold, labeled, or
represented as "100 percent organic," "organic," or "made with organic
(specified ingredients)" or fed to livestock on organic operations.

the organic farmer pays and pays and pays

no due process/ the organic farmer is always guilty and has to prove he is
not guilty every year for the rest of his life. the organic farmer pays and
pays and proves and proves and still here they come again.
I can go on and on and don't think things like Regulatory impact assesment
or Unfunded mandates act or Paper work reduction act or civil justice reform
or federalism will help because they don't mean what they claim its only
smoke and mirrors.  the usda say they want to help the small grower but the
shepherd feeds the flock and not just fleeces it.  they  are taking they are
not giving us anything and they just took our word.  Organic

then u got your certifier and the local chapter and the inspector and the
state and their cars and their  computer and their kids need their teeth fix
and on and on  . you get the idea .  a big hole a bottomless pit needs
feeding and the organic farmer will pay and pay and pay and for what to be
known as no safer or no better for the earth than conventional farmer.
not a good deal= u think




check out an organic farmers homepage
http://www.rain.org/~sals/.my.html
sals@rain.,org
----- Original Message -----
From: "John Schinnerer" <John-Schinnerer@data-dimensions.com>
To: "permaculture" <permaculture@franklin.oit.unc.edu>
Sent: Tuesday, April 25, 2000 3:49 PM
Subject: "Organic" rip-off


> Aloha,
>
> My hat is off to all those who worked to keep GMOs, irradiation, sludge
and
> so on out of the "organic" standards proposal.  This is a good thing.  An
> irradiation plant is almost certain to be built on the Big Island, but
even
> if "organic" food goes in what comes out can't be labeled "organic."


the USDA did not stop GMO and Irradiatiion and sludge we did my certifier
and most all others did .  the USDA only tried to make that stuff organic. u
got it wrong. they are not savors of organic the people said no way and they
for once bowed to the people and took that off for now but don't forget the
USDA has taken over organic and that may be all back on tomorrow .  they got
our word we don't have it anymore.  so lots of folks did fight and I rejoice
but that was the big smoke screen for the takeover.  those were never
organic so don't take we will give u a inch and take a mile as a friendly
jester.  folks already have to be certified to sell abroad and folks alread
have to be certified to sell to the big players we don't need this add pain
and complete takeover.   bussiness was and is taking care of bussiness those
that need certification can get it those that don't are not forced into it .
This is a game and it is the organic grower that is being gamed.  already I
am paying way to many folks don't need even more fees and even more paper
work and even more time kissing up.  read the fee part and know one thing
every time is says pay its the farmer that is paying even when they say
certifier pays it is the farmer that pays every time and they don't say the
amount because all these folks get to charge what they can.  the inspectors
want another raise ok the farmer pays we don't care they want a nother
residue test ok the farmer will pay they want a new computer ok the farmer
will pay a we need to take a trip and have a meeting ok the farmer can pay
we need to hire more help ok the farmer will pay we need the state to
regester every one ok the farmer will pay we need the fed gov. in on this ok
no big deal the farmer will pay.  were im I suppose to get all this extra
money they will not let u print it.  we need barriers from folks that spray
ok the farmer will give up his land and if we release GMO or spray the
organic farmer will pay don't wory.  the inspector has to come from tin buck
too and needs a motel and massage don't worry the farmer will pay.  and must
 pay force to pay under law if he want to tell his customers he is organic
he will pay of get out.  read the fees and tell me what will it cost .  it
is all up in the air all I know is the farmer will pay does pay and will pay
more and more and for what .   a stamp that will not mean anything in a few
year now that the USDA owns the name.  don't give them kodos for not
allowing the big three we knew the big three were not organic all along.
Just so No to making the farmer pay to grow organic. enough is enough .
> And...
>
> A pattern I see is that the USDA/agribusiness complex (the USDA is
> systemically wedded to agribusiness, not small growers) is doing what it
> does as a system to make sure that "organic" as a certification will
profit
> "organic" agribusiness (an oxymoron if ever I heard one).  The big ones
can
> afford the overhead of paying multiple layers of fees and/or payoffs to
> government certification agencies and/or agents.  Small growers can't, and
> will be squeezed out.  This is the dominant business model in all other
> arenas of commodity commerce, so if one wishes to play that game there are
> plenty of examples of what course that game will take.  The details of the
> "organic standards" rules and regulations do not significantly affect the
> nature of the larger game.  MegaOrganics, Inc. (a wholly owned subsidiary
of
> Monsanto) here we come... ;-)
>
> Sal offers solutions in his comment about how the food speaks for itself -
> *if*a grower steps out of the agribusiness food-as-commodity box and does
a
> CSA or local direct farmer's market or alternative currency or barter or
> other clever schemes yet to be designed.  The common pattern in such
designs
> is that there is a close relation between food-producer and client - they
> know each other personally as human beings and that *is* the
> "certification."  Of course there can be betrayals of trust in these
> relations, but at least each party is taking direct responsibility for
these
> relations rather than wanting to place that responsibility somewhere else.
>
> One of the most basic pathologies here is the desire to "own" some
> "standard" called "organic" and use it in place of actual human relatings
> and personal responsibility for one's choices and actions.
>
> John Schinnerer
>
> ---
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