Arial> Dear colleague:
> Please see the fact sheet below concerning the USDA proposed
> organic rule. It contains the useful information concerning the
> organic standard which is now in the public comment phase. The
> comment period ends June 12, and the scientific community needs to
> in this proposed standard. Comments should be sent to:
> Keith Jones, National Organic Program
> USDA-AMS-TMP-NOP 2945 So. Bldg.
> Ag Stop 0275
> P.O. Box 96456
> Washington, D.C. 200090-6456
> or via website:
> or via fax:
> (703) 365-0760
> The USDA expects to publish the final organic crop production rule
> by the end of 2000, and to implement the rule approximately 18
> after final rule publication. It is important for agricultural
> and professionals to comment on the proposed organic rule. That is
> am sending you this note.
> Consumers and producers need a clear, enforceable rule that
> establishes a set of production and processing criteria to market
> labeled as organic. This type of rule would create genuine choice
> those who prefer organic food. The efforts of the United States
> of Agriculture (USDA) to provide farmers with standards for organic
> agricultural production and consumers with choice about the foods
> purchase should be supported. Currently, a large number of
> anti-biotechnology gorups have been commenting on the proposed
> crop production standard, seeking a threshold of 100% biotech-free
> crops. A requirement of zero tolerance of biotech crops in organic
> and products will be very difficult to do, and could affect the
> agricultural practices of conventional farmers.
> The organic standards should focus on the intentional processes
> followed by the organic producer, rather than on the presence of
> amounts of genetic material as a result of natural causes over which
> organic farmer may not have control. The rule must recognize that
> movement of genetic material among plants by means of pollen flow is
> natural occurrence. Pollen may move between flowering plants of the
> or related species. Knowledgeable farmers are fully aware of that
> take specific steps to preserve the identity of their crop when
> to grow a crop for specific markets, such as white, high oil or
> corn. It makes sense that the these identity preservation
> should also be utilized by organic growers. Just as it is difficult
> not impossible to guarantee that organic products are 100% free of
> pesticides, it will be impractical to guarantee that the products
> biotechnology are not present at any level in organic products. The
> organic rule should not make the "organic" claim impossible to meet
> those conscientiously operating under an approved organic program.
> rule should state that it imposes a specific production process for
> organic food, not a product guarantee.
> By the same token, consumers should not be led to believe that a
> 100% surety in any area can be guaranteed through organic
> certification of growing methods, laboratory testing, certification
> seed production or by any other means. The organic standards should
> for the presence of trace amounts of genetic material that were not
> intentionally bred into organic crops, similar to the allowances
> genetic variations within plants or seeds of a particular crop
> It is important to remember that all of the biotechnology-derived
> materials and crops used in conventional agriculture in the U.S.
> fully reviewed for safety by three agencies of the U.S. government.
> Some have tried to characterize the proposed standards as setting
> zero-tolerance for the presence of genetic material introduced
> modern biotechnology in organic crops. The threat of liability
> raised by some groups could create conflict among growers and an
> crisis for the many growers who grow both conventional and organic
> It seems essential that the organic rule allow all segments of the
> agricultural community to coexist peacefully and grow crops
> and efficiently. The proposed rule should be clarified to prevent
> potential consequence of the organic standards pitting farmer
> Please consider passing this reminder to comment to the USDA on
> organic rule to those who you feel will find it of value.
FACT SHEET: NATIONAL ORGANIC PROGRAM (NOP)
REVISED PROPOSED RULE
WHY: National Standards and Regulations
Š The Organic Foods Production Act (OFPA) of 1990 requires the
U.S. Department of Agriculture (USDA) to develop national standards
and regulations for organically produced agricultural products.
ÿ Any farm, handling, or processing operation that wants to
sell an agricultural product as organically produced will be affected
by the proposed national organic standards.
Š OFPA requires that agricultural products labeled organic originate
from farms or handling operations certified by a state or private
agency that has been accredited by USDA.
Š The Agricultural Marketing Service will administer the National
WHAT: The National Organic Program
Š Production and handling requirements, which address organic
crop production, wild crop harvesting, organic livestock management,
and processing and handling of organic agricultural products. The
National List of Allowed Synthetic and Prohibited Non-Synthetic
Substances is also included.
Š Labeling requirements for organic products, along with compliance,
testing, fee, and State program approval requirements.
Š Certification requirements, the certification procedure, and
Š Accreditation requirements for receiving and maintaining
accreditation, as well as requirements for foreign accreditation.
Š Other administrative functions of the NOP, which include evaluation
of foreign organic certification programs, the State program approval
process, and user fees.
Š Steps to implement the NOP.
HOW: Proposed Organic Crop Production Standards
Š Land would have no prohibited substances, such as most
synthetic pesticides and fertilizers, applied to it for at least
three years before the harvest of an organic crop.
Š Crop rotation would be implemented.
Š The use of genetic engineering (defined in the rule as
"excluded methods") is prohibited.
Š Soil fertility and crop nutrients would be managed through
tillage and cultivation practices, supplemented with animal and crop
waste materials and allowed synthetic materials. Use of sewage
sludge is prohibited.
Š Preference would be given to the use of organic seeds and
other planting stock, but a farmer could use non-organic seeds and
planting stock under certain specified conditions.
Š Crop pests, weeds and diseases would be controlled primarily
through management practices including physical, mechanical and
biological controls. When these practices are not sufficient, a
biological, botanical or allowed synthetic substance may be used.
Irradiation may not be used.
HOW: Proposed Labeling Standards
Š Products may be labeled as "organic" and bear the USDA certified
organic seal on the display panel if their organic ingredient content
is greater than 95%.
Š Products may be labeled as "made with organic ingredients" if the
organic ingredients comprise 50-95% of the product. The USDA seal
may not be used.
Š For products made with less than 50% organic ingredients may
identify specific ingredients on the ingredient label only. The USDA
seal may not be used.
FACT SHEET: NATIONAL ORGANIC PROGRAM (NOP)
REVISED PROPOSED RULE
ANALYSIS: Support and Concerns About Aspects of the Proposed Rule
Š Consumers and producers need a clear, enforceable rule that
establishes a set of production and processing criteria to market
foods labeled as organic.
Š The proposed rule should be more clear that this is a process-based
and not a product-standard rule. The Preamble stresses the
process-based approach, however, in the body of the rule, there is
room for misinterpretation.
Š The rule must recognize that the movement of genetic material among
plants by means of pollen flow is a natural occurrence. Pollen may
move between flowering plants of the same or related species. The
organic standards should focus on the intentional processes followed
by the organic producer, rather than on the presence of genetic
material as a result of natural causes over which the organic farmer
may have no control.
Š The organic standards should allow for the presence of trace
amounts of genetic material that were not intentionally bred into
organic crops, similar to the allowances made for genetic variations
within plants or seeds of a particular crop variety.
Š The labeling proposed in the rule does not make it clear that
a USDA seal indicates only that a production method was followed and
is not a guarantee of food safety or quality. Hence, by not
providing for an explanation of USDA certification, especially as
this relates to labeling the products, the proposed rule allows for
an interpretation that organic food production provides safer, more
healthful or higher quality food products than does conventional
agriculture, which is not the case.
Š The proposed rule prohibits the use of biotechnology-derived
agricultural products in the non-organic ingredients while allowing
typically prohibited conventional techniques, such as the use of
pesticides and synthetic fertilizers. By allowing for the use of
pesticides on the non-organic portion of the product, but disallowing
the use of biotechnology on the non-organic portion, the proposed
rule intrudes on conventional food production.
WHEN: Procedures for Commenting on Proposed Rule
Š The public must submit comments on this revised proposed rule in
either written and electronic form by June 12th, which is 90 days
from the time it was published in the Federal Register. Comments may
be made from USDA's website (www.ams.usda.gov/nop) or sent to:
Keith Jones, Program Manager,
National Organic Standards Program
USDA-AMS-TMP-NOP 2945-SO Ag Stop 0275
PO Box 96456
Washington, DC 20090-6456
Š All comments will be available for viewing on NOP website.
After reviewing and categorizing the comments, USDA will revise the
proposed rule, and submit a final rule for publication in the Federal
Š USDA has announced its intention to have a new organic rule in
place by the end of 2000, with implementation approximately 18 months
after publication of the final rule.
Additional Sources of information:
USDA National Organic Program: www.ams.usda.gov/nop
USDA Economic Research Service Study: