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Date:

May 14, 2000

Subject:

USDA Organic Standards; Call for Comments

 



Arial> Dear colleague:

>

> Please see the fact sheet below concerning the USDA proposed

> organic rule. It contains the useful information concerning the
proposed

> organic standard which is now in the public comment phase. The
public

> comment period ends June 12, and the scientific community needs to
weigh

> 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:

> http://www.ams.usda.gov/nop

>

> 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
months

> after final rule publication. It is important for agricultural
scientists

> and professionals to comment on the proposed organic rule. That is
why I

> am sending you this note.

>

> Consumers and producers need a clear, enforceable rule that

> establishes a set of production and processing criteria to market
foods

> labeled as organic. This type of rule would create genuine choice
for

> those who prefer organic food. The efforts of the United States
Department

> of Agriculture (USDA) to provide farmers with standards for organic

> agricultural production and consumers with choice about the foods
they

> purchase should be supported. Currently, a large number of

> anti-biotechnology gorups have been commenting on the proposed
organic

> crop production standard, seeking a threshold of 100% biotech-free
organic

> crops. A requirement of zero tolerance of biotech crops in organic
crops

> 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
trace

> amounts of genetic material as a result of natural causes over which
the

> organic farmer may not have control. 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. Knowledgeable farmers are fully aware of that
and

> take specific steps to preserve the identity of their crop when
choosing

> to grow a crop for specific markets, such as white, high oil or
sweet

> corn. It makes sense that the these identity preservation
techniques

> should also be utilized by organic growers. Just as it is difficult
if

> not impossible to guarantee that organic products are 100% free of

> pesticides, it will be impractical to guarantee that the products
of

> biotechnology are not present at any level in organic products. The

> organic rule should not make the "organic" claim impossible to meet
by

> those conscientiously operating under an approved organic program.
The

> 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
production, the

> certification of growing methods, laboratory testing, certification
of

> seed production or by any other means. 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.

> It is important to remember that all of the biotechnology-derived

> materials and crops used in conventional agriculture in the U.S.
have been

> fully reviewed for safety by three agencies of the U.S. government.

>

> Some have tried to characterize the proposed standards as setting
a

> zero-tolerance for the presence of genetic material introduced
through

> modern biotechnology in organic crops. The threat of liability
being

> raised by some groups could create conflict among growers and an
identity

> crisis for the many growers who grow both conventional and organic
crops.

> It seems essential that the organic rule allow all segments of the

> agricultural community to coexist peacefully and grow crops
effectively

> and efficiently. The proposed rule should be clarified to prevent
the

> potential consequence of the organic standards pitting farmer
against

> farmer.

>

> Please consider passing this reminder to comment to the USDA on
the

> 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

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.

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.

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.

The Agricultural Marketing Service will administer the National

Organic Program.


WHAT: The National Organic Program

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.

Labeling requirements for organic products, along with compliance,

testing, fee, and State program approval requirements.

Certification requirements, the certification procedure, and

recordkeeping requirements.

Accreditation requirements for receiving and maintaining

accreditation, as well as requirements for foreign accreditation.

Other administrative functions of the NOP, which include evaluation

of foreign organic certification programs, the State program approval

process, and user fees.

Steps to implement the NOP.


HOW: Proposed Organic Crop Production Standards

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.

Crop rotation would be implemented.

The use of genetic engineering (defined in the rule as

"excluded methods") is prohibited.

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.

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.

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

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%.

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.

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

Consumers and producers need a clear, enforceable rule that

establishes a set of production and processing criteria to market

foods labeled as organic.

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.

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.

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.

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.

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

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

Fax: 703-365-0760

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

Register.

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:

http://www.econ.ag.gov/whatsnew/issues/organic/


Arial