GREENFIELD, Massachusetts (January 27, 1998) -The Organic Trade Association (OTA) announced today that the association is fundamentally opposed to the proposed national organic regulations as currently set forth by the USDA. "We strongly believe that the Proposed Rule is not compatible or consistent with current organic practices," said Katherine DiMatteo, executive director for the OTA. "We fervently believe that the current draft of the regulations 'lowers the standard' for organic and is unacceptable as written."
As the organic industry has used either state and/or independent third-party certification with strict criteria for over 20 years, there is intense worry that the proposed federal regulations will actually be weaker than the current decentralized regulation practices. "The industry has developed and maintained high standards that consumers have grown to trust and expect from the certified organic label," said DiMatteo.
Two organic industry meetings were held last week in Washington, D.C. and San Jose, California as a means of gathering industry and public opinion in response to the USDA's current draft of the national organic regulations, which were released on December 16, 1997 for public review through May 1, 1998. After gathering information and input from over 200 organic industry members at the OTA-sponsored meetings, the OTA announced its grave concern that the USDA, by not following the recommendations of the 14-member National Organic Standards Board (NOSB), has placed the term "organic" at risk of losing its high integrity meaning.
"As we see it, the USDA's Proposed Rule blurs the lines between conventional and organic agriculture. The Organic Foods Production Act of 1990 was originally enacted because Congress recognized that organic production is different enough from conventional agriculture to justify its own clear definition," said DiMatteo.
The OTA, after its study of the lengthy and complex proposed regulations and after analyzing the significant input from the industry, cites nine key areas of concern that, if left unchanged in the final draft, would force the OTA and other organizations in the organic industry to "take a serious look at the validity of these federal regulations," said DiMatteo. "We must insist on national standards that stick to the true meaning of organic. The Proposed Rule does not accomplish that objective."
The Top Nine Threats to Organic Integrity As Set Forth in the Proposed Rule:
#1 Missing the "Big Picture" by eliminating key concepts
The definition of organic as written in the proposed, national organic standards lacks the holistic approach central to organic practices. The proposed rules take a reductionist approach to organic food production that eliminates key concepts such as the health of the agro-ecosystem and biodiversity on the farm.
#2 Ignoring the recommendations of the National Organic Standards Board
The USDA undermines the NOSB's authority in this draft of the proposed regulations. The USDA has ignored the clearly mandated authority the NOSB was given in the Organic Foods Production Act of 1990 to recommend the National List of Materials for organic practices.
#3 Possible inclusion of genetically-engineered organisms (GEOs) in organic systems
The use of GEOs is an unproven technology that the organic system does not need in order to grow high quality and nutritious food. There is not enough scientific data documenting the long-term impact GEOs will have on the environment or human health.
#4 Possible inclusion of food irradiation in post-harvest organic production
Food irradiation (ionizing radiation) is a synthetic process that has never been allowed in organic production. The long-term effects of irradiation are still unknown, and irradiation is not a panacea to food safety concerns.
#5 Possible inclusion of biosolids (sewage sludge) in organic farm practices
Sewage sludge from municipalities' waste may contain heavy metals and toxins and, therefore, is not appropriate for use on land where food is to be grown for human consumption. The use of sludge has never been allowed in organic food production and is completely unnecessary.
#6 Weak livestock section
The livestock section is weak as currently written, and gives too much leeway in the amount of non-organic livestock feed, types of living conditions and use of antibiotics and other animal drugs allowed in organic production. The organic industry expects the regulations to include the use of only 100% organic feed, and consumers expect absolutely no antibiotics in organic meat and dairy production.
#7 Unnecessary loopholes
Loopholes were created when the U.S. Department of Agriculture (USDA) eliminated the carefully worded restrictions on the use of materials common to the current organic standards, replacing them with new terms such as "active" and "non-active" synthetics and ingredients. There is no historic or legal reason to create new terms. These loopholes will allow synthetic materials and ingredients in organic production that have never been allowed before.
#8 Weakened de-certification authority
Under the proposed rules, the authority to decertify growers, processors and manufacturers has been placed solely in the hands of the Secretary of Agriculture. As a result, there would be no efficient de-certification process and therefore products not meeting organic requirements may remain on market shelves longer. Enforcement of certification standards, currently placed in the hands of private certifiers, may be weakened through what will inevitably be a lengthy bureaucratic process.
#9 Ignoring historical land usage practices
Although the Organic Foods Production Act has set the criteria that farms should be free from the use of prohibited substances for three years to be certified, in some cases there is soil contamination so excessive that the land may not be appropriate for organic production. The USDA Proposed Rule does not include previous history of the land as part of the requirements of the Farm Plan submitted to a certification agent. The USDA's proposed concept of "unavoidable contamination level" of each farm is not acceptable to the organic industry.
January 27, 1998
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