Revise “Organic Agricultural Industry” Term:
Comments of the Organic Trade Association on
Proposed Rule with Request for Comments
September 12, 2006
Regulatory and Policy Manager
The Organic Trade Association (OTA) is pleased to have the opportunity to comment on this proposed rule.
We appreciate the consideration given to organic farming methods, especially the recognition that organic farming practices may vary from nonorganic practices.
We also thank FCIC for including consideration of organic agricultural experts.
The term and definition are proposed to be:
Organic agricultural industry. Persons who are employed by the following organizations: Appropriate Technology Transfer for Rural Areas, Sustainable Agriculture Research and Education or the Cooperative Extension System, the agricultural departments of universities, or other persons approved by the FCIC, whose research or occupation is related to the specific organic crop or practice for which such expertise is sought.
However, we request that the term be changed to “Organic agricultural experts” to reflect the meaning of the definition as given. This would also be consistent with the new term “Agricultural experts” proposed in the same rule. We note that the industry is composed of a broad variety of businesses and believe that the industry as a whole should not be confused with those who are expert in organic agriculture. In addition, we would hope that Experiment Stations would be eligible to be the employers of “Organic agricultural experts” along with the other institutions listed.
Thank you very much for your consideration.