COMMENT ON PROPOSED AMENDMENT TRD-200003667 to 4 TAC Section 65.1
Submitted by Tom Hutcheson
July 27, 2000
The Organic Trade Association (OTA) supports this proposed amendment.
The organic industry has been self-regulating for decades. With increased growth, the industry requested federal legislation defining organic agriculture in 1990, and with the publication of the Final Rule for the
USDA’s National Organic Program, the industry will be under federal regulation.
Because there is now a federal standard for organic agriculture, OTA supports the harmonization of those federal standards with related industries. With this proposed amendment, the State of Texas has taken the lead in reducing related confusion in the marketplace, which remains possible so long as fertilizer is not considered an agricultural product or commodity and is therefore not included in the federal rule.
The State of Texas has also recognized and addressed the possibility of confusion between the chemical and the agricultural definitions of “organic.” While it is not uncommon for the same term to be use differently in different fields, chemistry and agriculture are so closely related that the clarification and differentiation articulated in this proposed amendment is especially welcome.