Keith Jones June 12, 2000
Room 2945-S, Ag. Stop 0275
P.O. Box 96456
Washington, DC 20090-6456
Docket Number TMD-00-02-PR2
Dear Mr. Jones:
On behalf of the 1095 members of the Organic Trade Association (OTA), I am submitting the following comments to the USDA National Organic Program Proposed Organic Rule. The implementation of these regulations will have a dramatic effect on every OTA member.
OTA, representing its members, has worked side by side with the government for the past ten years to develop a national program for the production and labeling of organic products. OTA has been supportive of this public-private partnership because of the promise that, through a national organic program, consistency in production standards for farmers and handlers and consistency in labeling for consumers would bring equity to the marketplace. In addition, there has been the expectation that national organic standards would end the debate about the definition of organic and the validity of this agricultural production system. As an industry we have struggled to contain the assumptions and claims that have been placed on organic agriculture and organic products. Now, with this Proposed Rule (Docket Number TMD-00-02-PR2) for the USDA National Organic Program, OTA is optimistic that the promise is about to be fulfilled. Thank you for your determination and for your responsiveness to the organic industry.
In an April 30, 1998 letter, OTA asked USDA to write a national standard that reflected current organic industry practices and consumer expectations. You have delivered standards that are very close to answering our request. OTA has prepared an extensive comment, written not to criticize but to improve and clarify the regulations offered by USDA. As you know OTA has recently completed the American Organic Standards and we understand the many details and opinions involved in writing comprehensive production and processing standards. We also understand that it is difficult to address every possible situation or consequence. In these comments we have offered a number of new definitions and standards that, we hope, will make the National Organic Program Proposed Organic Rule a more complete and acceptable set of regulations.
Organic is not a casual or part-time interest of OTA members. This is their business and livelihood. These comments reflect "in the field" experience, not to the lowest common denominator but to a balanced quality standard which reflects the flexibility necessary for process-based standards and the strict procedures which ensure verification and adequate enforcement. OTA expects that these comments will be considered as expert opinion and given the consideration that they are due.
Katherine T. DiMatteo