COMMENT
of the Organic Trade Association
on the
National Organic Standards Board draft:
“Principles on Organic Production and Handling”'

July 31, 2001
 

Submitted by

Tom Hutcheson, Policy Coordinator
Organic Trade Association

P.O. Box 547, Greenfield, MA 01302

 
(Proposed revisions in bold)

1.1 Organic agriculture is an ecological production management system that promotes and enhances biodiversity, biological cycles, and soil biological activity. It emphasizes the use of management practices in preference to the use of off-farm inputs, taking into account that regional conditions require locally adapted systems. These goals are met, where possible, through the use of cultural, biological, and mechanical methods, as opposed to using synthetic materials to fulfill specific functions within the system.

1.2 An organic production system is designed to:
1.2.1 Optimize soil biological activity;
1.2.2 Maintain long-term fertility;
1.2.3 Minimize soil erosion;
1.2.4 Maintain or enhance the genetic and biological diversity of the production system
and its surroundings;
1.2.5 Utilize production methods and breeds or varieties that are well adapted to the
region;
1.2.6 Provide livestock with optimal living conditions that promote their health and well
being;
1.2.7 Recycle materials of plant and animal origin in order to return nutrients to the land,
thus minimizing the use of non-renewable resources;
1.2.8 Minimize pollution of soil, water, and air; and

[Proposed revision:  Replace 1.2.8 with AOS 3.6.8:  Promote the environmentally responsible use of soil, water, and air, and minimize agricultural pollution; and]

1.2.9 Become established on an existing farm or field through a period of conversion
(transition), during which no prohibited materials are applied and an organic plan
is implemented.

1.3 Organic handling practices are based on the following principles:
1.3.1 Organic processors and handlers implement organic good manufacturing and
handling practices in order to maintain the integrity of organic products through all
stages of processing, handling, transport, and storage;
1.3.2 Organic products are not commingled with non-organic products, except when
combining organic and non-organic ingredients in finished products which contain
less than 100% organic ingredients;
1.3.3 Organic products and packaging materials used for organic products do not come
in contact with prohibited materials;
1.3.4 Proper records, including accurate audit trails, are kept to verify that the integrity
of organic products is maintained;
1.3.5 Organic products are handled using processing methods that maintain the organic
integrity and quality of the products; and
1.3.6 Organic processors and handlers use practices that minimize environmental
degradation and consumption of non-renewable resources. Efforts are made to
reduce packaging; use recycled materials; use cultural and biological pest
management strategies; and minimize solid, liquid, and airborne emissions.

[Proposed revision:  replace 1.3.6 with AOS 3.7.6:   Ecologically sound management practices should be a goal of organic handling operations. Efforts should be made to reduce packaging, use recycled materials, and reduce solid, liquid, and airborne emissions produced by handling operations.]

1.4 Organic products are defined by specific production and handling standards that
are intrinsic to the identification and labeling of such products.

1.5 Organic standards require that each certified operator must complete, and submit
for approval by a certifying agent, an organic plan detailing the management of the
organic crop, livestock, wild harvest, processing, or handling system. The organic
plan outlines the management practices and inputs that will be used by the
operation to comply with organic standards.

1.6 Organic certification is a regulatory system which allows consumers to identify and
reward operators who meet organic standards. It allows consumers to be
confident that organic products are produced according to approved management
plans in accordance with organic standards. Certification requires informed effort
on the part of producers and handlers, and careful vigilance with consistent,
transparent decision making on the part of certifying agents.
1.7 Organic production and handling operations must comply with all applicable local,
state, and federal laws and address food safety concerns adequately.

1.8 Organic certification, production, and handling systems serve to educate
consumers regarding the source, quality, and content of organic foods and
products. Product labels must be truthful regarding product names, claims, and
content.

1.9 Genetic engineering (recombinant DNA technology) is a synthetic process
designed to control nature at the molecular level, with the potential for unforeseen
consequences. As such, it is not compatible with the principles of organic
agriculture (either production or handling). Genetically engineered/modified
organisms (GEO/GMO’s) and products produced by or through the use of genetic
engineering are prohibited.

[Proposed revision:  replace 1.9 with a re-worded AOS 3.10:   Products produced by or through the use of excluded methods, such as genetically engineered/modified organisms (GEO/GMO’s), are not compatible with the principles of organic production (either the growing, manufacturing, or processing) and are not permitted under these standards.]

1.10 Although organic standards prohibit the use of certain materials such as synthetic
fertilizers, pesticides, and genetically engineered organisms, they cannot ensure that
organic products are completely free of residues due to background levels in the
environment.