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A Few Thoughts
Deb Paulson asked that I again address some of the organic
certification issues that have been discussed so much of late. Sal has
raised many important and pressing issues, with passion. But his style of
communication, his anger, and tendency to go on and on is starting to both
turn people off and obscure the real issues and need for thoughtful,
organized action.
I also implore everyone on this list, indeed all lists, to remember
the power of kindness and a little civility and humility. I wish Sal would
drop the sarcasm and constant accusations about peoples' and organizations'
motives. Calling USDA staff and other people involved in organic
certification "pencil pushers" at best does not help and at worst is
demeaning and sends a terrible signal to consumers. Plus, it will not help
resolve the underlying and very real problems Sal has raised.
Venting his spleen may make Sal feel better, but it does not a
movement make. If Sal (and other farmers) were to divert his (their) time
to making the case for change and coalition building, who would tend his
(their) farm(s)? Organic farmers are not well represented in the current
mix of players on these issues. The organic trade is more directly
controlled by the businesses processing and selling organic produce. Some
sustainable agriculture, consumer, farm worker and environmental
organizations will be addressing some/all of the points Sal raises in their
official comments to the USDA NOP regulations, which have been in "soon to
be published" mode for the last six months (or two years, depending on how
you count). But the trade will have a different set of concerns, and will
have much at stake in moving the regs closer to thier positions. It remains
unclear whether the organic farmer will receive a fair share of the
benefits/burdens when all is said and done.
How can Sal and other concerned and knowledgeful farmers help? By
educating the variety of trade, consumer, environmental and other
organizations that will be doing comments on the proposed organic program
regulations. Sal has put some key issues on the table that WILL be addressed
in the regs at length -- fee structures, the size of farms exempt from
sales, how the exemption should be applied, need to avoid duplicative
paperwork and overlapping certification, fair treatment of organic farms
sprayed as part of APHIS region-wide programs (like med-fly control), role
of genetic engineering in organic farming.
In response to Deb's questions, both private NGO-like organizations
and state governments run certification programs. The programs compete for
business through price, quality, and links to the marketplace. Some
certifiers are known and trusted in Europe, others in Asia, and some
specialize in parts of the food system (processing, for example). Competion
in the world of certifiers has been a generally good thing, except for a few
that have so diluted the integrity of the process that they now threaten to
drag down the whole industry.
The USDA is not going to get into the certification business
directly; what they will do is accredit existing and future certification
programs as "up to standards". What does that mean? It is sort of like
what educational boards, or hospital accrediation does for an academic
institution, or a hospital. These accrediting bodies review competence,
procedures, the record, and phyical assets to determine whether they can
deliver an acceptable product or service, as advertised. At a minimum, USDA
accreditation will catch, and deal with those certifiers not competing on a
level laying field, i.e. by offering certification services for half the
cost, and better yet, with NO PAPERWORK. Send us the money and we'll send
you our seal. This is not the kind of certification Sal wants to see.
At the risk of greatly simplifying a complex process, and leaving
some things out since I am a bit rusty on this front, I will summarize what
it means when an organic certifier is accredited by USDA, or IFOAM (the
international organic federation), or anyone else. It means that the
certifier has clear and meaningful organic production standards that are
minimally in compliance with some established standards, and some existing
allowed/prohibited inputs list; that the certifier calls for and receives a
credible organic farm plan; that the certifier hires or has on staff
competent inspectors who file reports that contain information needed to
reach judgements that a given grower is in compliance with required
standards; that "chain of custody" can be documented as food is harvested
from x field and is sold through the system; and that the decision to
certify a given grower is based on a factual record that supports the
judgement the grower is in compliance, and that the decision was reached by
a body qualified to make such judgement and free of conflicts of interest.
Once the USDA regulations are in place, the Department will start
accrediting certifiers, as the law requires. This need not add a new tax on
organic farmers. Since the regulations are not out, I do not know how the
costs of accreditation will be set or paid. I do not know how certifiers
will pass on the costs to their growers. But I suspect the cost of gaining
USDA accreditation will be modest relative to a certifiers operating budget,
and that it will translate into just a few cents per acre extra certified.
If Sal is paying $10.00 per acre for certification now, he might pay $10.08
for USDA-accredited certification. Will the benefits of having USDA
accredited certification be worth 8 more cents to Sal? My personal guess is
that, despite some ongoing controversies and inefficiency, it will be
supported by and worth it to scrupulous organic producers and the better
certifiers. It may well be opposed by those just seeking the cheapest way
into the organic market and who view the certification process has little
more than a paperwork hassle to work around.
The basic purpose of certification is to gain and keep consumer
confidence in organic food, whether grown on a large or small farm. If the
consumer is turned off to organics by bad press over fraudulent organic
practices, or shoddy certification, it will not matter if the farms involved
were large or small. Run well, as some certfiers are doing today,
certification can be a positive process of reflection regarding what a
farmer is doing and why their system is working, or sometimes does not work.
It can foster valuable information exchange, help define research needs and
the limits of new technology and inputs, and it can stimulate collegial
review of methods to overcome common problems.
Stepping back, there are two major dimensions of this debate. One
dimension/question can be stated simply as -- Is certification needed at
all? Why should organic farmers go out of their way, and bear the cost, of
getting a stamp of approval when they are, as Sal says, the "good guys"?
Enough said on this front.
Second, if there is going to be certification, how can it be done
fairly and efficiently, in ways that build consumer confidence in the
industry, and which stand the tests of time? The USDA's entrance as an
accrediting body is relevant to this question, but not terribly germane to
the first, unless it is answered affirmatively.
Certification is a formal way for the consumer and farmer to cut a
deal within dynamic and open marketplaces. The consumer agrees to pay a
little more, and sometimes go out of their way some, or alter their choices,
in return for knowing, or at least believing that what they are buying has
been grown and processed in a substantially different and less ecologically
damaging way. Certification is a tool organic farmers and the trade have
used to build confidence and recognition in the marketplace. It is
something the industry has developed itself as a proactive way to accelerate
change. Other avenues such as certifiying conventional produce as damaging
to the environment and threatening to health, is tied up in committee.
It is a HUGE mistake, in my judgement, to load onto the debate over
certification all the ills and controversies on the agriculture scene today.
Organic certification has almost nothing to do with trends in the size of
farms or farm structure. It did not cause them nor will it change them. Nor
is it the place to fight over region-wide mandatory spray programs, although
there is a need to address consequences for organic farmers unlucky enough
to live in a quaranteen area or where all land is sprayed. It is a critical
place, though to debate the role of genetic engineering in food production,
since people have a right to know and so many want more information on
labels about how their food is produced.
Those who support organic farming need to keep their eye on the
important balls as they work with colleagues, associates and organizations
to respond to the USDA proposed rule. I think a broad coalition still might
come together, and through speaking with a more or less united voice, could
convince USDA to take some of Sal's advise. But there is much work to do to
go from here to there. Its time to move ahead for those who want to make a
difference.
Note New New Address!!:
Charles Benbrook 208-263-5236 (voice)
Benbrook Consulting Services 208-263-7342 (fax)
5085 Upper Pack River Road benbrook@hillnet.com [e-mail]
Sandpoint, Idaho 83864 http://www.pmac.net
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