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Re: comments onUSDA/NOP cost and benefits to organic farmers and handlers
In a message dated 97-10-09 11:57:22 EDT, Sals@rain.org writes:
<< Subj: Re: comments onUSDA/NOP cost and benefits to organic farmers and
handlers
Date: 97-10-09 11:57:22 EDT
From: sals@rain.org (sal)
To: Erorganic@aol.com, sals@rain.org, sanet-mg@ces.ncsu.edu
CC: smallfarm-mg@maat.reeusda.gov
I love when this guy posts because he makes my case for me. The USDA
/NOP is not going to benefit the small farmer and will force him out it
is set up for the big boys. .
eak: It is a pleasure to be your foil Sal.
When this thing started we ask what about
the small farmer and were told don't worry there will always be a place
in organic growing for small farmers sal . Well the $5000 gross is not
what I call a help for a small farmer. These folks also want to make the
small organic farmer a factory farmer and like this guy says if you can't
pay you can not play. He says if we cannot afford this new tax on
organic farmers we can not call yourself organic even if you are .
eak: When you buy diesel Sal, you pay a tax that does a service. When you
take a plane you pay a tax that does a service. When you pay an annual
property tax, it does a service. The quality and dependability of those
services are on balance higher then what service you get when you go to a
store and buy something. However, the basic difference is a public service
must and should be impartial, be without prejudice and favoritism. Part of
the payment for service is to make sure that prejudice and favoritism do not
occur in carrying out the pupose. Fortunately, this government has in place
an overal size and person neutral policy. That is what makes little guys
like me able to have a fair chance. Now, as soon as someone thinks they
have been wronged they want to change the rules. Logical. But by the same
token, it is important to understand the Proposed Rules or Rules. Let me put
it straight Sal. OFPA was passed by Congress in 1990. It is on balance the
finest piece of organic legislation in the world and the finest environmental
legislation that has been passed--that is not opinion, but I can back up line
by line. This continuing conversation indicates you do not know its content,
you do not know the processes and procedures built in OFPA as well as the
Regulatory Flexibility Act, the Administrative Procdures Act, to make the
USDA/NOP work as a National Program and to rectify the existing inequities
and unfairness that exist within states. If your not willing to discuss
issues that relate to reality, but would rather rant against taxes and cry
over the need for every cent to make your farm sustain, it is fast coming
time to move on to the issues, not your personal opinions.
This
guy is supposed to be working for us but I feel he is working for the big
boys and he is saying if a a organic farmer is not serious if he is poor
and fighting to keep his land he is not really an organic grower. That
covers a lot of folks.
eak: Wrong analysis Sal. I am continually becoming more informed and
thinking about the options. You really tweak my curiosity. What is your
average volume of sales weekly? I try to average $700-$800 over the last 6
years. Below $450 I wouldn't go to market. Then again, I have spent 30
hours a week for six years trying to get the USDA/NOP implemented to serve
small to moderate size organic farmers and handlers and to provide a
completely trustworthy label for customers.
. This is sad. and the problem is that once
this Act goes though it will take a act of congress to change it. We
don't need to make more problem for the small farmer. He acts like $250
here and $400 there is nothing but to some folks they need every cent to
live their organic farming lives. They are making the organic farmer pay
for this whole ball of wax and the smaller farmer may be lost in the
shuffle. And where does he get this $250 out of his own head that is
where and that is where the NOP must have gotten the $5000 gross is a
small farm.
eak: Are you certified Sal? What are your certification costs? I am
President of Arkansas OCIA, have been integral in administrating two
different certification agencies, have spent the last years making myself
knowledgeable of the cost and operation of every certification agency in the
world. Even in California with higher costs, a small to moderate size
vegetable farm certification, 2 to 25 acres, a small to moderate handling
operation can be done for reasonable price. If the certifying agents
operating in California cannot beat $250 a farm and $450 a handling operation
on this scale, it is time for some competition. I prophesize that under the
NOP their will be qualified certification agents that can do the job in
California as they do in every other state for these prices. These prices
are not the prices that are charged or should be charged to Danny Duncan,
John Givens, Dale Coke, Bill Knudsen or Health Valley. Simply, because it
takes longer and is more arduous to perform such certifications. The
USDA/NOP adding $20 more to every farmer applying and $40 more to every
handling operation applying easily raises $140,000 per year at the level of
5000 farm and 1000 handling operation certifications the first year. After
the first accreditation round of certification agents, the next review is
mandated within 5 years. Of the 50 certification agencies, that means 10
must be reviewed each year. Certainly, $14,000 apiece is enough to review
the accreditation status of a certification agency and provide support for a
qualified Peer Review Panel to assist the Secretary of Ag to make a
determination. In fact, there should be excess funds to carry on some of the
other USDA/NOP responsiblities indicated below. As the numbers of farmers,
handlers and certification agencies grow so will the job responsibilities of
the USDA/NOP and so will their annual budget.
What are the responsibilities of the USDA/NOP staff once the proposed rule is
finalized? The budget is defined by the work necessary.
-To determination accreditation eligibility of all certification agent
applicants.
-To determine equivalence of ag products imported into the US to OFPA
standards of farming, handling and certification. This is not determined on
a case by case basis, but on a sovereign nation to nation basis, with the
USDA/NOP making the determination and representing the interest of US farmer
and handlers. A charge could be made to importers of organic products for
these services.
-To provide general information to the public on how the USDA/NOP operates,
its standards, etc.--where public access to certification documents and
residue testing are available
-To inform other Federal and State agencies on the standards, qualified
certified farms and handling operations and appropriate enforcement actions.
The USDA/NOP with the exception of cease and desist on operation of an
accredited certification agency will not actually enforce the organic
standards and rules. The state governing official and the accredited organic
certifying agents are the first line of complaint and enforcement per the
guidelines laid down by the NOP. There power on one hand is in removing or
granting certification status. The State governments have multiple powers to
prosecute in the interest of the general welfare and issue cease and desist
labeling orders. The accredited certifying agents will as agents of the US
Government determine whether a farm or a handling operation meets the
requirements to use the word "organic".
With implementation of the USDA/NOP, FDA and its regional offices will
enforce all processed food, dairy products, fish and shelled egg labeling
using of the term "organic". USDA through FSIS (Food Safety and Inspection
Service) will enforce all red meat, poultry and processed egg labeling using
the term "organic". PACA will do likewise for "organic" labeled vegetables
and fruits. Fiber and field crops fall under multiple agencies that will
carry out enforcement. There are State agencies that have similar powers of
enforcing labeling descriptions who will do likewise. All state agencies
will operate under enforcement guidelines established by the Secretary of Ag.
There will be consistency and uniformity of application of enforcement,
standard and requirement for certification guidelines nationwide. We have
already reviewed what a State must go through to establish additional
guidelines that must be approved by the Secretary of Ag as applicable to the
specific State only. All State and Federal agencies will ultimately refer
back to the master list of certified organic farms and handling operations
maintained by the USDA/NOP to determine if a particular label can use the
term "organic". The list of certified organic farms and handling operations
as well as accredited certifying agents will be available on the Web, updated
daily.
-And lastly, the USDA/NOP has the responsibility to review any NOSB Proposed
Amendments to the National List, provide for a public comment period on such
amendments and publish final changes in the National List or regulatory
Rules.
That is the full extent of the USDA/NOP's responsibility under the Organic
Food Production Act. Much of the USDA/NOP information program should be on
the Web with some printed material. It always takes time and budget to setup
a smooth running and cost effective program in any business or government.
It is essential to have the persistent input of organic farmers and handlers
nationwide. We must require, review and make sure that the National Organic
Program truly is efficient and benefits its clientele. Within two years
after OFPA's implementation, the USDA/NOP should be self sustaining and have
a minimal of staff. The benefits to everyone will be immense, provide
USDA/NOP is run efficiently and limits its work to its mandate by Congress.
This is too important to be making up numbers we are
dealing with people lives.It is not fair to change the rules on the small
organic farmer . He is not stating it will only cost $250 because it is
fact he is just trying to sweet talk you all. I live in Ca. and even
here in the heart of organic land it is hard to find a close inspector
that does not have to travel long distances what about the poor small
grower in the big timber Wy. where the inspector will have to travel many
hours and have to charge the small farmer gas,salery,motal
room,inspection and time it takes to do paper work and this will cost the
poor farmer even if he is doing the good he knows.
eak: I find it informative to ask the farmer in Montana, Ohio, Colorado or
Texas what their existing cost is for what size and type of operation? What
improvement could be made? The biggest complaint I have gotten is the
inspectors are not experienced enough in the type of farming or in organic
farming or handling. Both farmers and handlers dislike paying people with
less knowledge then they have to certify them. But let us remember these
complaints are about now and the past years under the existing privately run,
some for profit, some non-profit certification system. The USDA/NOP needs to
be forcefully reminded that such ineptness is unacceptable. When it really
hits the fan is when it is found that a California certified organic farmer
or handler is certified by more lenient standards than an East Coast farmer
or handler and vis a versa. USDA/NOP will solve this problem--a consistent
and uniform national organic standard and method of organic certification.
We not only have to
support our self be now we have to support all these other folks. Don't
let this guy sweet talk you .once this act is in it will take a act of
congress to change it.
eak: Correct. It will take an Act of Congress to change it. In the interest
of the entire organic community, regulatory administration should not be
allowed to change the content and purpose of the Organic Foods Production
Act. This is why it is absolutely important to contribute informed public
comment during the Proposed Rule public comment period. The Organic Farmers
Marketing Association will be providing a side by side comparison of
contradictions between the USDA/NOP Proposed Rule and OFPA on the OFMA Web
site within one day of its issuance to the public. Written comparisons will
be sent out to our mailing list of 15,000.
the $5000 small farm exemption is a Joke and a
insult to all those poor folks fighting to keep their farms. It is sad
that the money and the paper work is more important than a mans
righteousness.
eak: No one every questioned a person's righteousness when he or she were
directed to drive down the right side of the street. It is a set of rules so
everyone is on an even playing field and a pedestrian (the consumer) knows
how not to get hit. You are correct that all rules do get applied
personally. However, they are for the general welfare and benefit and as
such must be impartial, have rational criteria and be decided on and
supported by reasonable consensus of those effected.
Small Farmers will be persecute because they can not afford
to play and did not dot their i or cross their ts and not for any wrong
they have done. Some folks that grow organic will be persecuted just for
telling folk the truth that they are organic. Organic farmer still have
to do what other farmers do like complete paper work on all pesticide
they use if it is organic or not also they have to follow all the others
rules that other farmers follow but this is a extra tax on them alone
for what they <bigger>DON'T USE .
eak: Everyone who thinks they have a better idea for themselves and others,
often all others, sooner or later has to watch out for being self righteous.
I, you and now millions of others know the use of synthetic chemical
pesticides, synthetic fertilizers, synthetic ingredients, processing aids,
and food additives in processed foods has and is an error. We still have the
status quo that have benefited from their use in place. Citizens still have
the option of smoking or buying non certified organic products. If you can
pass a law taxing synthetic pesticide/fertilizer use and using that tax to
develop a National Organic Program, I think that would be in the public
interest and I am ready to back such. If you are throwing out ideas great.
If you are suggesting to torpedo really what is the only Congressional Act
in many years that creates the potential for radical change in agricultural
and land use practices in the US (including benefiting small to moderate
farmers), as a friend once said take your proposal, wrap it up and chuck it
as far as you can throw it.
</bigger>He says there is are people
selling organic that are lying. This may be true. There are people that
steal be we don't search every ones house in the whole US because a few
folks steal. We should not search every organic grower place in the
whole US year after year after year and charge them money for it because
a few people may lie. Some of us cannot afford it. Even when we do
search some ones house we have a warrant and have to show just cause
because it is private property but here they want to search every organic
farm and charge us to do it just because some one may be a lier. HEY
THIS IS PRIVATE PROPERTY
eak: Are you certified Sal? No one searches your farm during inspection. If
they do and there have been instances of such overzealous inspections, that
inspector needs to be reprimanded, if not removed from such a position. Have
you had such invasions of your privacy Sal? Please inform OFMA of the
certification agency and the inspectors name. email the information to
cvof@iquest.net
.I say if some one knows an organic farmer is
lying let someone know like the state or a certifier so they get a
warrant and check him out but don't search and tax and burden every good
organic grower in the whole of the US because someone may be lying. A lot
of us can not afford it. The history of the presentUSDA?NOP act is a
history of repeated injuries and usurpations, all having in direct object
the establishment of an absolute Tyranny over small organic growers.
eak: Sorry you see the USDA/NOP that way. To make it clear, the USDA/NOP
has yet to be implemented because we have tried to take into serious
consideration public input such as you have made. If your having trouble in
California, you must not be able to control your own State government and
bureaucracy. You are simply scapegoating others for your own inadequacy to
form a consensus in directing the State of California. Personally, if you
don't mind a little information from outside California, many people think
California organic vegetable farmers are doing very well. Many of them are
not even certified, but just send their money in with no farm or handling
plan and get registered "organic". They manage frequently to provide very
stiff pricing competition for organic producers outside the state. Maybe
your whole tirade is just a smoke screen to not have California farmers and
handlers operate according to the USDA/NOP standards. Just makes a farmer
ruminate over the back fence, doesn't it.
Best in all your efforts, Eric Kindberg
The Organic Farmers Marketing Association at www.iquest.net/ofma/
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