Washington Tilth Producers and the WSDA Organic Advisory Board


ORGANIC STANDARDS ARE IN JEOPARDY!!

As Tilth Board members and members of the WSDA Organic Advisory Board we are writing this letter because this is a crucial time within the Organic Foods Industry. The USDA has recently released their proposed rules for the National Organic Program (NOP). After reviewing this document, we believe there is a strong need for a coordinated response. We must insist on standards that follow the true meaning of organic agriculture.

To summarize the process to this point. In 1990 Congress passed the Organic Foods Production Act (OFPA). This mandated the USDA to set up a National Organic Program (NOP). Within this mandate, authority was given to form the National Organic Standards Board (NOSB), a fourteen member board comprised of people within the organic community. The NOSB worked for six years to come up with recommendations for the program. From these recommendations, the USDA wrote the NOP proposed rules released December 16, 1997 for Public review and comment through April 30.

As written, the proposed rule will undermine a meaningful organic program. The rule should be rewritten to more closely reflect the NOSB recommendations. We need your comments now! Write a letter; send E-mail; attend the hearing.

We have outlined some key issues to use in your letter. Please identify yourself, where you live, what you do, and why this proposed rule is unacceptable. Be as specific as possible.

Come to the USDA Meeting on the Organic Standards
February 26 - Rainier Room at the Seattle Center, 
305 Harrison Street, from 9 a.m. to 4 p.m. 
We need to fill the room. 
People are invited to comment and their comments will become part of the public record. Please attend and submit written and oral comments. Comments are limited to 5 minutes per person. To sign up, call Karen Thomas at (202) 720-3252. Soon!
WRITE or E-mail:
The USDA  proposed rule can be viewed through the internet NOP homepage at http://www.ams.usda.gov/nop or a copy can be purchased for $8.00 from the federal Register by calling 
(202) 512-1800. Comments must be received by April 30, 1998, and can be mailed, faxed, or emailed to:
Eileen Stommes, Deputy Administrator 
USDAAMSTMÑNOP 
Room 4007S, Ag stop 0275 
P.O. Box 96456, Washington DC 20090-6456 
http://www ams.usda.gov/nop      Fax: (202) 6904632

Comments should include docket number TMD94-002. It is also helpful to include the specific information including the Comment Topic Heading and Federal Register page no. (ex. 62 FR 65801). These are provided with the issues.


The top threats to the Organic Industry as set forth in the Proposed Rule.

1. The Rule needs to be rewritten 
(comment topic:  General: 62 FR 65869)

The definition of organic as written in the proposed national organic standard fails to adhere to the requirements of the Organic Foods Production Act (OFPA 7 U.S.C.S. 6501). Additionally, the OFPA clearly mandates that the NOSB has the authority to 1) provide the Secretary of Agriculture with recommendations and 2) to develop the Proposed National List. The rule should be revised to more closely reflect the original intent of the law.

2. Genetically Engineered Organisms (GEO) 
(comment topic General/Crops/ National List, sec. 205.2, 205.6)

The NOSB recommended prohibiting the use of GEOÕs in organic production systems. We support this position.

3. Food Irradiation 
(comment topic: Handling/National List Section 205.17, 62 FR 65884)

The NOSB recommended against the use of ionizing radiation in the handling of organic food. There should be no irradiation of organic foods.

4. Sewage Sludge 
(comment topic: Crops/National List  sec. 205.22, 62 FR 65892-3)

Sewage Sludge from municipalities may contain heavy metals, pesticides and other contaminants. The NOSB found sewage sludge unacceptable for organic food production. We support their recommendation.

5. Weakened Livestock Section 
(comment topic: Livestock sec. 205.14, 205.15)

The proposed rule disregards careful consideration by the NOSB that requires livestock to have access to the outdoors, pasture and sunlight. The proposed rule would allow most confinement operations including caged laying hens, feedlot beef and confinement hog operations. Furthermore, it reduces the requirement for 100% organic feeds to 80% and reduces or eliminates the restrictions of use of animal protein for feed and medications including antibiotics and parasiticides. We support the NOSB recommendations.

6. Fees and reCOrd keeping requirements 
(comment topic: Fees sec. 205.421425, 62 FR 65890)

The NOSB recommended that the USDA minimize the financial impacts to small businesses. The proposed rule creates a regressive flat fee structure which will cause a severe financial burden on small farmers, organic food handlers and private certifying organizations. This rule could reduce the numbers of companies willing to offer organic foods to consumers.

7. Loopholes and Inert ingredients 
(comment topic: Crops/Handling/National List, sec 205.20, 62 FR 65890)

The proposed USDA rule eliminates the carefully crafted language and definitions governing specific materials in the National List. These changes will create loopholes that will allow inappropriate materials to be included in the National List. Additionally, the USDA  proposed allowing Materials in EPA list 2, ÒSuspected Toxic Inerts.Ó  The NOSB recommended that these inert ingredients be prohibited from organic product formulations They do not belong in the organic program.

8. USDA would prohibit eco-labeling 
(comment topic: Labeling, sec 205.103)

It was the intention of the NOSB to allow specific production claims that reinforce knowledge of production practices  to the consuming public. As proposed the USDA would eliminate any labeling not in accord  with the rule. This would eliminate the ability of consumers to choose those practices important to them, such as humanely raised livestock.

9. Vague unenforceable language 
(comment topic: General/Crop Production, sec. 205.3, 205.7(a,b,c,) )

The proposal states that growers must use production materials according to an order of preference but does not define what that means. The proposal states that materials must be used in a manner that does not significantly contribute to environmental degradation but then does not define any parameters.  The NOSB recommended that a farm plan to address these issues and more be provided with the application as a way to monitor the farm practices over time.


In closing, we all have seen the phenomenal growth, in both quantity and diversity of organic food over the last few years. The integrity that now exists in organic agriculture has evolved in a twenty year process from our farms to the private and state certification organizations. If now is the time for a National Program, it has to be one that reflects the standards and integrity that now exist, not one that blurs the lines between conventional and organic agriculture. We need a strong vocal response before the proposed program becomes a reality


The time to comment is nowÑ 
the time to act is now!!


For more information, please contact :
 
The Organic Trade Association (OTA) (413) 774-5484 or visit their website at www.ota.com;
Washington State Department of Agriculture (WSDA), Miles McEvoy  (360) 9021877;
Washington Tilth Producers 800-731-1143;
Washington Sustainable Agriculture Working Group (WASAWG) 
	John Faucett- Long (206) 9358738.