To The USDA On National Organic Standards

Dear USDA National Organic Program,

Although the USDA’s March 2000 proposed National Organic Standards are a vast improvement over the first proposed rules issued in December, 1997, as an organic consumer I am very concerned that the USDA adhere to the following principles:

(1) Do not weaken or dilute any of the proposed organic rules published in the USDA’s March 2000 document in any manner whatsoever.

(2) Private (i.e. non-govern-mental) and state organic certi-fiers must have the legal right to exercise their free speech, by certifying and labeling products to higher or stricter standards than the minimum “USDA Certi-fied Organic” standards. Private and state certifiers must be able to state on their label that this product “meets or exceeds” or “exceeds” USDA organic standards. USDA organic standards should provide a “floor,” not a “ceiling,” for certification and labeling.

(3) So-called “natural foods” with less than 50% organic ingre-dients should not be allowed to use the word “organic” anywhere on their package or product labels.

(4) Although the proposed regulations on organic animal husbandry require access to out-doors, no clear definition of what constitutes “pasture” are offered, nor does the USDA delineate exact space or spacing requirements for humane housing and outdoor access for poultry, pigs, cattle, and other animals. This proposed set of regulations, as currently written, actually allows for animal factories.

(5) Although the USDA claim they don’t intend to impose economic hardships on organic certifiers and farmers, the added costs of USDA oversight will fall heavily on small certifiers and farmers. The USDA should pro-vide accreditation services to organic certifiers free of change as well as subsidize 100% of the costs of any farmer who wishes to become certified as organic.

(6) Although genetic con-tamination of organic crops by “genetic drift” from farms grow-ing genetically engineered crops is one of the most serious envi-ronmental threats to organic agriculture, no liability provisions for genetic contamination are delineated in the USDA’s proposed federal regulations. The USDA must hold biotechnology patent holders and seed companies accountable and financially liable for the environmental and economic damages inflicted on organic farmers and producers caused by genetic drift.

(7) The USDA’s proposed rule, for the most part, lives up to its claim of prohibiting the Big Three — Genetically Modified Organisms, Irradiation, and Sewage Sludge. This is good, but the USDA needs to close the loop-holes. A general statement pro-hibiting GMOs of any kind (i.e., “excluded methods”) from all aspects of organic production should be included in the body of the Rule. Unbelievably, while ionizing radiation is prohibited, it is not defined. This creates a potential loophole for its use. Finally, while sewage sludge is prohibited, the USDA proposal would allow the use of toxic sewage sludge that has been burned (toxic sewage sludge ash).

(8) The USDA must respond to the many comments made in response to the first set of pro-posed regulations regarding fair labor standards on certified organic farms.

(9) Finally, while organic agriculture has been the best example of a successful and sustainable agricultural system in United States agriculture during the past 50 years; the USDA has shown a disproportionate com-mitment to biotechnology and conventional agriculture. Organic agriculture needs full funding in proportion to its market share. Last year the USDA paid out $25 billion dollars to support conven-tional agriculture. To make the long overdue transition to organic agriculture — which is the only thing that can save America’s family farms — the USDA must allocate billions of dollars, not a mere six million dollars as the current proposed organic regu-lations call for, to ensure a sustainable and equitable future.