I think a small farmer who is "in transition" to organic should not be held back in any way.
I was just surfing the USDA site and I started reading a transcript(No Adobe required)
a public forum the agency held there a few months back.
I know this website's space is limited, but check out what this guy says about the government "adjusting the proposal"
Hi. My name is Sean
Marquis. I am an organic farm worker. I am a member
of NOFA New Jersey, and I am a member of the George
Street Co-op, which is an organic foods co-operative.
Most importantly, I buy and I eat organic food.
I would like to make a quick comment about
what this gentleman asked earlier about things being
in there like irradiation and whatnot that are there
as questions, as Bob Anderson said, and not as part of
the actual proposed rule.
In my view, if it's in there, it's in
there to stay unless we actually rip it out. It's not
there as a question. It's there unless we take it
The final recommendations of the NOSB were
the culmination of nearly seven years' work. The USDA
needed about four months to turn them into garbage.
I am left with five minutes to comment on this fiasco.
You're too generous.
The proposed USDA rule on organic
agriculture is full of the influence of big business
and big money. This is quite evident in the section
on supplementary information. There we see such
phrases as "facilitate commerce," "facilitate trade,"
and "taking full advantage of international markets."
In the subsection "Summary of Benefits of
the Proposed Rule," we see more of the same, including
the following, quote, "Opening access to international
markets. The trade restrictions that currently exist
would be resolved. Larger growth in exports. Organic
producers could expand the scale of their operations
and USDA activities to negotiate equivalency of
organic standards in world markets."
This is an attempt to bring down the level
of the playing field through NAFTA, the GATT, the
World Trade Organization, and the world court. Most
other countries, particularly the European Union, have
much higher organic standards than those that exist in
the USDA proposed rule.
Rather than make the USDA standards more
comparable to other more stringent international
standards, the game seems, rather, to be to low-ball
Once this rule becomes law, the USDA can
then use GATT, NAFTA, and the World Trade Organization
to sue the European Union and others in the world
court for having restrictive trade barriers. This
will then fulfill the USDA's claim that, quote, "The
trade restrictions that currently exist would be
Another prong of its attack stabs directly
at the heart of small farmers, consumer groups, and
certifying agencies that built the organic industry
literally from the ground up.
With minimal resources and a lot of
determination, it created a burgeoning $4 billion a
year industry. Instead of a progressive fee
structure, the USDA recommended a flat rate fee
structure. This unfairly burdens the smaller aspects
of the organic food production process in favor of
economies of scale.
In Parts 205 and 209 of the rule, cost of
the proposed rule, direct program cost, this is
clearly stated as, quote, "Due to the fixed components
of the fees, larger certifiers would have the ability
to spread their costs over a greater number of
Also, this section refers to certifiers
having to, quote, "Furnish reasonable security for the
purpose of protecting the rights of farms, the amount
and type of security would be established through
future rulemaking." How much?
Private certifiers receive their funding
by charging fees to farmers and handlers to cover the
expenses of certification. Any fees charged to the
certifiers by the USDA will in some fashion will be
passed on to farmers and handlers. So the small
certifiers, farmers, and handlers all get nailed
This practice continues in the
certification of foreign programs seeking equivalency
with the USDA program, as per Section 205.423. Small
certifiers and farming co-operatives, particularly in
regards to Southern nations, will be unfairly burdened
by all the USDA fees, plus having to fund the
transportation, accommodations, and expenses of USDA
representatives to come to their country and review
their programs. This also threatens indigenous
populations that practice sustainable harvesting for
Where are these traditionally poor groups
going to get the monies needed under this program?
What this proposal does is make it very easy for
conventional agribusiness to slap on an "Organic"
label, price out small farmers and food operations
while still charging a premium, glutting the market
and destroying, once and for all, the small farmer,
all the while reaping huge profits.
Section 205.219(b)(2), quote, "The
Secretary may waive ineligibility for certification if
it is in the best interest of the program," end quote.
This is extremely broad, ambiguous, and arbitrary, and
leaves a huge opening for rule-bending, rule-breaking,
favoritism, and corruption. Get rid of it.
Section 205.8(a). Treated seeds are
treated seeds. They are synthetic and should not be
Section 205.3. An irrigation water plan
and standards for irrigation water should be a part of
the organic standards.
Section 205.8(c). GEOs are synthetic and
are not allowable.
Section 205.17. Ionizing radiation is
synthetic and, therefore, not allowable.
Section 205.22. Biosolids, treated
municipal waste, sewer sludge, however you wish to
term it, this is a synthetic material and should not
Section 205.107 is a solicitation for
alternatives for the proposed USDA organic symbol. I
suggest the international biohazard symbol. If this
proposal goes through as is, that would be truth in
What do you think? Have you "commented" yet? Today is the last day if you haven't. If they listen to our comments perhaps we won't have to march on Washington.
The entire transcript of the Jersey meeting is at http://www.ams.usda.gov/nop/jersey.txt
The site also has a "comment box" for each of the proposals.