National Campaign for Sustainable Agriculture Rejects Proposed USDA National Organics Standards
Jon Greenbaum, Produce Manager Genesee Coop Foodstore

The USDA is poised to enact the National Organic Standards. The standards are up for public review until mid March. After that the USDA can revise them or implement them unchanged. The Consensus within the Organics industry appears to be that we should reject the proposed USDA standards which allow sewage sludge, food irradiation, genetic engineering, factory? farming (the use of intensive confinement feedlots and factory production methods practiced on farm animals), and animal cannibalism (the practice of including diseased rendered cows in cow feed).

The proposed USDA standards ignore the recommendations of the National Organics Standards Board and would destroy three decades of work to ensure the trustworthiness of the certified organic label. "Organic" has always meant more than "free from pesticides and chemical fertilizers". It is a holistic approach to sustainable agriculture. The USDA, however, doesn't seem to understand this philosophy, or perhaps the USDA simply finds a sustainable philosophy antithetical to its present industrial agricultural orientation. If that is the case then it isn't surprising that the standards are also heavily weighted towards large corporations and large farm operations. Although the USDA spends millions of tax dollars on all sorts of programs (like promoting McDonalds overseas) it has decided to pass all the bureaucratic expenses of operating a national organics standards office onto farmers, certifiers, and processors. For example, the new standards would increase the Northeast Organic Farmers Association (NOFA) costs by 20% and would probably put some of the small local organic farmers out of business.

The Organic Subcommittee of the National Campaign for Sustainable Agriculture, (a coalition of 500 organizations) has called for the withdrawal of the USDA proposal. Standards should be rewritten based on the National Organic Standards Board recommendations and the 1990 Organic Food Production Act and resubmitted for public comment again. According to GVOCSA farmer and National Campaign member Elizabeth Henderson, "The proposed regulations are too flawed to fix. We could probably win some easy repairs on the issues that are simplest to understand but we might still be left with a program that would put small organic farms and certification programs out of business."? It is also particularly distressing that the USDA standards have the potential to undermine organic standards in other countries. Currently, the Codex Alimentarius governs international organic agriculture trade. The Codex standards do not allow unsustainable practices such as sludge, genetic engineering, and irradiation, but the U.S. could use the GAFP World Trade Organization to force a lowering of these international standards. This is Not Organic!

Municipalities around the country are taking advantage of the 1984 EPA beneficial sludge use policy which redefines sewer sludge as a "beneficial biosolid" and Part 503 of the 1993 Clean Water Act which allows sewage sludge to be sold as a home fertilizer. Instead of spending millions of dollars to dispose of this waste, municipalities are looking to make some money on the stuff. This is the same sludge that is so toxic that it cannot be legally landfilled. The EPA caved in to lobbying pressure from the Water Environment Federation (formerly known as Federation of Sewage Works Association) and simply lowered its standards. Sewage sludge still contains high levels of heavy metals, and pathogens (such as salmonella, hepatitis A, tapeworms and hookworms, and deadly protozoa and fungi). Furthermore, no government agency has studied the long term affects of annual sludge fertilizer application or its impact on ground water.

This past year genetically engineered foods entered the market in large numbers. Consumers who wanted to avoid eating products that include Monsanto's genetically engineered Roundup Ready Soybeans (soybeans genetically engineered to withstand blistering doses of a Monsanto herbicide called Roundup) knew that they could trust products made from certified organic soybeans. The new USDA standards would no longer guarantee that an "organic" product does not contain genetically altered foods. In a recent poll conducted by the biotech giant Novartis 93% of respondents wanted to see mandatory labeling of genetically engineered foods. Such labeling is particularly important to consumers with food allergies who are concerned that bioengineered foods may expose them to genetic components of the foods they are allergic to.

The bioengineering issue is of particular concern to organic farmers who apply Bacillus thuringensus (Bt) to their crops. Bt is a naturally occurring bacterium that can kill certain pests. Different Bt strains control different pests. The bacterium breaks down fairly quickly so farmers need to time its use precisely. Because it breaks down so quickly pests do not develop a resistance to Bt. The problem is that new transgenic varieties of vegetables containing genetically implanted Bt bioinsecticide are now on the market. If a farmer plants the new transgenic Bt vegetables the crop will provide a constant genetically based pesticide presence for many generations of insects. How many growing seasons will it take before only Bt resistant pests are left in that area? How will we contain these Bt resistant pests? The loss of naturally occurring Bt would be a tremendous blow for organic farmers. The Bt problem is a good example of how bioengineered plants pose a threat to delicately balanced ecosystems. Environmentalists and organic farmers are also very concerned about possible accidental cross-pollination of genetically engineered plants with other plants. If you think kudzu is a problem down in Mississippi, consider the fact that genetically engineered plants are the ultimate exotics.

Irradiation has been used as a method of controlling spoilage since the 1980's. Because irradiation breaks down the foods cell walls, accelerated vitamin loss occurs during storage. Ionizing radiation can also create free radicals which can then lead to the creation of radiolytic products like benzene and formaldehyde. In studies of animals fed irradiated foods there is a significant increase of tumors reproductive failure and kidney damage. Perhaps most importantly, we should not encourage the nuclear industry by providing yet another use for its byproducts. Nor do we need to perpetuate the myth that radioactive substances can be handled safely.

We have until mid March to respond. The National Campaign for Sustainable Agriculture Organics Sub Committee is calling on consumers to contact the USDA and tell them to withdraw-rewrite and resubmit the standards for another public comment period. Send copies of your comments to your legislators and ask them to contact Secretary Glickman and tell him how upset their constituents are about these regulations.

Letters to the USDA should be sent to:

USDA-National Organic Standards
Docket #TMD-94-00-2
USDA, AMS, Room 4007-S
AgStop 0275, P.O. Box 96456
Washington, D.C. 20090-6456

fax: 202-690-4632 (Include docket number)

e mail: see http://www.ams.usda.gov/nop

Sources: SynthesislRegeneration I5- Winter 1988; NYSAWG News-Winter
1988: Organic Farms Folks and Foods-Celebration 1997; The Natural Farmer
-Winter 97/98;? In These Times: Oct. '95,? May '96, June '96, April '97,
Oct. '97