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I hope you can open this attachment - it is a brief analysis of
the Rule by the members of WSDA's adviosry group and Washington Tilth.
Also contains further info on how to ccomment, the hearing this Thursday
in Seattle, etc. We have a short list of people who will put up
out-of-towners, if needed, let me know.
I understand that a number of people dressed as fruits and
vegetables will be around when the press conference is held at 11:00 Am.
Se you there!
Margaret
---------- Forwarded message ----------
Date: Mon, 23 Feb 1998 17:36:25 EST
From: [EMAIL PROTECTED]
To: [EMAIL PROTECTED]
Subject: Organic Farming Rule changes
This is being sent at the request of Diane Dempster
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Washington Tilth Producers and the WSDA Organic Advisory Board=0D=0D=0DOR=
GANIC STANDARDS ARE IN JEOPARDY!!=0D=0DAs Tilth Board members and members=
of the WSDA Organic Advisory Board we are writing this letter because th=
is is a crucial time within the Organic Foods Industry. The USDA has rece=
ntly 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 me=
aning of organic agriculture.=0D=0DTo summarize the process to this point=
.. In 1990 Congress passed the Organic Foods Production Act (OFPA). This m=
andated 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 c=
ommunity. The NOSB worked for six years to come up with recommendations f=
or the program. From these recommendations, the USDA wrote the NOP propos=
ed rules released December 16, 1997 for Public review and comment through=
April 30.=0D=0DAs written, the proposed rule will undermine a meaningful=
organic program. The rule should be rewritten to more closely reflect th=
e NOSB recommendations. We need your comments now! Write a letter; send E=
-mail; attend the hearing.=0D=0DWe have outlined some key issues to use i=
n your letter. Please identify yourself, where you live, what you do, and=
why this proposed rule is unacceptable. Be as specific as possible.=0D=
=0DCome to the USDA Meeting on the Organic Standards=0DFebruary 26 - Rain=
ier Room at the Seattle Center, =0D305 Harrison Street, from 9 a.m. to 4 =
p.m. =0DWe need to fill the room. =0DPeople are invited to comment and th=
eir comments will become part of the public record. Please attend and sub=
mit written and oral comments. Comments are limited to 5 minutes per pers=
on. To sign up, call Karen Thomas at (202) 720-3252. Soon!=0DWRITE or E-m=
ail:=0DThe USDA proposed rule can be viewed through the internet NOP hom=
epage at http://www.ams.usda.gov/nop or a copy can be purchased for $8.00=
from the federal Register by calling =0D(202) 512-1800. Comments must be=
received by April 30, 1998, and can be mailed, faxed, or e=10mailed to:=
=0DEileen Stommes, Deputy Administrator =0DUSDA=10AMS=10TM=D1NOP =0DRoom =
4007=10S, Ag stop 0275 =0DP.O. Box 96456, Washington DC 20090-6456 =0Dhtt=
p://www ams.usda.gov/nop Fax: (202) 690=104632=0D=0DComments should =
include docket number TMD=1094-00=102. It is also helpful to include the =
specific information including the Comment Topic Heading and Federal Regi=
ster page no. (ex. 62 FR 65801). These are provided with the issues.=0D=
=0D=0DThe top threats to the Organic Industry as set forth in the Propose=
d Rule.=0D=0D1. The Rule needs to be rewritten =0D(comment topic: Genera=
l: 62 FR 65869)=0D=0DThe definition of organic as written in the proposed=
national organic standard fails to adhere to the requirements of the Org=
anic 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 Secret=
ary of Agriculture with recommendations and 2) to develop the Proposed Na=
tional List. The rule should be revised to more closely reflect the origi=
nal intent of the law.=0D=0D2. Genetically Engineered Organisms (GEO) =0D=
(comment topic General/Crops/ National List, sec. 205.2, 205.6)=0D=0DThe =
NOSB recommended prohibiting the use of GEO=D5s in organic production sys=
tems. We support this position.=0D=0D3. Food Irradiation =0D(comment topi=
c: Handling/National List Section 205.17, 62 FR 65884)=0D=0DThe NOSB reco=
mmended against the use of ionizing radiation in the handling of organic =
food. There should be no irradiation of organic foods.=0D=0D4. Sewage Slu=
dge =0D(comment topic: Crops/National List sec. 205.22, 62 FR 65892-3)=
=0D=0DSewage Sludge from municipalities may contain heavy metals, pestici=
des and other contaminants. The NOSB found sewage sludge unacceptable for=
organic food production. We support their recommendation.=0D=0D5. Weaken=
ed Livestock Section =0D(comment topic: Livestock sec. 205.14, 205.15)=0D=
=0DThe proposed rule disregards careful consideration by the NOSB that re=
quires livestock to have access to the outdoors, pasture and sunlight. Th=
e proposed rule would allow most confinement operations including caged l=
aying hens, feedlot beef and confinement hog operations. Furthermore, it =
reduces the requirement for 100% organic feeds to 80% and reduces or elim=
inates the restrictions of use of animal protein for feed and medications=
including antibiotics and parasiticides. We support the NOSB recommendat=
ions.=0D=0D6. Fees and reCOrd keeping requirements =0D(comment topic: Fee=
s sec. 205.421=10425, 62 FR 65890)=0D=0DThe NOSB recommended that the USD=
A minimize the financial impacts to small businesses. The proposed rule c=
reates a regressive flat fee structure which will cause a severe financia=
l burden on small farmers, organic food handlers and private certifying o=
rganizations. This rule could reduce the numbers of companies willing to =
offer organic foods to consumers.=0D=0D7. Loopholes and Inert ingredients=
=0D(comment topic: Crops/Handling/National List, sec 205.20, 62 FR 65890=
)=0D=0DThe proposed USDA rule eliminates the carefully crafted language a=
nd definitions governing specific materials in the National List. These c=
hanges will create loopholes that will allow inappropriate materials to b=
e included in the National List. Additionally, the USDA proposed allowin=
g Materials in EPA list 2, =D2Suspected Toxic Inerts.=D3 The NOSB recomm=
ended that these inert ingredients be prohibited from organic product for=
mulations They do not belong in the organic program.=0D=0D8. USDA would p=
rohibit eco-labeling =0D(comment topic: Labeling, sec 205.103)=0D=0DIt wa=
s the intention of the NOSB to allow specific production claims that rein=
force knowledge of production practices to the consuming public. As prop=
osed the USDA would eliminate any labeling not in accord with the rule. =
This would eliminate the ability of consumers to choose those practices i=
mportant to them, such as humanely raised livestock.=0D=0D9. Vague unenfo=
rceable language =0D(comment topic: General/Crop Production, sec. 205.3, =
205.7(a,b,c,) )=0D=0DThe proposal states that growers must use production=
materials according to an order of preference but does not define what t=
hat means. The proposal states that materials must be used in a manner th=
at does not significantly contribute to environmental degradation but the=
n 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 wa=
y to monitor the farm practices over time.=0D=0D=0DIn closing, we all hav=
e seen the phenomenal growth, in both quantity and diversity of organic f=
ood over the last few years. The integrity that now exists in organic agr=
iculture has evolved in a twenty year process from our farms to the priva=
te and state certification organizations. If now is the time for a Nation=
al Program, it has to be one that reflects the standards and integrity th=
at now exist, not one that blurs the lines between conventional and organ=
ic agriculture. We need a strong vocal response before the proposed progr=
am becomes a reality=0D=0D=0DThe time to comment is now=D1 =0Dthe time to=
act is now!!=0D=0D=0DFor more information, please contact :=0D =0DThe Or=
ganic Trade Association (OTA) (413) 774-5484 or visit their website at ww=
w.ota.com;=0DWashington State Department of Agriculture (WSDA), Miles McE=
voy (360) 902=101877;=0DWashington Tilth Producers 800-731-1143;=0DWashi=
ngton Sustainable Agriculture Working Group (WA=10SAWG) =0D=09John Faucet=
t- Long (206) 935=108738.=0D
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>From [EMAIL PROTECTED] Wed Feb 25 22:32:43 1998
From: [EMAIL PROTECTED]
Date: Thu, 26 Feb 98 16:06:00 +0930
To: <[EMAIL PROTECTED]>
Subject: GED Workshop
GENDER/ENVIRONMENT/DEVELOPMENT WORKSHOP
When:
14-15 April 1998
Where:
Mawson Graduate Centre for Environmental Studies
University of Adelaide
South Australia
Cost:
Registration: $10.00 student/unwaged, $20.00 waged
Proceedings: yet to be costed.
Sponsors:
Mawson Graduate Centre for Environmental Studies
Department of Social Inquiry (Women's Studies)
University of Adelaide
Centre for Development Studies
Flinders University
Further Information/Abstracts/Registration:
Dr Glenda Mather ([EMAIL PROTECTED])
Department of Social Inquiry
OR
Dr Sandra Taylor ([EMAIL PROTECTED])
Mawson Graduate Centre for Environmental Studies
University of Adelaide
Adelaide 5005
South Australia
Purpose:
A two-day workshop to explore the connections between gender,
environment and development that have motivated grassroots
political movements and local/national/international policy
perspectives. Postgraduate student presenters are particularly
welcome.
Abstacts:
250 words to Glenda or Sandra by mid-March.
