Interdisciplinary Minor in Global Sustainability
Senior Seminar (Instructor: Peter A. Bowler)
University of California, Irvine, March 1998


The USDA’s Standards for Organic Food

By Dore Burry

In 1990 the Organic Foods Production Act was passed. Since then, the USDA has been working feverishly to make federal approved standards of "organic" food. These standards will replace the many different organic certification programs presently used throughout the country. It will replace them with across-the-board requirements for raising, producing, manufacturing, and labeling organic products.

In December 1997, the USDA announced their long awaited standards proposal, the Federal Standards for Organic Food Production and Processing. Working with the USDA to make suggestions for the proposal was the National Organic Standards Board (NOSB). This board is composed of crop and livestock farmers, organic food processors, retailers, scientists, environmentalists, and consumer representatives. The NOSB is not part of the USDA and therefore was only able to make suggestions for the standards – not write them. The NOSB, as you will see below, made many suggestions to the USDA that were not followed. The NOSB’s suggestions were aimed at making the quality of organic foods the same as available today or better.

This proposal is making a federal standard of quality for organic food, which will hopefully improve or maintain its quality. However, one should be wary. The USDA is making this an all-encompassing federal standard, so there will be no other organic certification besides what it deems "organic." We must make sure that the USDA’s consideration of what is labeled organic is really what we want it to be. We must not allow strong private interest groups to do the speaking for us.

This issue really boils down to what you consider organic. I have chosen to highlight five portions of the proposal that was submitted by the USDA (it is available at www.ams.usda.gov/nop/pream.htm) to bring attention to some very questionable practices that will be used in production of organic foods.

1) (From Proposal)

Livestock health care - Section 205.14.

After careful consideration of the information available, we propose to restrict the use of animal drugs in animals intended as organic slaughter stock. We propose in sections 205.14(b)(1) and (2) that animal drugs could be administered to mammals intended as slaughter stock during the first 21 days of life, and to all other slaughter stock during the first 7 days after arrival at the certified facility. Animal drugs administered topically and parasiticides could be administered at any time of life.
 

This is not a good thing for those of us who want antibiotic-free meat. It states above that "animal drugs could be administered to mammals…during the first 21 days of life." Antibiotic-free meat will no longer be available. I personally want as few additives, drugs, etc., as possible in my meat. Current practices in organic meat operations do not use any antibiotics, hormones, or steroids. This portion of the proposal is not bettering the quality of "organic" meat – as it should – it is worsening it.

2) (From Proposal)

Use of terms or statements that directly or indirectly imply that a product is organically produced and handled - Section 205.103.

We propose in this section that labels, labeling or market information that directly or indirectly imply organic production and handling practices may be provided for or affixed only on agricultural products produced and handled in accordance with the Act and the regulations in this part. Our proposed regulations would authorize the use on a label, labeling, or market information of the term organic and other terms and phrases that directly or indirectly imply that the product was organically produced and handled.

Therefore, under our proposal, any terms or phrases that directly or indirectly imply that a product has been organically produced or handled would be prohibited from being used on the label, labeling, or market information of products that are not produced in accordance with the Act and the regulations in this part.

Examples of terms or phrases which we consider may imply directly or indirectly that a product is organically produced and handled include: "produced without synthetic pesticides"; "produced without synthetic fertilizers"; "raised without synthetic chemicals"; "pesticide-free farm"; "no drugs or growth hormones used"; "raised without antibiotics"; "raised without hormones"; "no growth stimulants administered"; "ecologically produced"; "sustainably harvested"; and "humanely raised".
 

This means that the USDA has the sole right to label anything organic- and there will be no more "organic meat." No meat may be stamped "raised without antibiotics" because that would imply it was raised in an organic fashion but not in accordance with the Act. The USDA does not label organic meat "raised without antibiotics" (because it would be a lie) and it is prohibiting anyone to sell meat under that description. This gag clause is a hindrance to our right to know privileges and removes all antibiotic-free meat from the market. We cannot allow this.

3) (From Proposal)

Livestock living conditions and manure management - Section 205.15.

We propose in section 205.15(b) that, if necessary, animals could be maintained under conditions that restrict the available space for movement or access to outdoors, provided that other living conditions are adequate to maintain the animals' health without the use of animal drugs, except as provided in 205.14(b). The flexibility provided by the provisions of 205.15(b) would allow operations without facilities for outdoor access to be certified for organic livestock production.
 

This is not good news to those of us who want cage free eggs and range free meat. This is a ploy to allow factory farms to stamp their cows "organic." The wording gives it away – "the flexibility provided…would allow operations without facilities for outdoor access to be certified for organic livestock production." This means that cows in stalls the same size of the ones in public restrooms can receive "organic" certification. Again, the quality of "organic" foods is watered down.

Okay, so organic meat is now limited to animals on drugs while living in bathroom stalls, it can’t get much worse, right?

4) (From Proposal)

The National List of active synthetic substances allowed for use in organic crop production -Section 205.22.

NOSB recommended that biosolids, or municipal sludge, should be classified as synthetic and were not appropriate for use in organic crop production. The EPA defines biosolids as the primarily organic residuals, produced by current wastewater treatment processes that treat domestic sewage. We are requesting comments to assess the extent to which biosolids maybe used in organic production. The USDA specifically invites comments on whether the use of biosolids (municipal sludge) should be permitted or prohibited in organic production.

The USDA has approved the use of biosolids (sewage) for agricultural fertilizer and it is being used on some crops. However, no organic certification system in existence allows municipal sludge to be used on organic crops. This is another section aimed at weakening the present organic food quality. These practices sound like conventional growing, not organic.

The use of ionizing radiation has recently been approved by the FDA on red meat products. Ionizing radiation exposes food to 300,000 rads of gamma radiation – the equivalent of 30 million chest x-rays – and is not allowed by any existing organic certification program, yet the USDA states in the following that they are considering it for use in organic products.

5) (From Proposal)

Processing practices - Section 205.17.

The NOSB has recommended to the Secretary that the practice of ionizing radiation should not be allowed in organic handling, and its use is prohibited by most existing organic certification programs which we have reviewed. Public comment is invited with respect to the compatibility of the use of ionizing radiation with a system of organic farming and handling.
 

For those who care about maintaining a high quality of organic foods, these highlighted sections should be a clarion call. The USDA has extended its public comment period to April 30th 1998. Lets help better define "organic."

For those who agree that the above five portions of the proposal are good enough for the USDA’s standards of organic food, the letter below only needs to be signed and mailed.
___________________________________________________________

Eileen S. Stommes
Deputy Administrator
USDA-AMS-TM-NOP
Room 4007 – So.
Ag. Stop 0275
P.O. Box 96456
Washington, D.C. 20090-6456

Dear Mrs. Stommes,

I am writing this letter in response to tell you what I think of the USDA’s federal standards for organic food production and processing (Docket # TMD-94-00-2). There are at least five sections in which I think the USDA needs to rewrite before it is an acceptable standards proposal. They are as follows:

Livestock health care - Section 205.14

There should be no allowable antibiotic use in organic meat. The NOSB’s recommendation of prohibiting the use of antibiotics in the production of organic slaughter stock is an acceptable revision to the USDA proposal.

Use of terms or statements that directly or indirectly imply that a product is organically produced and handled - Section 205.103

This section should not exist. The USDA should make their endorsements upon organic food very noticeable so that consumers can readily locate the USDA endorsed products on a shelf. There should not be any type of prohibition against a healthy product being labeled, "raised without antibiotics." The USDA might allow antibiotics to be used in organic slaughter animals – so disallowing a "raised without antibiotics" label would not be fair to meat products that are raised without antibiotics.

Livestock living conditions and manure management - Section 205.15

The USDA’s decision to allow restricted space captivity is unacceptable for "organic" slaughter animals. There should be no flexibility that would allow operations without facilities for outdoor access to be certified for organic livestock production.

The National List of active synthetic substances allowed for use in organic crop production -Section 205.22

The NOSB recommended that biosolids, or municipal sludge, should be classified as synthetic and were not appropriate for use in organic crop production. I agree with this recommendation. The use of municipal sludge was never approved by organic certification programs in the past and there should be no use of sludge in organic crop production in the future.

Processing practices - Section 205.17

There should be no ionizing radiation in organic handling. Again, I agree with the NOSB’s recommendation.
 

I feel that the above five portions of the USDA’s proposal are unacceptable and I hope my comments during this public comment period are registered. I think that the NOSB offers good suggestions to keep the level of quality of organic foods at an acceptable level and I feel that the USDA’s proposal lessens the quality of organic products in many respects. The USDA, in this proposal, is allowing some practices that conventional foods undergo when this is not a proposal for standards of conventional foods. Organic foods should be the highest quality foods available to the consumer and the methods that produce them must be meticulously scrutinized. Thanks for your time.
 

Sincerely,