Proposed rules on organic farming raise hackles, and questions; should foods altered by genetic engineering, undefined toxic ingredients, sewage sludge, irradiation and antibiotics be considered "organic"?

Late Bulletin: At press time the news arrived that the government has backtracked or its proposal after receiving more than 200,000 letters of protest. Irradiation, genetic engineering and sewage sludge will not be allowed on products labelled organic.

Should foods altered by genetic engineering, undefined toxic ingredients, sewage sludge, irradiation and antibiotics be considered "organic"?

The US Department of Agriculture's proposed rule which would govern the National Organic Program has been met with a storm of protest by groups and individuals from the organic farming, marketing, and certification communities, as well as from consumer and environmental organizations.

The proposal grew out of the 1990 federal Organic Foods Production Act, intended to establish a national definition of "organic" for farmers and food processors. Currently, many states and a number of private certification organizations have their own rules governing inputs and practices that can be called "organic." The organic industry hoped that setting a national standard would create a level playing field for farmers and food processors, help build consumer confidence in the organic label, and increase opportunities for both interstate and international commerce.

As proposed, the USDA's rule would do just the opposite. After a seven-year effort by members of the National Organic Standards Board (a decision-making body established as part of the National Organic Program to come up with a set of practices acceptable to the organic community, the USDA has chosen to ignore many of the Board's recommendations in proposing national organic standards.

The proposed rule opens the door to use of genetically engineered organisms, food irradiation, undefined toxic "inert" ingredients, sewage sludge, and other materials currently prohibited by organic certifiers in California and elsewhere. Conditions under which livestock could be called "organically raised" arc also questionable, allowing for confinement with no access to the outdoors, up to 20% non-organic feed, and antibiotic treatments.

These possibilities alone are enough to dilute the existing definition of organic and damage consumer in the industry. In a recent press release, Sierra Club Executive Director Carl Pope said, "If USDA's proposed rules are adopted as written, consumers will lose all faith in the `organic' label, and a $3.5 billion industry in organic products will be threatened."

The International Federation of Organic Agriculture Movements has also responded, noting that the possibility of genetically engineered organisms and the proposed prohibition of private certification based on standards higher than or in addition to federal requirements will "drive a wedge through the heart of the US organic movement and effectively destroy the hard-won consumer confidence in organics--presumably the reason for a law in the first place."

As written, the proposed standards would not be acceptable to many foreign governments and private certification groups, negating efforts to expand overseas markets for US products.

In addition, the proposed rule ignores the authority granted to the National Organic Standards Board (NOSB) by Congress, shifting decision-making over materials which could be used in organic production to the USDA. This means that even if a list of inputs acceptable to the organic community were established, the USDA would be in a position to alter the materials standards without NOSB intervention.

Missing the bigger picture

Also disturbing is the USDA's reductionist approach toward organic production. Nowhere in the rule is the bigger picture of agroecosystem health and biodiversity addressed. These issues have been central to the efforts of the Center for Agroecology & Sustainable Food Systems (the Center) and a priority for existing certification groups.

For example, California Certified Organic Farmers (the state's oldest organic certification group) defines organic agriculture as "an ecological production management system that promotes and enhances biodiversity, biological cycles and soil biological activity. It is based on minimal use of off-farm inputs and management practices that restore, maintain, and enhance ecological harmony."

The proposed rule's failure to include language that speaks to agroecosystem health is one of the red flags noted by Center entomologist Sean Swezey. "The USDA can't get away from the idea that organic products are just commodities," says Swezey, who also acts as a technical representative and member of the l California Organic Foods Advisory Board. "The Center's research has continually emphasized that organic farming is a process that needs to be verified in the marketplace. It's not merely a final product with a list of approved inputs; the performance of organic farming is as identifiable as a trademark, and should be. The USDA needs to be informed that organic farming has always wanted performance and process to be revealed in the label."

Swezey explains that private certifiers such as CCOF look not only at what goes into an organic product in terms of inputs, but also at how farmers manage their land. For example. CCOF requires a grower's farming plans to include cover cropping, crop rotation, composting and other practices which protect and enhance natural resources. Says Swezey, "The proposed rule seems to negate the idea of materials and performance standards being rigorously reviewed in the certificate on process. They seem to want to evade high standards with very vague language."

Center member Thomas Wittman, a long-time organic farmer, believes that rather than tax farmers for the right to call their product organic--as the proposed rule would do--the government should be supporting organic growers for their efforts to protect the environment. "We're already doing what the government is trying to get conventional growers to do, especially in terms of limiting soil erosion and using cover crops," he says.

Adds Swezey, "The consumer has a certain picture in mind when they buy an organic commodity that includes the way the farmer is farming. The rule in many ways will obscure I that picture and make it difficult to hold organic farming to accepted and well-known performance standards."

Swezey believes the California law that now governs organic certification in the state should be the model for any national program. "A number of the Center's staff and farming clients have been involved in crafting a very effective law, one that holds growers to higher standards than the proposed rule. Adopting the federal rule as written would mean diminishing or losing 15 to 20 years of effort in California," he says.

Rule prompts action

Wittman notes one positive result of the USDA's efforts. "The proposed rule has galvanized the organic industry into one very strong lobby, which has never happened before. We're I looking at a big environmental movement in the making."

Public interest in the rule is already evident. In the first 10 weeks of the comment period, the USDA received more than 12,000 letters to its web site <www.ams.usda.gov/nop> and extended the comment period an extra 30 days (to April 30).

Swezey also sees a silver lining to the controversy over the proposed rule, viewing it as an opportunity to influence existing attitudes toward organic production. "The rule represents a very interesting emergence of the disharmony between national agricultural policy and the organic industry," he says. "We need to strive to educate the USDA and political decision-makers as to the uniqueness of both the process and the product in organic commodities."

Nutrient content of some fertilizer materials (%)

Material                    Approx. NPK        Mg      Ca      S

Activated Sludge              (6-2-0)          1.8     0.9     0.4
Basic slag                    (0-5-0)          3.4    32.0     0.2
Blood meal                    (13-0-0)         0.4    trace   trace
Bonemeal, steamed             (2-11-0)         0.3    24.1     0.2
Gypsum                        (0-0-0)         trace   22.4    18.6
Limestone, dolomitic          (0-0-0)         12.0    21.0     --
Limestone, pure               (0-0-0)         trace   40.0    trace
Manure([dagger]), beef        (0.7-0.5-0.6)    0.1     0.1     0.1
Manure([dagger]), dairy       (0.5-0.3-0.5)    0.1     0.2     0.1
Manure([dagger]), pig         (0.5-0.3-0.5)    0.1     0.6     0.1
Manure([dagger]), poultry     (1.3-1.3-0.6)    0.3     1.8     0.2
Manure([dagger]), sheep &
  goat                        (1.4-0.5-1.2)    0.2     0.6     0.1
Monoammonium
 phosphate                    (12-50-0)        0.3     1.4     2.6
Peat                          (3-0-0)          0.3     0.7     1.0
Phosphate rock                (0-6-0)          0.1    33.1    trace
Potassium sulphate            (0-0-50)        trace   trace   18.0
Sulphate of potash
 magnesia                     (0-0-22)        11.0    trace   22.0
Tankage                       (7-10-0)         0.3    10.9     0.4
Wood ash                      (0-2-5)          0.2    14.0    trace

([dagger]) fresh manure, as it comes from the animal: urine, feces, but no bedding.