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Mississippi Market's position on
the National Organic Program Proposed Rule
April 28, 1998
Eileen S. Stommes
Deputy Administrator
USDA-AMS-TM-NOP
Room 4007-S
Ag Stop 0275
PO 96456
Washington DC 20090-6456
Re: Docket # TMD-94-00-2
Dear Ms. Stommes,
Mississippi Market Cooperative and Delicatessen has
been a leader in the promotion and sales of organic and
natural foods in the Twin Cities area for over 19
years. The majority of our member-owners initially
sought us out because we could offer them an
alternative from the conventional grocers in the area;
our product line emphasizes organic and unrefined
foods. Today, our member-owners exceed 2900 and our
sales are over $4.5 million per year. We are currently
in the process of building a second location which we
expect to be open by the end of the year.
Mississippi Market has spent two decades building
partnerships between organic farmers and consumers, and
is concerned that the National Organic Program Proposed
Rule (NOPPR) will seriously undermine the trust of this
partnership. We (the member-owners and staff)
respectfully summit the following comments regarding
the Proposed Rule.
Subpart A, Section 205.2, Terms defined:
Organic:
We recommend that the USDA follow the proposed draft
guidelines for the production, processing, labeling and
marketing of organically produced foods. Define organic
agriculture as "a holistic production and marketing
system that promotes and enhances the agroecological
health, including biodiversity, biological cycles, and
soil biological activity. It emphasizes the use of
management practices in preference to the use of
off-farm inputs. This is accomplished by using
cultural, biological and mechanical methods, as opposed
to using synthetic materials to fulfill and specific
functions within the system." This is consistent with
the recommendation of the National Organic Standards
Board (NOSB) and reflects the belief we have always
held that organic farming is not just an end product
but a philosophy of farming that emphasizes land
stewardship as the primary goal.
Subpart B; Section 205.20-205.28, The National
List:
We insist that the USDA uphold the legal authority of
the NOSB as stipulated in the OFPA, by prohibiting the
Secretary of Agriculture from adding exemptions for the
use of specific synthetic substances to the Proposed
National List submitted by the NOSB. The changes to the
list as proposed by the NOPPR violates both the law and
the public/private partnership that supported the
passage of the OFPA.
Subpart B, Section 205.5, Land Usage:
We believe that the complete history of land should be
taken under consideration prior to granting
certification. Under the proposed rule, only the past
three years use of land would be considered.
Subpart B, Section 205.7 (d), The use of biosolids
in the proposed organic rule:
The USDA asks specifically if biosolids should be
permitted or prohibited in a system of organic
production. We feel that the use of biosolids is not
consistent with the philosophy of organic farming. The
heavy metals and other toxins do not break down in the
composting process and therefore should be considered
synthetic inputs. Biosolids should be strictly
prohibited in any organic farming system.
Subpart B, Section 205.13, Livestock Feed: under (b)
prohibited, add (3) (I) to read as follows:
the feeding of any animal parts back to livestock is
strictly prohibited. Livestock feed consisting of
rendered animal protein (animal by products) is not in
line with organic farming philosophy. This practice
must be prohibited if organic meats from ruminants are
to be protected from bovine spongiform encephalopathy.
Livestock that is certified organic should = only be
fed 100% organic feed.
Subpart B: Section 205.14, Livestock Health
Care:
We support a prohibition of synthetic antibiotics,
paraciticides, medications, and growth hormones in the
production of livestock. Under ( c) if antibiotics
should be necessary to save the life of the animal,
then after successful treatment, it should be culled
from the rest of the livestock and sold on the
conventional market.
Subpart B: Section 205.15, Livestock Living
Conditions:
Livestock that is certified organic must have access
to fresh air and the outdoors. Facilities that cannot
provide outdoor access should not be allowed to be
certified organic.
Subpart B, 205.17 (b), The use of ionized radiation
in the proposed organic rule:
Ionizing radiation (irradiation, cold pasteurization)
is a synthetic input and is not compatible with any
organic farming practices. We question the safety of
the process, the impact on our health and the disposal
of waste after the irradiation process. Therefore we
request that ionizing radiation be strictly prohibited
in the final organic rule.
Subpart B, section 205.22 (d), The use of
Genetically Engineered Organisms in the proposed
rule:
Genetically engineered organisms (GEOs) are synthetic
life forms because they have been genetically modified
by inserting foreign genes from unrelated organisms
into the existing genetic sequence of plant or animal
cells. They cannot occur in a natural environment or in
natural reproductive systems. We will not knowingly
purchase products containing "chymosin" and "toxins,
derived from genetically engineered bacteria." Our
member-owners prefer to buy milk that has been produced
without the use of Recombinant Bovine Somoatotropin
(rBST). We request that GEOs be strictly prohibited
under the organic rule. This request is in line with
the recommendation made by the NOSB in regards to
GEOs.
Subpart C, Section 205.103 and Section 205.301,
Labeling:
We support the use of "eco-labeling". Farmers have the
right to label their products in terms of how that
product was produced, even if it is not in accordance
with USDA organic standards. Consumers also have the
right to know if the foods meet their personal criteria
for purchase consideration. (Labels such as
"biodynamic" which provide valuable information to our
customers and members, would be excluded under such a
proposal.) We also believe that certifiers be allowed
to certify for standards higher than the minimum
standards established by the USDA.
Subpart D, 205.202, Exemptions and exclusions for
certification:
Point (a)(2) reads: "A retail operation, or portion of
a retail operation, that only handles organically
produced agricultural products but does not process
them is exempt from the requirements in this part."
It is easy for a retailer to inadvertently mislabel
or mishandle organic product. To protect the integrity
of the organic product, all retail establishments
should be certified. Clear guidelines and retail
training materials should be provided to all handling
retailers to insure consistent standards.
Subpart D: Section 205.205, add section (f): retail
handling plan.
The following information shall be submitted
concerning a retail operation in their organic handling
plan.
- A brief general description of the type of
handling operation and the processing, manufacturing,
and other handling procedures that is intended to be
used.
- A list of structural pest management methods used
or intended to be used.
- The measures that will be used to prevent
co-mingling of organic and non-organic products.
Procedures outlined that will verify that an organic
product in question is certified by an accredited
certification organization. Procedures to provide
certification documents if each organic product in
question.
- Explanation to employees of goals of the
retailer's organic handling program to be included in
the retailer's formal employee training
procedures.
-
A retailer who processes or manufactures an organic
product must include:
- The recipe detailing organic and non-organic
product showing compliance with NOP's labeling
requirement
- The source of water use in the ingredient
list.
- Raw product amounts used in the ingredient
list (if applicable).
- Type of packaging materials used to protect
organic integrity.
Subpart E , Section 205.421-205.424, Fees for
Accreditation:
We recommend that the fee system for organic
accreditation be changed to one that is based on a
sliding fee scale so certification fees do not place an
undue burden on small organic farmers and producers.
Organic farming should support family farms, small
businesses, and local and regional agricultural
systems.
In conclusion: The members-owners and staff of
Mississippi Market want a clear choice from
conventional farming practices. We urge the USDA to
develop a national organic program based on
precautionary principles, not risk assessment. If
Secretary Glickman believes that the National Organic
Program should offer "consumers freedom of choice",
then he must agree that consumers have already voiced
that they want stricter organic standards We do not
feel that the NOPPR reflects the intent of the OFPA
when it was passed in 1990, nor does it require the
same high standards enforced by current certification
bodies, both state and private. We respectfully ask
that the USDA withdraw, rewrite and resubmit the NOPPR
for another public comment period.
Yours in Cooperation,
The Member-Owners and Staff Mississippi Market
Cooperative, Inc.
cc: President Bill Clinton
Vice President Al Gore
Senator Paul Wellstone
Senator Rod Grams
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