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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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