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(Following is the complete text of a letter circulated
in November 2005. Because it is such a
faithful---and authoritative---presentation of both
USDA and OTA attitudes, I welcome the chance to
answer its many points and assumptions.
Basically, Gershuny seeks to re-direct the debate
which ended with the passage of the Organic
Foods Production Act in 1990.---A.H.)
in November 2005. Because it is such a
faithful---and authoritative---presentation of both
USDA and OTA attitudes, I welcome the chance to
answer its many points and assumptions.
Basically, Gershuny seeks to re-direct the debate
which ended with the passage of the Organic
Foods Production Act in 1990.---A.H.)
HARVEY AND THE SOUL OF ORGANIC
By Grace Gershuny
There have recently been a lot of accusations and “action alerts” flying around the
internet and print media that raise the specter of corporate agribusiness conspiring to
“weaken” or “dilute” organic standards. Calling it a “sneak attack,” the Organic
Consumers Association (OCA) and others rallied the grass roots to oppose a legislative
change to the Organic Foods Production Act (the law that authorized the Federal organic
regulations) that was initiated by the Organic Trade Association (OTA). The amendment
was passed by Congress on October 27th, along with a directive to USDA to study the
organic industry and report back in 90 days.
OCA and others accuse OTA of having been “taken over” by agribusinesses like Dean
Foods and WalMart, who, according to OCA, want to undermine the strict organic
standards reached through a democratic process in order “get organic cheap.” These
accusations are not only based on distortions of truth, but they work against the interests
of organic farmers, consumers and everyone else involved.
The controversy has left a bitter rift in the organic community, a rift which threatens to
unravel years of consensus-building that contributed to USDA publishing an organic
regulation that almost everyone could live with at the end of 1999. This is my effort to
clarify some of the confusion generated by the accusations and misinformation, and to
urge folks who support the bigger organic vision to avoid undermining that vision. I have
been a passionate advocate and practitioner of organic agriculture for over thirty years. I
developed NOFA’s (Northeast Organic Farming Association) first organic certification
program in 1977, and have organized, written, taught, and consulted around agriculture
and food system issues since then, as well as keeping my hands in the soil. I was also a
founding member of OTA, served on the National Organic Program (NOP) staff for five
years, and currently consult for the organic industry, including OTA, on regulatory issues.
What was all the fuss about?
The current scenario begins with a lawsuit filed three years ago by Arthur Harvey, an
organic blueberry grower from Maine. Harvey challenged several provisions of the
National Organic Program (NOP) regulations as being inconsistent with the law. Although
he lost on all counts, in 2004 his appeal was joined by twelve “amici,” primarily consumer
and environmental groups; in January of 2005 the First Circuit Court of Appeals found in
Harvey’s favor on three counts. OTA’s amendment was intended to change only the
language in the law that the court said invalidated the current organic regulations.
If let stand, the Harvey ruling would have blocked the use of “allowed synthetics” in or on
organic processed products, including substances like baking powder, one form of pectin,
ascorbic acid, and carbon dioxide. By some estimates, this would remove the organic label
from up to 90% of current organic processed products (which accounted for 58% of all
organic products sold at retail in 2004, according to OTA’s Manufacturers Survey).
Beyond multi-ingredient products such as baked goods and frozen foods, this change
would also have affected single ingredient products such as sugar, which uses calcium
hydroxide as a processing aid, bananas, which are ripened with ethylene gas, and many
whole grains, which are treated with carbon dioxide as a fumigant. Because these key
ingredients could not be counted as part of a product’s organic content, additional
products would have lost their organic status in a domino effect. This is the primary
correction that OTA’s amendment made, and there will now be no need to change the
rules for processed organic products.
The second outcome of the Harvey ruling invalidated the rules relied upon by small dairy
farms transitioning to organic management, which allowed cows to receive up to 20% non-
organic feed until three months prior to selling their milk as organic. OTA’s amendment,
which inserted language that allows transitioning dairy herds to consume farm grown feed
from land that is in its third year of transition to organic, has generally been supported.
The third Harvey ruling disallowed the procedure by which any non-organic agricultural
ingredient may be used in up to 5% of an organic processed product if an organic
equivalent is verified to be commercially unavailable. Instead, it stipulated that any non-
organic agricultural product must be individually reviewed by the National Organic
Standards Board (NOSB) and included on the National List before it can be used-a process
that can take a year or longer. OTA’s amendment did not eliminate this problem, but it did
include a provision allowing for a temporary emergency exemption for specific products to
be issued by the USDA. The exemption would still have to be published in the Federal
Register for public comment before it could take effect, and be approved at the next
meeting of the NOSB. This exemption could apply to products that may become
unavailable in organic form due to natural disasters, crop failures, or other unforeseen
factors.
A recent legal analysis by the Congressional Research Service confirms that the
amendment’s effect was limited to reversing part of the Harvey ruling, without otherwise
changing the law. There had long been discussion about making these and other technical
corrections to the law, and there was some agreement among the various stakeholders
that this would be supported in the next Farm Bill. Hardly a “sneak attack.”
For the sake of this discussion, I will refer to those who opposed OTA’s legislative
amendment as the “amici.”
Regulatory Fixes and Industry Impact
There is a lot in the OFPA that is both unclear and ambiguous, and the process of trying to
write regulations that were consistent with it taught me how frustratingly contradictory it
is. The new amendment removes at least one of the contradictions, and the new language
ratifies the existing regulations that allow the use of a limited number of approved
synthetic substances in up to 5% of organically labeled products. While some continue to
insist that this allowance is inappropriate, all organic standards in the world, including the
European Union, Canada, and Codex Alimentarius, include allowances for similar lists of
synthetic ingredients in organic processed products.
One accusation made is that the amendment would allow hundreds of synthetic
substances, known to the cognoscenti as “food contact substances,” to be used in organic
processing without review by the National Organic Standards Board (NOSB), the citizen
advisory panel authorized by the law. Substances such as sanitizers and boiler chemicals
are not currently required to be reviewed by the NOSB and included on the National List,
and this amendment does not change this. Concerns about residues of these things getting
into organic products can readily be addressed by a regulatory revision. Most certifiers
currently interpret the rules requiring protection of organic integrity by insisting that
processors protect products from sanitizer and boiler chemical residues on equipment
surfaces. A regulatory approach could also make certain categories of these substances
off-limits for organic handlers, based on NOSB recommendations-having the NOSB spend
its time reviewing each of these materials, which are already scrutinized by FDA, would be
pointless.
The charge has been made that the amendment takes authority away from the NOSB.
This accusation refers mainly to the emergency exemption provision discussed above.
Since the NOSB does not make these decisions now, this charge is groundless. Moreover,
the new requirement that each agricultural product must be individually listed will create a
huge problem that will tie up the NOSB in examining hundreds or thousands of petitions for
agricultural products, none of which should really be concerns for the National List.
The amici argued that the industry could adjust to the Harvey ruling through revising the
regulations, without having to change the law. It wouldn’t be so bad, they said, for
affected products to just use a “made with organic ingredients” label. However, many
farmer advocates (especially in the Northeast, where we don’t sell a lot of ingredients to
processors) don’t seem to realize that the “made with” label, beyond being less appealing
to consumers, also allows almost any non-organic agricultural ingredients, commercially
available in organic form or not, to be used in up to 30% of the product composition. It
also allows some other unpleasant things like sulfites, nitrates, and unapproved processing
aids to be used in producing the non-organic portion.
This translates into a diminished market for a bunch of those organic minor ingredients-
why buy expensive organic blueberries for that “made with” pancake mix if you don’t have
to? And they have also not considered those single ingredient products--can you imagine a
“made with organic bananas” label on the box? Big processors such as Stonyfield Farm
said that they would stop making organic products at all if the only option was the “made
with” label, which consumers don’t recognize and won’t pay higher prices for, thus
eliminating a major market for organic dairy. It’s also interesting to note that, when the
regulations were being developed, many consumer groups opposed the provision for a
“made with organic” label as misleading.
The democratic process
As a member of the organic committee of the National Campaign for Sustainable
Agriculture (representing Rural Vermont, on whose Board I serve), I have never been
informed or asked for my input about decisions concerning their response to Harvey. I
bring this up to suggest that those criticizing OTA’s strategy as undemocratic might do well
to avoid throwing stones. In various discussions with Campaign members and others, I
heard repeatedly that they opposed amending the law at all, since it could open the door
for various undesirable changes by agribusiness types. They then came out with their own
legislative proposal, which included major new issues that haven’t been publicly discussed.
Although negotiations between OTA and the amici broke down over this issue, OTA’s
intent to pursue a legislative strategy was never a secret.
The ironic thing about this is that, in contrast to groups such as OCA, OTA is a
democratically controlled, member directed organization. It has about 1600 members,
representing the whole spectrum of organic producers, processors, distributors, retailers,
suppliers, consultants (including yours truly) and certifiers. Everyone’s vote, regardless of
scale, counts equally. OTA’s Board (which includes representatives of various organic
sectors, none of whom are Dean Foods or WalMart) unanimously approved a plan to
quickly enact the needed technical corrections to avoid severely disrupting the industry.
More information about OTA and its activities is available at www.ota.com.
It is also worth noting that the strategy of changing the rules (which were extensively
publicly vetted) through a lawsuit is a decidedly undemocratic approach. While groups
such as OCA vociferously lobbied Congress to oppose the legislative amendment, no such
public input is possible in influencing a court decision.
What consumers want and what consumers don’t know
One of the most frustrating things for me is the sense that the whole meaning of organic
has become a hostage to consumer ignorance. Much of the blame for this rests squarely
with the organic industry and its imperative to market products as “pure, natural and
safe.” It is no wonder that, according to a Consumers Union poll, most consumers think
that organic products contain no “artificial ingredients.”
If someone is ignorant about what you do, does it make sense to work on educating them,
or should you change what you do to fit their beliefs? This is the crux of the debate that
was raging in the organic community when the OFPA was being drafted. As I argued then,
and believe now more strongly than ever, the distinction between “synthetic” (bad) and
“natural” (good) is the wrong place to hang the whole definition of what is organic.
Consumers must realize at this point that not all synthetics are bad, and not all “naturals”
are good.
It should also be obvious to the organic community that the distinctions are not nearly as
straightforward as the advocates of this position argued in the eighties. Recent
deliberations by the NOSB in attempting to clarify the definition of “synthetic,” and efforts
to reclassify some substances now designated as synthetic to become non-synthetic, have
underscored this fuzziness. The compromise of allowing specific exemptions to the “no
synthetics” rule that was crafted into the OFPA does make sense. The distinction between
synthetic and non-synthetic in the realm of food additives is, however, pretty meaningless,
but that is what we are stuck with.
Much of the controversy, in my opinion, results from a combination of ignorance,
ideological blinders, unchecked assumptions, and confusion about the regulatory process.
I would like to suggest in closing that one of the biggest unchallenged assumptions holds
that making organic standards “higher” and “stricter” protects small producers and
consumers. Understandable and well meaning, but really mistaken.
Contrary to the widespread presumption that agribusiness types wish to “loosen” or
“weaken” organic standards for their own ends, in reality the increasing bureaucratization
of the organic rules benefits the bigger players, who have regulatory compliance staffs to
make sure they are meeting all the arcane requirements. Small, independent producers
then feel like organic has been “stolen” from them, as one former colleague put it, and try
to find ways to circumvent the rules. Similar issues have arisen over health and safety
rules that have put many small producers out of business. From the consumer standpoint,
most of these “stricter” organic requirements do nothing whatsoever to improve organic
integrity, product quality or environmental protection. Despite these obstacles, the organic
industry has grown exponentially over the past decade or so.
Many in the community think it’s fine to get rid of mass produced organic processed
products, and believe that big corporate players should be prevented from going organic.
They believe that everyone should just buy all their food from local producers and prepare
home-cooked meals of whole foods. This may be the ideal choice, but how many American
consumers are likely to change their lifestyles this radically? And how about products like
cotton? I recently attended an organic fiber training that drove home to me the
importance of supporting an inherently mass-production oriented industry for the sake of
removing as many acres (and farm workers) as possible from the harm caused by massive
toxic pesticides, herbicides and defoliants. It is simply not okay to limit this possibility in the
realm of food production in the name of meeting uninformed consumer expectations--at
the same time diminishing the range and quality of organic products available to ordinary
consumers.
My own vision would have organic become the predominant kind of agriculture in this
country (and of course, the whole world), and not remain an elite niche market. For the
sake of the planet, I hope that those who support the organic vision will stop erecting
more obstacles to its proliferation.
Grace Gershuny
GAIA Services
1417 Joe’s Brook Road
St. Johnsbury, VT 05819
802-633-4152
graceg@kingcon.com
Reply to Grace Gershuny, by Arthur Harvey
Grace Gershuny's article above, circulated in November, is a faithful and authoritative
presentation of both USDA and OTA beliefs. It also reveals the underlying assumptions
behind the recent actions to degrade organic standards, as well as previous actions over
the past six or eight years.
Gershuny was part of the small group within USDA who crafted the regulation which the
court found contrary, in part, to the Act of Congress---the Organic Foods Production Act
of 1990 (OFPA). Others who are still at the National Organic Program are Keith Jones and
Barbara Robinson. Richard Mathews has now been transferred to another position in
USDA. Gershuny makes several arguments:
1) That my lawsuit "lost on all counts" until it was joined by consumer and environmental
groups, after which the court of appeals ruled in my favor on three counts.
The fact is that the "friends of the court" gave moral support (not financial) to my appeal,
but had no effect on my arguments. The judges made no reference to their briefs in the
decision.
2) The effect of the court ruling would "remove the organic label from up to 90% of
current organic processed products"
This is total nonsense. First, the court order does not apply until June 2007, which gives
plenty of time for manufacturers to re-formulate with natural alternatives. No doubt most
of these would cost more than the synthetics. Gershuny does not personally claim "up to
90%", but passes along what some other unnamed person has said.
But suppose we re-phrase it to "up to 90% of organic products contain synthetic
ingredients that have no natural substitutes". I don't think that could be true, and if it
has any degree of truth, then consumers are being hoodwinked wholesale, because they
are not being told what goes into their "organic" products.
In my own line of blueberry and apple products, four out of nine are affected, which I did
not realize before the court decision. Two blueberry jams with organic sugar will
probably be re-labeled "made with organic blueberries" unless the sugar manufacturers
eliminate the synthetic processing aids. Two other products were formerly thickened with
the synthetic form of pectin, but we have switched to using organic apple pectin and pulp.
This actually costs less than the synthetic, although it requires more careful supervision of
the process. It also expands the market for organic cider producers who used to discard
their pomace. Our customers look for our brand name as much as the organic seal, so I do
not expect any loss of market share from the changes in labeling.
3) The "primary correction" made by the OTA rider is to legalize synthetic processing
materials for sugar and bananas, plus the use of carbon dioxide in grain storage.
This is a case of throwing out the baby with the bath water which is not even dirty.
Carbon dioxide is a perfectly natural part of the air we breathe. USDA lists it as synthetic
because of bureaucratic laziness. There are various natural sources for carbon dioxide
which USDA ignored in creating the National List. The better procedure here would be for
the NOSB to propose more appropriate guidelines for classifying such substances.
Bananas were ripened quite well before synthetic ethylene was available, although at a
higher cost.
I am not a food chemist, but I do know that the sugar industry is large and competitive. I
would expect them to be diligent in finding natural processing aids, especially since they
would know their competitors are doing the same.
4) The 'made with organic ingredients' label allows "almost any non-organic agricultural
ingredients, commercially available in organic form or not, to be used in up to 30% of the
product"
Gershuny might do well to read the organic regulation, at 205.105:
"To be sold or labeled as '100 per cent organic', 'organic', or 'made with organic
(specified ingredients or food group(s))', the product must be produced and handled
without the use of:
(a) Synthetic substances and ingredients, except as provided in 205.601 or 205.603;.....
(e) Excluded methods.....;
(f) Ionizing radiation......; and
(g) Sewage sludge."
If the NOP would get busy and implement this more fully, the "made with" label might
deserve more respect than it currently gets from some of the captains of industry.
5) Switching some products to the 'made with organic' label "translates into a diminished
market for a bunch of those organic minor ingredients---why buy expensive organic
blueberries for that 'made with' pancake mix if you don't have to?"
Consider the pancake mix labeled "made with organic flour" at $2 a box, competing with
annother brand labeled "made with organic flour and organic blueberries" at $2.50. Or,
Stonyfield raspberry yogurt labeled "made with organic milk" at 79 cents, next to Horizon
yogurt labeled "made with organic milk and organic raspberries" at 89 cents. I don't think
any of these brands would even try to market the cheaper label.
6) "changing the rules (which were extensively publicly vetted) through a lawsuit is a
decidedly undemocratic approach"
This one takes my breath away. Do we not live in a nation of laws, passed by the
Congress and protected by the courts against abuses by the executive? I would be the
first to agree the American system of government often fails. But does anyone seriously
propose that the OTA rider, which tries to rip the heart out of an act of Congress that
was developed through many hearings and debates in both houses, is somehow more
democratic?
7) " This is the crux of the debate that was raging in the organic community when the
OFPA was being drafted. As I argued then, and believe now more strongly than ever, the
distinction between 'synthetic' (bad) and 'natural' (good) is the wrong place to hang the
whole definition of what is organic."
But that distinction is exactly what OFPA is built upon, starting with 6504: "To be sold or
labeled as an organically produced agricultural product under this chapter, an agricultural
product shall (1) have been produced and handled without the use of synthetic chemicals,
except as otherwise provided in this chapter".....
Since Gershuny rejects the basis of OFPA, why did she work for the USDA in drafting the
rules to implement the law?
Gershuny does not offer something different on which to base organic standards. It is
easy to find shortcomings in the no-synthetics-added principle, but is there in fact a
feasible alternative?
If industry people succeed in stamping out this principle, there will be nothing to stop
industry lobbyists as they team up with USDA to convert organic standards into nothing
more than a label which takes advantage of gullible consumers. Farmers must be
scratching their heads over the fairly stringent standards they must follow, before they
give their produce to manufacturers who can add a long list of synthetic ingredients and
processing materials without the consumer's knowledge.
8) "There is a lot in the OFPA that is both unclear and ambiguous, and the process of
trying to write regulations that were consistent with it taught me how frustratingly
contradictory it is. The new amendment removes at least one of the contradictions"
The alleged contradiction in OFPA that Gershuny refers to, is exactly the one which the
court declared is NOT contradictory. USDA argued throughout the litigation that it was
contradictory.
Perhaps we can now understand the source of her frustration, because she was trying to
allow synthetics in the Rule where Congress had created a firewall against them.
Gershuny was not alone in taking that position. There have always been powerful voices,
not only among manufacturers, who argued that organic food cannot claim to be safer or
better than conventional food. They argue that organic is not about the product, but
about the process, or system of production. That wholistic system is believed to benefit
the environment. Even though OFPA contains no such doctrine, the rejection of organic
food as superior coincides with USDA's refusal to allow claims that organic food is safer for
consumers. USDA cannot very well continue to promote conventional agriculture and also
organic agriculture, unless it is for the purpose of serving a niche market of irrational
consumers who nevertheless can benefit the industry by paying higher prices. I am not
suggesting that Gershuny supports all of these notions, but it is useful to see where she
fits into the picture.
As for any other contradictions in OFPA, Gershuny is not specific. I can discuss one that
was the subject of my lawsuit. At one point, OFPA guarantees consumers access to
certification documents. At another point, it requires certifiers to protect confidentiality of
"business information". So how did USDA resolve this? By classifying all documents as
business related.
True, OFPA is ambiguous on that issue. But not true that Gershuny and the others
struggled to find a middle path---they simply did what was best for the manufacturers and
other producers.
Another of my original complaints was that USDA had failed to include in the Rule a
requirement in OFPA that wild crop lands not be treated with chemicals. This was
additional to the 3-year rule, and would mean that wild lands could not be rotated in and
out of organic production. In the course of the case, Keith Jones testified that the OFPA
requirement was omitted from the Rule because some wild rice handlers were concerned
it might limit their ability to obtain crops.
Here again, I don't see the USDA staff struggling with contradictions, but rather crafting
the regulation to suit manufacturers.
9) "One accusation made is that the amendment would allow hundreds of synthetic
substances, known to the cognoscenti as 'food contact substances', to be used in organic
processing...such as sanitizers and boiler chemicals...having the NOSB spend its time
reviewing each of these materials, which are already scrutinized by FDA, would be
pointless."
Gershuny's approach to this topic is strange. First, "food contact substances" is not a term
of "cognoscenti" (whoever they might be)---it is used by the Food and Drug
Administration (FDA) to describe their list of chemicals allowed in processing and
packaging without being mentioned on the food labels. They call it "effective pre-market
notification", which means: if consumers want to know about them, they can dig through
the list of 300+ and try to figure out which ones might be in their food. The list is at www.
cfsan.fda.gov/~dms/opa-fcn.html
'Section 409(h)(6) of the FFDCA (21 U.S.C. 348(h)(6)) defines a food contact substance
as "any substance intended for use as a component of materials used in manufacturing,
packing, packaging, transporting, or holding food if such use is not intended to have any
technical effect in such food." The premarket notification process for food contact
substances in section 409(h) of the FFDCA is the primary method by which the Food and
Drug Administration (FDA) authorizes the use of food additives that are food contact
substances.'
FDA reviewed all these chemicals, but not for consistency with organic standards.
Gershuny is off the mark talking about equipment sanitizers and boiler chemicals. The
issue is chemicals such as are listed below which certainly violate OFPA 6510(a), which
says: "shall not....use any packaging materials, storage containers or bins that contain
synthetic fungicides, preservatives or fumigants". Or, 6510(b): "use any bag or
container that had been previously in contact with any substance in such a manner as to
compromise the organic quality of such product;" Funny thing, though---this part of OFPA
was never translated into detailed regulations. Was this one of those "contradictory"
areas which Gershuny found so frustrating while drafting the regulation?
A sampling of the first 100 in the FDA list:
#1 silver sodium hydrogen zirconium phosphate, rhombohedral....
"antimicrobial additive"
#2 amines, bis(hydrogenated rape-oil alkyd) methyl, N-oxides... "antioxidant and/or
stabilizer"
#6 copolymer of acrilonitrile and trivinylcyclohexane ion-exchange... "treating potable
water"
#11 4,5-dichloro-2-n-octyl-3(2H)-isothiazolone "as a preservative and slimicide in the
manufacture of paper and paperboard intended to contact aqueous and fatty food"
#35 dimethyl dicarbonate "as a microbial control agent in non-carbonated beverages
containing up to and including 100 percent juice"
#41 silicone acrylate resins.... "on paper or paperboard, at a maximum level of 1.3
milligrams per square inch (mg/in2), in contact with all food types...."
#52 agarose resin, crosslinked and alkylated with epichlorohydrin... "as a chromatic
material for the isolation and purification of food enzymes"
#55 terpolymer of styrene, divinyl benzene and ethyvinyl benzene, aminoethylated....
"for use in treating aqueous sugar solutions and hydrolyzed starch solutions"
#59 Glycine,N,N-bis-2-hydroxy-3-2(2-propenyloxy).... "as a component of paper and
paperboard in contact with nonalcoholic food"
#74 tetra-polymer of divinyl benzene, ethyl vinyl benzene, acrylonitrile, and 1.7-
octadiene.... "demineralizing sugar solutions...and to soften water for food and beverage
production"
#100 polyvinyl alcohol, manufactured as described... "component of coatings applied to
fruits
and vegetables with inedible peels, excluding citrus fruits"
The wrong turn that led to a regulation in violation of OFPA, was both philosophical and
legal. It happened on July 23, 1998, as described in a document on the USDA website,
titled "Interdisciplinary Taskforce on Processing Principles". From that document:
"IV. Because the Organic Foods Production Act of 1990 (OFPA) technically bars the use
of synthetic substances in organic food processing, no criteria for permitting them are set
out in the OFPA. The criterion on the NOSB's recommendation, namely that the
substance is "essential" to the manufacture of a product, would be a difficult concept to
defend as a sole criterion. Therefore, the Taskforce will develop a set of criteria to
determine which synthetic substances should be allowed.
V. The principles underlying organic production are ecological integrity and resource
conservation. Some such principles should also underlie the handling of organic foods
after harvest---that is, there should be stated goals directed towards minimizing the waste
of nonrenewable natural resources in processing and packaging of organic foods."
So there we have it. Organic food has little or nothing to do with health, safety or the
consumer desire to avoid the addition of chemicals to their food. Organic principles have
been boiled down to a "goal" of "minimizing waste". And what the OFPA says can be
simply brushed aside. Not much ambiguity here. Just a brash revision of what Congress
passed and what the great majority of consumers believe is in organic products.
Arthur Harvey, 1197 Main St, Hartford, Maine 04220 207-388-2860
Gershuny Letter & My Reply