Testimony presented to USDA National Organic Program & National Organic Standards Board by Alexis Baden-Meyer, Organic Consumers Association, Washington, DC
May 22, 2008

I want to thank the members of the Nation Organic Standards Board, the representatives of the USDA National Organic Program and everyone in the room for being here together to further the organic movement. At a time when humanity faces a triple global crisis around energy, food and climate change, the organic movement is leading by example and providing solutions. Organic agriculture can simultaneously feed the world, conserve energy, and mitigate greenhouse gas emissions. It can increase biodiversity, restore human health and the health of ecosystems so that we can all have access to clean air, soil and water.

Another thing that's really special about the NOSB and the USDA NOP is the democratic process that we're seeing in action today. This is another way that the organic movement is leading by example. You won't find any other process for setting federal policy that is more democratic and inclusive of public participation.

I would like to congratulate the NOP on the budget increases achieved in the Farm Bill reauthorization and I want to thank all of the advocates in the room who worked tirelessly to make that happen. The Organic Consumers Association would like to encourage the NOP to spend the money on TAP reviews and NOP enforcement.

We support the petitions that the Cornucopia Institute has submitted on dairy and hexane-derived additives in infant formula. So, we'd like to see some money spent there. But, I would also like to encourage the NOP to do what other federal programs do: use your budget to increase your budget. Use the powers granted you by Congress to increase the powers granted you by Congress. Promote yourselves within the USDA as a model for conservation and food safety. I'd like to see the NOP enage in some mission creep. Communicate with an infiltrate other programs. Organic is the best model for conservation and food safety and everyone at the USDA and in Congress should hear that from you.

The following are the biggest threats that I see to consumer confidence in the organic program:

1. The delay in the NOP's announcement of rules on pasture and origin of livestock and the potential for those rules to be weak when they are finally announced. OCA supports the comments of the Northeast Organic Dairy Producers Alliance (NODPA) on this issue.

2. The NOP's lack of enforcement of the use of the word organic to market personal care products that don't carry the USDA seal. Some of these products contain petroleum-based formulations that produce the carcinogen 1, 4 dioxane.

3. The organic certification of fish farming. OCA supports Food & Water Watch's comments on this issue.

4. The continued and increasing use of synthetics in products labeled USDA organic. OCA supports the comments of Organic Materials Review Institute (OMRI), PA Certified Organic, Oregon Tilth, Lynn Coody, One-Cert and CCOF on these issues.

5. The extention of rules designed for community grower groups to the certification of multi-site retailers. OCA supports the comments of the National Organic Coalition (NOC) on this issue.

I've really enjoyed listening to the board's discussion. The committee presentations have been excellent and you all have asked a lot of really good questions. Several times the question, "What will consumers think?" has come up.

I'm going to brief our members on this meeting and encourage them to tell you exactly what they think. In addition, I'd like you to frame the question in your mind this way: If the things you know about organic production had to be on the label next to the organic seal, what would consumers think?

What if an organic pear had a sticker on it next to the USDA label that said treated with tetracycline?

What if organic mushrooms said grown on GMO substrates or produced with the use of synthetic hydrocarbon?

What if organic fish said grown on a land-based fish-farm or fed feed that doesn't meet UDSA standards that applied to other animal feeds?

There was a question posed earlier about whether consumers aren't savvy enough to read organic product labels. Let's remind ourselves that not everything ends up on the label.

The gap between the details of what you all know happens in organic production and what ends up on the label is filled by consumer trust. Let's do our best to maintain a program that is deserving of consumer trust.

Thank you.

Alexis Baden-Mayer
Washington D.C. Representative of the Organic Consumers Association