Dear President Obama and Secretary Vilsack,
The undersigned organizations applaud your recent statements and symbolic demonstrations of support for a new federal focus on food quality. The appointment of Dr. Kathleen Merrigan as Undersecretary at the USDA, and your words and actions (such as the new gardens) leave our organizations optimistic about the future.
Organic agriculture has proven, over the past 20 years, since widespread commercialization, to be the best economic development vehicle for family farmers. However, its great potential has been stunted by gross mismanagement at the USDA's National Organic Program.
A Crisis in Confidence
The NOP is dysfunctional. There has been a long-standing adversarial relationship with the majority of organic farmers and consumers and the groups that represent them.
Senior management with oversight of the NOP has treated industry stakeholders arrogantly and disrespectfully on many occasions and has overridden NOP career staff when their findings might have been unfavorable to corporations with interests in the organic industry (ascertained through FOIA documents-available upon request).
We would strongly recommend, as many public corporations do when trying to regain shareholder and Wall Street confidence, that the Department bring in a highly respected and skilled individual from the outside to run this program. Currently, there are no staff members with a history of experience in organic production agriculture or policy. This is disrespectful to the industry that it is mandated to regulate.
In addition to bringing in new top management overseeing the NOP, we support staffing a position in the Secretary's office to integrate organic programs throughout the diverse subdivisions of the Department.
Respecting the Intent of Congress
There are dozens of policy resolutions promulgated by the National Organic Standards Board (NOSB), the expert citizen advisory panel that Congress requires the Secretary to consult, that the Department has failed to act on. It is highly disrespectful for the NOSB to have engaged with the public in crafting rulemaking and guidance recommendations and have a large percentage of these resolutions languishing and ignored for, literally, years.
Audits prepared by the American National Standards Institute (ANSI) and the Inspector General's office were damning in their criticism of the program's failure to respect the NOSB's Congressionally mandated purview over policy and the program's failure to carry out its most fundamental responsibility-oversight and accreditation of the nation's network of independent organic certifiers.
The USDA has failed to establish the Congressionally mandated Peer Review Panel of experts to provide oversight of the NOP accreditation responsibilities.
The USDA has failed to adequately fund Technical Advisory Panels (TAP) to evaluate materials for use in organic production. The diverse NOSB is unqualified and handicapped in fulfilling their responsibilities without this resource.
Furthermore, Congress specifically set aside seats on the NOSB to assure a broad representation by all stakeholders in the industry (farmers, certifiers, consumers, retailers, manufacturers, environmentalists, etc.). The will of Congress has been grossly disregarded by prior USDA Secretaries in making these appointments, and there should be a renewed commitment by the incoming Administration to respect the letter and spirit of the law requiring disciplinary diversity and a collaborative relationship with this body.
Transparency
The program has operated in secret concerning certification documents, enforcement actions, and fulfilling FOIA requests. This has led to lawsuits and ill-will in the budding industry. The new Administration must radically change the character of the program to regain public confidence.
Protecting the Integrity of the Organic Label
It's been eight years since the NOSB passed the first of five separate regulatory or guidance recommendations to rein-in livestock abuses on giant industrial-scale dairies, each milking thousands of cows and labeling milk as organic.
Pasture Controversy: This past fall the USDA finally published a draft rule, far eclipsing anything that the NOSB had recommended, to require grazing on organic dairies. Not surprisingly it garnered wide concern from many other sectors in the organic livestock industry.
In essence, the NOP staff completely rewrote the livestock provisions of the federal standards without NOSB or industry input. This mess needs to be immediately cleaned up by the new Administration. Strong consensus recommendations from the organic community should be adopted. Inaction by the Department has squeezed profit margins for ethical family-scale organic dairy farms, and many now face financial ruin. For many farm families around the country this is an emergency!
Controversy over Conventional Animals on Organic Dairy Farms/Beef Production: The Department needs to engage in immediate rulemaking to close loopholes allowing "conventional" replacement cattle to be brought onto organic dairy farms on a continual basis. There is also an immediate need to close loopholes allowing feedlot production of organic meat animals, bypassing the expectation of consumers who assume that organic animals are raised on pasture and not depending on exclusive near confinement.
We thank you for your consideration of these points. The undersigned groups look forward to working with the Obama Administration and making the organic program one of the brightest stars in the USDA's constellation.
Respectfully submitted:
The Cornucopia Institute
Demeter Association, Inc.
Eden Foods, Inc.
Local Harvest
Organic Consumers Association
Organic Sacramento
Weston A. Price Foundation
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Open Letter to Obama from the OCA, Cornucopia, & Organic Community
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Organic Consumers Association, April 17, 2009
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