Im Alexis Baden-Mayer, political director of the Organic Consumers Association. On behalf of our quarter of a million active members, I would like thank you Chairman Moyer and each member of the National Organic Standards Board for bringing a number of important issues to the attention of Director Robinson and the USDA National Organic Program staff at this meeting. Of particular interest to organic consumers are seven things:
1. Food Packaging (disagree): We join Jim Riddle and others in urging you to reject the use of carbon dioxide, and other inert atmospheric gases or packaging aids that create an appearance of freshness even after food has spoiled in 100 percent organic products. The NOSB Certification, Accreditation and Compliance Committee is considering that inert atmospheric gases are not processing aids because they have no functional effect in the food, but merely modify the environment in which the food is packaged. Jim Riddle points out that this is an incorrect reading of the law. 7 CFR 205.301(f)(4) is quite clear. It states, products labeled as 100 percent organic, if processed, must be processed using organically produced processing aids. This means that all ingredients and processing aids, including so-called packaging aids, must be 100% organic in order for the product to be labeled 100% organic. Anything less does not comply with the Final Rule, and is misleading to consumers.
2. Nanotechnology (disagree): We respectfully disagree with the Materials Committee that Under the current definition, most nanotechnology would not fall into the category of excluded methods. Nanotechnology production techniques are "means that are not possible under natural conditions or processes and are not considered compatible with organic production." Organic farming methods are based on the use of natural biological and ecological processes. The use of engineered nano-particles which would not exist in nature and whose basic physical structure has been modified at a very fundamental level would be incompatible with this important organic principle. We support the comments of the Center for Food Safety and the Consumers Union on this issue.
3. Sulfurous Acid (oppose): We oppose the Crops Committees recommendation to allow the on-farm burning of elemental sulfur (which results in the emission of sulfur dioxide, a source of acid rain) to create sulfurous acid for crops like wine grapes that like acidified soil. We join Jim Riddles comments that this recommendation should be tabled until a full and impartial TAP review is conducted.
4. National Organic Program Peer Review Board (agree with caveat): The overwhelming majority of organic farmers, producers, and certifiers are playing by the rules, but a single example of organic fraud can crumble consumer confidence in organic certification. Thank you to the Certification, Accreditation, and Compliance Committee for pushing the Nation Organic Program to create the legally required Peer Review Board. We support Jim Riddle and Lynn Coodys comments regarding how this should be done, including their recommendation that the National Voluntary Conformity Assessment System Evaluation, an existing government program specifically focused on auditing organic accreditation programs, is well suited to fulfill the role of Peer Review Panel.
5. Soy Lecithin (agree): Organic processors have been allowed to use conventional soy lecithin even though organic soy lecithin is now available. Organic consumers expect the highest percentage possible of organic ingredients in their organic foods. We support the Handling Committees recommendation to remove the exemption for conventional soy lecithin.
6. Biodiversity (agree): We join the Wild Farm Alliance and others in support of the current recommendations on the Implementation of Biodiversity Conservation in Organic Agriculture Systems. These recommendations address two current consumer concerns. First, misguided, one-size-fits-all food safety regulations, that could unnecessarily harm wildlife and destroy their habitat, and second, the destruction of rainforests by agriculture, especially soy, palm and beef production. The adoption of the biodiversity recommendations would be an assurance to consumers that organic remains the highest standard of environmental protection in agriculture.
7. Personal Care Products (agree): Personal care products labeled or marketed as organic should meet USDA standards. Unlike organic foods, many personal care products are falsely labeled as "organic." The USDA should use its enforcement power to go after shampoos, cosmetics and other personal care products that mislead consumers by improperly using the term "organic" in their name, branding and marketing claims. We join Dr. Bronners Magic Soaps and others in encouraging the Certification, Accreditation and Compliance Committee to finalize recommendations with the hope that they will be adopted this fall.
