Mr. Matthias Fecht

Organic Guarantee System (OGS) Coordinator

International Federation of Organic Agriculture Movements  (IFOAM)

Dear Mr. Fecht:

As a longtime member of IFOAM, the International Federation of Organic Agriculture Movements, the Organic Consumers Association recognizes that the proposed revisions of the IFOAM “Benchmarks of Standards” were clearly drafted with the four principles of organic farming-health, ecology, fairness, and care-in mind.  Unfortunately, in its attempt to foster international equivalence, the new draft IBS is likely to encourage wide disparities in organic standards.

At a time when the rapid entry of powerful corporate interests into the organic market is forcing a race to the bottom, this shift from “Basic Standards” to “Benchmarks” is irresponsible and could ultimately obscure the distinction between organic and conventional products and farming techniques. Instead of trying to find the lowest common denominator, IFOAM should actively promote the best practices of the highest organic standards.

Even if IFOAM chooses to set a floor rather than a ceiling, the IBS should meet the legitimate expectations of organic consumers who rightly believe that organic production is a pro-active, ecologically sound management system. These include the expectations that:

Successful conversion to organic

€¢    Can be ascertained by measuring the extent to which soil fertility has been improved and contaminants have been reduced.

Animal products sold as organic come from animals who

€¢    Have been in organic management continuously since birth.

€¢    Have eaten only what is consistent with their natural diet and is certified organic.

€¢    Are not clones or the progeny of clones.

€¢    Were not factory farmed or kept in confined animal feeding operations.

€¢    Were not given antibiotics or other allopathic medicines.

€¢    Have been protected from exposure to contaminants.

Crops sold as organic

€¢    Do not contain GMOs.

€¢    Were fertilized with organic compost and/or manure.

€¢    Were protected from exposure to contaminants by buffer zones.

To avoid creating a multilevel hierarchy of organic standards that could deflate consumer confidence in the concept, the IBS should drop unquantifiable terms and set measurable benchmarks for both processes and outcomes.

For example, the section on crop conversion speaks in terms of a “length” that is “sufficient” to achieve an outcome. This would be okay if the outcome were measurable, but the draft IBS contains no requirement to ascertain the extent to which soil fertility was “improved” and contaminants were “reduced.”

The section on animal production is even more vague with conversion periods described as “appropriate” with no reference to outcomes.  Organic farming has the potential to restore balance to the ecosystems whose health the planet relies on.  The Organic Consumers Association is committed to shifting as much agricultural production to organic as soon as possible, but we think that the best way to do this is with the highest organic standards. We trust that IFOAM shares this ideal and will remain a leader in promoting the best practices of the highest organic standards.

Sincerely,

Alexis Baden-Mayer, Esq.

Washington Representative

Organic Consumers Association