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PAN ALERT: USDA No Sneak Attacks on Organic Standards

USDA rushing addition of more conventional ingredients in organic products: On May 15, the US Department of Agriculture announced a scant seven-day public comment period on a controversial proposal developed with absolutely no input from consumers--to allow 38 new non-organic ingredients in products bearing the "USDA Organic" seal. At least three of the proposed ingredients, backed by beer giant Anheuser-Busch and pork and food processors, represent a serious threat to organic standards.

Take action TODAY! The Organic Consumers Association (OCA) is gathering signatures for a petition to the USDA due May 22, demanding that the comment period be extended. Sign immediately, and PAN will see that your name is added to OCA’s petition.

OCA, speaking from the perspective of organic consumers, supports the National Organic Program for clarifying to producers that if an item is not on the National List of exceptions for ingredients, it cannot be used in conventional form. But in this case, consumers should not support all of the National Organic Standards Board's (NOSB’s) 38 recommended additions to the National List. Specifically, OCA opposes the addition of casings from processed intestines, hops (without specific listings), food colorings derived from plants that are supposedly not "commercially available" in organic form, fish oil, beet juice, lemongrass, rice starch and whey protein.

USDA claims that these exceptions must be added to the list as concessions to countless companies who have violated the National Organic Standards in the past by using conventional ingredients that were not on the National List. These same companies have been given months to petition the NOSB for inclusion of desired conventional ingredients on the National List. In contrast, the general public has only been allocated 7 days to comment.

Please sign the petition today. Demand that USDA extend the comment period to allow real public input. Sign the petition below, or click on the "Learn more" link below to read the full USDA proposal. Comments must be received by PAN or OCA no later than 3 pm Eastern, 12 noon Pacific Time, May 22, 2007.

Subject: Comments on AMS-TM-07-0062

To: Robert Pooler Agricultural Marketing Specialist National Organic Program, USDA/AMS/ TMP/NOP 1400 Independence Ave., SW., Room 4008-So., Ag Stop 0268 Washington, DC 20250.

Speaking from the perspective of organic consumers, we support the NOP for clarifying to producers that if an item is not on the National List, it cannot be used in conventional form. However, we do not support all of the NOSB's 38 recommended additions to the National List. Notably, we are opposed to the addition of casings from processed intestines, hops (without specific listings), fish oil, beet juice, lemongrass, rice starch and whey protein.

AMS-TM-07-0062 claims that these exceptions must be added to the list to offer concessions to countless companies who have violated the National Organic Standards in the past by using conventional ingredients that were not on the National List. These same companies have been given months to petition the NOSB for inclusion of desired conventional ingredients on the National List.  In contrast, the general public has only been allocated 7 days to comment.

Specifically, we are opposed to allowing the following conventional ingredients in organic production:

1) FOOD COLORINGS
We believe additional criteria should be added to any of the added food colorings to the National List. Food colorings should be treated in a manner similar to flavors by the NOP. Before a food coloring is added to the National List, it should be stipulated that there are no synthetic solvents, preservatives or additives.

2) CASINGS FROM PROCESSED INTESTINES
The proposed addition to the National List is focused on bovine, ovine and porcine animal intestines used as sheaths for products such as sausage links.  Surveys of organic consumers find that a high percentage of beef eating organic consumers choose organic products to avoid diseases associated with conventional meat production. Specifically, the organic beef industry has enjoyed a considerable boom as more consumers are concerned with bovine spongiform encephalopathy (BSE) which has only been detected in animals raised conventionally. BSE is transmitted via the consumption of prions in infected body tissue. There is no scientific evidence that excludes bovine intestine as a possible source of BSE transmission.

In short, many consumers are choosing to pay notably higher prices for organic beef based meats to avoid conventionally raised beef. By allowing conventional casings on the National List, these consumers will be misled into believing that the meat product they are eating was raised in accordance to the National Organic Standards, when, in fact, the intestinal casing may be from an animal that lived its life on a factory farm in intensive confinement, consuming pesticide laden foods, and treated with an assortment of antibiotics and drugs.

A meat labeled as "organic" should truly be organic, and the allowance of conventionally produced intestinal casings violates consumer rights.

3) HOPS 
Hops (Humulus lupulus) should not be included on the National List in such general terms. Only specific low-supply varieties should be listed. Although organic hops is in high demand, there are over a dozen varieties of organic hops available on the market (available in both pellet and whole flower form). 

Hops is one of the main ingredients in beer. It is misleading to allow a beverage to be labeled as "organic" when its main ingredient was grown with pesticides and synthetic fertilizers. By including hops on the National List, consumers will not be able to distinguish truly organic beer from a beer with a main ingredient that is conventionally grown.

Also, putting hops on the National List offers unfair advantages to large-scale breweries. There are many micro-breweries now selling truly organic beers (with organic hops). These companies cannot compete with the prices of larger companies stepping into the "organic" beer business, like Budweiser, who will be allowed to use less expensive, conventionally grown hops (non-organic hops costs less than half as much as organic hops). Breweries need to put more effort into developing organic hop resources here in the USA before they try and make organic beer with inorganic hops.

We believe specific varieties of hops that are in well documented low supply on an organic level could be listed here, but including all varieties of hops on the National List is unnecessary and harmful to organic hops producers.

4) FISH OIL
We do not agree with the recommendation of listing fish oil on the National List. Fish oil has not undergone any TAP review, which is required for any substance proposed for the National List. Also, there are no organic standards for fish under the USDA NOP. Also, there must be criteria for the fish oil when/if it is allowed. For example, is it solvent extracted, and has it been tested for contamination from heavy metals, PCBS, and dioxin. This is a substance that is still undergoing review and definition and should not be considered for listing until it has gone through these required processes.

5) Lemongrass, Rice Starch, Beet Juice & Whey Protein Concentrate We believe the above ingredients are available in quantities sufficient enough to serve the organic industry. These ingredients should be re-evaluated using the criteria established by 7 U.S.C. 6517 and 6518 of the OFPA and NOP criteria (72 FR 2167). 

We ask that you remove each of the above ingredients from the AMS-TM-07-0062 proposal. We also ask that you consider extending the public comment period from 7 days to a period more appropriate for such a major rule change (30-60 days).

Thanks for your consideration,

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Comments may also be submitted directly to Robert Pooler, Agricultural Marketing Specialist, National Organic Program via: http://www.regulations.gov.

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PAN ALERT: USDA No Sneak Attacks on Organic Standards

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