Remember the Farmers

NOSB will define "compatibility" with organic practices at its next meeting

The next National Organic Standards Board (NOSB) meeting will be held October 22-24, 2003 in Washington, D.C. (around the time this article is published). This time the agenda for the meeting has a definite theme-one that should not be taken lightly. The public is being asked to comment on how the NOSB will interpret one of the criteria it is required to use when evaluating a material for placement on the National List.

As you may recall, the NOSB's real statutory authority comes in its ability to place materials on the National List: the synthetic substances that are allowed in organic production and handling, as well as the non-synthetic (or natural) substances that are prohibited. Such materials are petitioned for placement on the list and undergo an evaluation under several different criteria prior to the NOSB vote. One category of these criteria deals with the "compatibility and consistency of substances in systems of organic or sustainable agriculture."

The question for the public and for the NOSB at this meeting is:

In substance review and evaluation, what constitutes compatibility/consistency with a system of sustainable agriculture/organic production and handling?

Most of the National List criteria are less nebulous and more easily understood. The task of determining how to evaluate compatibility and consistency is daunting. How do we define "sustainable" agriculture and organics so that the definitions will apply to evaluation? How do we ensure that the intent of the regulations is maintained in the process? What effect does this have on organic products? Will the end result truly provide compatibility and consistency?

The question at hand is a provocative one. Originally there were two versions of the Organic Foods Production Act (OFPA)-the House and Senate each had a slightly different idea of what the program should be. Their Conferee Report gives us a glimpse into what Congress was thinking with regard to NOSB's evaluation of materials. When considering what should or should not be allowed, one concern was whether or not to allow natural substances based only on the fact that they are natural:

"The Committee understands that just because a substance is natural does not mean that it is safe and appropriate for organic production. The National List may also include natural substances otherwise allowed under this title but which are determined to be harmful to human health or the environment and inconsistent with organic farming. Certain botanical pesticides may be considered by the Organic Standards Board and the Secretary to be inappropriate for organic production because their use poses significant harm to human health or the environment."

This was such a major consideration that OFPA included a "Special Review of Botanical Insecticides" directive to the NOSB calling for a review of all botanical pesticides used in agricultural production and consideration of whether any of them should be included in the list of prohibited natural substances.

Obviously, the natural versus synthetic paradigm, once thought to be the distinguishing factor for materials used in organics, was shifting to a broader approach and scrutiny. To evaluate for "consistent" with organic, part of the task is to look at how the material impacts the environment in a broader way.

The board's agenda includes a term not seen a great deal in the organic regulations. "Sustainable" appears in OFPA only once, and not at all in CFR 205; however, it is used several times in the Conferee Report. By adding this term to the evaluation criteria, could there be a change in how materials are viewed?

In the shadow of the recent events at the WTO (see report in this issue -ed.), perhaps it is time to reconsider our approach to organic materials review. It is time to stop and think if the organic program being developed by our nation remembers the farmers, who are seldom able to get to Washington, D.C. to give public input. It seems that in materials evaluation, at least, the Congress that passed OFPA was thinking about farm sustainability. The term "sustainable agriculture" was just beginning to be used at about the same time. But unlike "organic" it does not have a clear definition.

In the past there has been much discussion of whether or not the organic regulations were intended to help keep family farmers on the land in addition to creating and promoting a more ecologically sound system of agriculture. Keeping farmers on the land is a huge job in this day and age-and often thought to be way beyond the scope of OFPA. For the first time, however, we are seeing NOSB grapple with a concept that may encourage open minds about this issue. In this analysis the board should take into consideration what "sustainable" really means.

If the NOSB can embrace the concept of sustainability and approach its task in a holistic manner, then it may have the ability to assist farmers and handlers. Sustainable agriculture has often been defined as taking into consideration a wider perspective than the human health and environmental impact of the farming system. Economic stability and quality of life issues are also a part of sustainability; however, they have not typically been part of the criteria considered in the implementation of the Organic Foods Production Act. Will the upcoming meeting broaden the vision of organics to include such ideals?

Currently there is no consideration of the financial factor in materials evaluation. Should there be? Many farmers think so.

Is it possible that there are synthetic substances that are more consistent with organics than their natural counterparts?

Is it possible that there are some things that just cannot be produced organically because for some essential ingredients there is no material that really fits all of the criteria?

Will these issues change the composition of the team of reviewers that provide information to the board?

When evaluating materials, the NOSB looks at a Technical Advisory Panel (TAP) review and recommendations from experts in the organic community. The TAP review is very scientific, performed by university or professional research organizations. These reviews need to be conducted by individuals who understand organics and sustainable agriculture in order for the recommendations to be complete. It is time to add this level of expertise.

The nations who walked out of the WTO made a statement about the importance of how meetings, agendas, and regulations must represent the needs of all of the people at the table-including farmers. Similarly, the National Organic Standards Board has the chance to make a statement with its work. The board has an opportunity to show that it views as important the needs of farmers as it considers organic farming and handling from the perspective of compatibility/consistency with sustainable agriculture. It is important that the focus start with farming and that farmers' needs and concerns rise to the top of the agenda.

For more information visit the National Organic Program website at

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