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I have some remarks on the March 31 article by Dan Sullivan, entitled
v. Veneman: Spectre
of unintended consequences roils organic waters.” For
my part, nothing "unintended" has occurred. Of course,
industry leaders who assumed that USDA could do no wrong (legally
speaking) are overwhelmed by surprise and wonder at the changes
they face. Such is the result of complacency. They could instead
have exercised due diligence and hired competent attorneys to predict
the unanimous verdict of the appeals court.
How did it happen that organic heavies--inside and outside USDA--pretended
all along that the law allowed synthetics in processing? And how
did it happen that USDA staff lied to the courts about whether .606
was administered to provide blanket approval for "any agricultural
product" in violation of the law? Fortunately, the appeals
court understood the duplicity and required a declaratory judgment
that the violations must stop.
Your discussion of the 80/20 dairy feed conversion system omits
one crucial element: Under that system, cows can--and for the most
part will--be fed GMO corn, soybeans and other products until 90
days prior to "organic" production. Consumers are not
being told of this. This was not the case when 80/20 was adopted
10 or 15 years ago.
I am asking the court to provide 24 months to phase in the reformed
standards, after which no further non-confoming products may enter
the stream of commerce. USDA has so far indicated a preference for
12 to 18 months. It might be worth making some effort to persuade
USDA to adopt the longer phase-in, which would reduce the impact
on farmers and allow manufacturers to find more natural substitutes
for the synthetics now in use.
The basis of the law is strict control of synthetics in farming
and a complete ban on synthetics added to processed foods (except
for health and safety requirement of other laws). Those who wish
to ask Congress to amend the law to legalize the present system
will have to undermine or abolish this basic principle. Once that
happens, there will be no checks at all on the free hand that USDA
will have to water down organic standards. This is the issue on
which I brought my lawsuit.