From Western Organization of Resource Councils (WORC):


http://www.worc.org/userfiles/file/Food%20Safety%20Act2.pdf

(Thanks to Jill Richardson: http://lavidalocavore.org )

        Tell
Congress: One Size Does Not Fit All When Considering Food Safety
Bills

Local foods businesses are not the same as animal factories or
mega-farms that sell products into industrial scale national and
international markets.

H.R. 2749 - Food Safety Enhancement Act of 2009

Lead Sponsor: Rep. John Dingell

The House of Representatives is working on H.R. 2749, the Food Safety
Enhancement Act of 2009. It’s an attempt to address the worst problems in

U.S. agriculture, but as it stands the bill threatens to undermine
the best things in U.S. agriculture - small farmers producing for local
markets. H.R. 2749 is a well-meaning attempt to address the genuine
problems of contamination from foodborne pathogens and complications in
prevention and intervention caused by large, industrialized food
distribution systems. All of the well-publicized incidents of
contamination in recent years - spinach, peppers, peanuts, hamburger -
occurred in industrialized food supply chains that span national and even
international boundaries. Food safety is a priority shared by all. It is
not compromised by the growing trend toward healthy, fresh, locally
sourced vegetables, meats, fruits, and small processing firms
reinvigorating local food systems. The following priorities need to be
incorporated to make food safety and healthy local food systems
complementary. Local food systems are inherently safer and traceable.

Record keeping should not strangle small producers selling into local
markets

Record keeping and traceability are essential in long industrialized
supply chains. For direct market produce growers, elaborate reporting and
record keeping requirements, including mandatory electronic filing, do
not make sense, as the buyer knows where the food comes from. For sales
to local retailers and restaurants, records should be kept to a minimum,
and should be flexible - on file on paper or electronically.

Under the legislation, FDA will develop rules for record-keeping. The
bill should add language to ensure that direct market produce growers be
consulted and included as a unique category of business in the rulemaking
process.

Registration and fee structures should recognize small home-based and
farm-based local processing

Farms that sell directly to the consumer or to a retail outlet or
restaurant are exempt from registering with the FDA. However, if a farm
makes jams and sells them it would need to register with the FDA and pay
a $500 annual fee, same as food giants like Del Monte.

FDA oversight of small, local food processors is overreaching and
unnecessary

The size and extent of industrial processing (including multiple
sourcing, etc.) should play a significant role in determining the level
of inspection, record keeping, and traceability requirements mandated and
overseen by the federal government. Small local processors selling into
local markets do not need federal oversight appropriate for large,
industrial, multi-sourced supply chains. The legislation permits
delegating some oversight responsibilities to the states. There should be
a clear threshold where state and local public health and sanitation laws
and authorities are sufficient.

All facilities subject to registration under theAct, including those
only engaged in intrastate commerce, are subject to federal inspection.
The large recalls during the last several years have all involved
facilities that shipped interstate. The Act should set a jurisdictional
threshold based on scale and extent of distribution. Since foodsheds
often span a state-line, these may be most appropriately defined as a
mileage radius.

HACCP undermined local and regional meat packers while failing to
increase inspections and

safety of large industrial meat processors

For meat processors, the Hazard Analysis and Critical Control Point
(HACCP) system adopted by the U.S. Department of Agriculture in the
1990’s effectively reduced the number of small regional packers by
creating a maze of paperwork and red tape that many were unable to
manage, while failing to reduce the increasing incidence of food borne
pathogens in the large industrialized meat packers. The HACCP system all
but eliminated the number of independent inspections of the large
industrial slaughterhouses. It is critical that Congress not replicate
the ineffective systems that failed in the meat industry.

H.R. 2749 extends HACCP type models to produce, with potentially
disastrous consequences for small producers.

Imports need sufficient scrutiny to ensure public health is not at
risk

Increased scrutiny, inspection and enforcement of safety of food
imports is a good idea to protect public health. There needs to be a
level playing field between U.S. farmers and global competitors. H.R.
2749 adds some labeling and inspections of imports, but it needs to be
stronger to protect public health. Free trade agreements, such as the
North American Free Trade Agreement (NAFTA), give carte blanche to
agricultural products coming in from trade partners whose standards and
systems of inspection may be grossly inferior. H.R. 2749 needs to go
further to study imported foods and ensure they are held to the same
standards as U.S. products.

FDA will establish standards for safe growing, harvesting, packing,
sorting, transporting and holding of raw agricultural commodities

It is over-reaching to establish federal farming standards for
produce that is not going into interstate commerce.

Care should be taken not to duplicate systems. Products that are
already certified under other rigorous certification standards (e.g.
organically certified, etc.) should be exempted.

This message originated from or was forwarded by:
Chrys Ostrander
Chrysalis Farm @ Tolstoy
Organic Micro-permaculture
33495 Mill Canyon Rd.
Davenport, WA 99122
509-725-0610
chrys@thefutureisorganic.net

http://www.thefutureisorganic.net

"From each according to their ability, to each according to
their needs"
Louis Jean Joseph Charles Blanc - "The organization of work"
1839
Karl Marx - "Critique of the Gotha Program" 1875

"The purpose of agriculture is not the production of food, but the
perfection of human beings"
Masanobu Fukuoka (February 2, 1913 - August 16, 2008)  - "One
Straw Revolution" 1978

"The community whose every member possesses the art of deriving a
comfortable subsistence from the smallest area of soil… will be alike
independent of crowned-kings, money-kings, and land-kings…."
Abraham Lincoln: Address to the Wisconsin State Agricultural Society,
Milwaukee, Wisconsin, 1859

"We will never have an organic future and a stable climate until we
pull all the troops out of Iraq
and redirect our annual $650 billion military budget to greening the
economy and guaranteeing
a sustainable environment and economic justice for everyone."
Ronnie Cummins, National Director, Organic Consumers Association
at the "Farms Not Arms" public forum and protest in Manhattan,
September, 2007

BODY {font-family=”Arial”} TT {font-family=”Courier New”} BLOCKQUOTE.CITE {padding-left:0.5em; margin-left:0; margin-right:0; margin-top:0; margin-bottom:0; border-left:”solid 2″;}

53,358 people have signed this petition as of this writing. Petition at
http://www.fooddemocracynow.org/

Dear President-Elect Obama,

We congratulate you on your historic victory and
welcome the change that your election promises to
usher in for our nation. As leaders in the
sustainable agriculture and rural advocacy
community we supported you in record numbers
during the caucus, primary and general election
because of the family farm-friendly policies that
you advocated during your campaign.

As our nation

>For immediate release
>December 15, 2008
>Contact: Christina Schiavoni, (212) 629-9788,
>Christina@whyhunger.org
>Kathy Ozer, (202) 543-5675, kozer@nffc.net
>
>
>President-elect Obama presented with urgent “Call to Action”
>to end food crisis
>Experts advise that economic reform must include sound farm and food
>policy
>
>As food banks scramble to respond to a dramatic increase in demand this
>holiday season, while unemployment surges and farmers face plummeting
>crop prices, a broad sector of groups are calling on the incoming Obama
>administration to put hunger and the global food crisis front and center
>on its list of top priorities.
>
>In today’s open letter to President-elect Obama, faith-based,
>environmental, agricultural, and hunger organizations outlined a “Call
>to Action on the World Food Crisis,” that includes specific
>recommendations for policy shifts and U.S. global leadership. The
>authors of the Call to Action call themselves the “US Working Group on
>the Food Crisis.”
>
>”The global food crisis ceded headlines to the financial crisis this
>fall,” noted Bill Ayres, Executive Director of World Hunger Year. “But
>the problem has not gone away. In fact, the fragile economy in the U.S.
>and around the world has only made hunger more widespread.”
>
>According to a recent report from the U.S. Department of Agriculture,
>which tracks U.S. food insecurity, 36.2 million people, including 12.4
>million children, were food insecure in 2007, even before the economic
>recession. The most recent global figures from the Food & Agriculture
>Organization estimate 963 million hungry people, a situation that the
>Working Group calls “morally reprehensible” and a potential driver of
>political unrest and instability.
>
>As a candidate, President-elect Obama pledged to end childhood hunger in
>the U.S. by 2015, and publicly recognized the deep flaws in the current
>global food system and the need for reform. “We want to give him some
>tools to reach these goals,” continued Ayres. “Addressing the food
>crisis well is not only more urgent in light of the economic downtown -
>it can be an important part of the solution.”
>
>The working group lays out specific recommendations for national
>policies that would:
>
>* Stabilize and guarantee fair prices for farmers and consumers
>globally;
>* Rebalance power in the food system;
>* Make agriculture environmentally sustainable;
>* Respect, protect and fulfill human rights of farmworkers and other
>food system workers; and
>* Guarantee the right to food.
>
>In promoting these solutions, the Working Group points to recent
>findings by international experts under the UN-sponsored International
>Assessment of Agricultural Knowledge, Science and Technology for
>Development (IAASTD). The IAASTD results, which were accepted and
>approved by 58 governments around the world (but not fully by the U.S.),
>emphasize the importance of supporting multifunctional, small-scale
>agricultural production to effectively address both hunger and
>environmental sustainability in the long term.
>
>”We are at a critical crossroads in rethinking the structure of our food
>and farming systems worldwide,” says Dr. Marcia Ishii-Eiteman, Senior
>Scientist for Pesticide Action Network and one of the authors of the
>IAASTD report. “We believe President-elect Obama can and must play a key
>role in moving us toward a future where sustainable agriculture supports
>vibrant rural communities, respects the dignity of workers, and delivers
>safe and healthy food for all.”
>
>”NAFTA, the WTO and other free trade agreements have pushed countries to
>become too dependent on highly speculative and volatile global markets
>for their food security,” said Ben Burkett, Mississippi farmer and
>President of the National Family Farm Coalition. “We need to reorient
>our farm policy away from a primary focus on exports and corporate
>profits and toward support for family farmers and food
>self-sufficiency.”
>
>Dennis Olson from the Institute for Agriculture and Trade Policy added,
>”There is now a global consensus that agricultural trade deregulation
>has played a large role in the food crisis. With regard to trade, we
>need to stop treating food like TV sets. Countries need the policy
>flexibility to stabilize agriculture markets and support their own
>production of healthy food - and that includes the U.S.”
>
>For more information:
>Letter to President-elect Obama:
>http://www.usfoodcrisisgroup.org/files/Open%20Letter%20to%20President-el
>ect%2012-15-08.doc
>US Working Group on the World Food Crisis and Call to Action:
>http://www.usfoodcrisisgroup.org/
>
>
>Available for interviews:
>* Kathy Ozer, Executive Director, National Family Farm Coalition,
>202-543-5675; kozer@nffc.net
>* Bill Ayres, Executive Director, WHY (World Hunger Year),
>212-629-6259; bill@whyhunger.org
>* Marcia Ishii-Eiteman, PhD, Senior Scientist, Pesticide Action
>Network North America (PANNA), 415-981-6205 x325;
>mie@panna.org
>* Dennis Olson, Senior Policy Analyst, Trade & Global Governance
>Program, Institute for Agriculture & Trade Policy, 612-870-3412;
>dolson@iatp.org

This message originated from or was forwarded by:
Chrys Ostrander
Chrysalis Farm @ Tolstoy
Organic Micro-permaculture
33495 Mill Canyon Rd.
Davenport, WA 99122
509-725-0610
chrys@thefutureisorganic.net
http://www.thefutureisorganic.net

“From each according to their ability, to each according to their needs”
Louis Jean Joseph Charles Blanc - “The organization of work” 1839
Karl Marx - “Critique of the Gotha Program” 1875

“The purpose of agriculture is not the production of food, but the
perfection of human beings”
Masanobu Fukuoka (February 2, 1913 - August 16, 2008) - “One Straw
Revolution” 1978

“We will never have an organic future and a stable climate until we
pull all the troops out of Iraq
and redirect our annual $650 billion military budget to greening the
economy and guaranteeing
a sustainable environment and economic justice for everyone.”
Ronnie Cummins, National Director, Organic Consumers Association
at the “Farms Not Arms” public forum and protest in Manhattan, September, 2007

Please consider making a contribution towards my sustainable
agriculture organizing work.
https://www.paypal.com/cgi-bin/webscr?cmd=_s-xclick&hosted_button_id=424800

Thank you.

Sometimes the underdog has more power in politics when enough of us rise
up to say "NO!" to a pending decision than we do when we try to
put forth a position pro-actively. This could be the case with the
pending Secretary of Agriculture appointment.  Below is what I’m
sending to

http://change.gov/page/s/ofthepeople
and my congressional delegation (along with the long quote). I
encourage you to do so as well.

Chrys

A candidate for Agriculture Secretary’s position on biotechnology is a
litmus test for me. Tom Vilsack fails that test. This is NOT the time to
appoint someone so close to the biotech industry to head the USDA. To do
so would be to commit a grave error of "business as usual" at a
time when CHANGE is what is desperately needed.

A person who identified himself as frankpatton left a comment on the

Huffington

Post blog on a post about Vilsack being considered for Ag. Sec. He
says all I need to hear to conclude that Tom Vilsack is NOT the right
choice for Sec. of Agriculture:

"Vilsack for US Sec of Ag? Are you kidding!

* Vilsack’s support of pharmaceutical crops, especially
pharmaceutical corn:

http://www.gene.ch/genet/2002/Oct/msg00057.html

http://www.organicconsumers.org/gefood/drugsincorn102302.cfm

* The biggest biotechnology industry group, the Biotechnology
Industry

Organization, named Vilsack Governor of the Year. He was also the
founder

and former chair of the Governor’s Biotechnology Partnership.

http://www.bio.org/news/pressreleases/newsitem.asp?id=2001_0920_01

* When Vilsack created the Iowa Values Fund, his first poster child
of

economic development potential was Trans Ova and their pursuit of
cloning

dairy cows.

* Vilsack was the origin of the seed pre-emption bill in 2005, which
many

people here in Iowa fought because it took away local government’s
possibility of

ever having a regulation on seeds- where GE would be grown, having
GE-free

buffers, banning pharma corn locally, etc. Representative Sandy
Greiner, the Republican sponsor

of the bill, bragged on the House Floor that Vilsack put her up to it

right after his state of the state address.

* Vilsack has a glowing reputation as being a schill for agribusiness

biotech giants like Monsanto. Sustainable ag advocated across the
country

were spreading the word of Vilsack’s history as he was attempting to

appeal to voters in his presidential bid. An activist from the west
coast even made this youtube

animation about Vilsack

http://www.youtube.com/watch?v=Hmoc4Qgcm4s

The airplane in this animation is a referral to the controversy that

Vilsack often traveled in Monsanto’s jet."

At 03:55 PM 11/19/2008, you wrote:

With all the chatter about Tom
Vilsack, USDA and who Obama might appoint to the Sec of Ag position, I
thought some of you might be interested in the latest post at the Blog
for Rural America by my colleague John Crabtree. Weigh in with your own
thoughts in our comment section, if you are so moved. Regards, Brian

Center for Rural Affairs | Blog
for Rural America

A Different View of Vilsack

by John Crabtree on
Wed, 11/19/2008 - 14:41.

The President’s Choice
President-elect Obama has not indicated his choice for Secretary of
Agriculture. Therefore, predictions on the outcome of this process are,
at best, speculative. We have no special insight into the
President-elect’s selection process. However, multiple media reports have
established an unofficial "short list," and my colleague Steph
Larsen wrote an
excellent
post reviewing the potential field of candidates (also posted at
Ethicurean
).

The Washington Post and other media outlets have reported that Governor
Tom Vilsack

is the "near shoo-in" in this process.

I have known Governor Vilsack for over a decade. Considering all the
ongoing speculation and critique of the former Governor, I thought I
should weigh in. There are a lot of questions that one might ask a
potential Secretary of Agriculture. I picked three.

Reforming Farm Programs

Historically, Governor Vilsack has shown consistent support for reforming
farm programs; especially making farm program payment limits more
effective, reducing subsidies to the nation’s largest farms and investing
the savings in conservation, rural development, nutrition, etc.

A 2006 Washington Post article

wrote of the Governor:

There may be no better sign of the changing debate over the nation’s
farm subsidies: A Midwestern governor running for president calls for
cuts in a system that has steered hundreds of millions of dollars a year
to his state…

Politicians such as Vilsack have joined a host of interest groups
from across the political spectrum that are pressing for changes in
government assistance to agriculture. They want the money moved from
large farmers to conservation, nutrition, rural development and energy
research. Vilsack, for example, favors programs that improve
environmental practices on farms…

Governor Vilsack has reiterated these positions since that time,
both publicly and, quite recently, to me. Last week I had a conversation
with Governor Vilsack about these issues. I asked him what areas need
investment the most, to which he responded that such a question is like
asking which of his two sons he loves the best. "There will be an
opportunity next year with the re-authorization of child nutrition
programs to address that need first. The Conservation Stewardship Program
must be more adequately funded than in the past to preserve our most
precious resources - our soil and water. And rural entrepreneurial
development, next generation biofuels, expanded wind/solar/geo-thermal
uses for land, specialty crops, local foods efforts and rural, high-speed
broadband internet access need investment," Vilsack added.

Biotechnology

Governor Vilsack’s most ardent detractors have focused on his promotion
of biotechnology as an economic opportunity for Iowa and Iowa farmers.
Organic farmers and organic consumer advocates have great trepidation
regarding Vilsack’s full-throated support for biotechnology, fearing the
destruction of the integrity of identity-preserved and organic
production, processing, transportation and marketing systems from
contamination by genetically modified materials. They have legitimate
concerns.

Because those concern are, arguably, the most significant criticism of
Governor Vilsack as a potential Secretary of Agriculture and because the
conflict between biotechnology and organic farming is so fundamental and
structural in nature, I felt there was no other way of finding out more
than to ask him. So, last week, I did.

He offered his priorities for protecting organic farmers and organic
production systems: labeling to provide consumers a stronger voice in the
marketplace and create opportunities for farmers to develop high-valued
markets for their products, coupled with separation distances and other
similar production, transportation and processing requirements that would
protect organic crops from contamination, and establishment of clear
liability from the biotechnology company, processor or handler
responsible for the contamination when it occurs.

Additionally, Governor Vilsack talked about the importance of preserving
and strengthening the integrity of the approval process for new
biotechnologies; that, from USDA’s perspective, new technologies should
have the burden of proof that they will not harm markets for
conventional, identity-preserved and organic products; and they should be
of benefit to farmers, not just biotechnology companies.

Precautionary approval of new biotechnologies is crucial. The
introduction of pharmaceutical corn in Iowa, for example, could threaten
conventional markets for export and domestic human consumption as well as
organic farmers. I have disagreed with Governor Vilsack over
biotechnology issues several times. But I am encouraged by the responses
above and by his open-minded approach and willingness to learn from past
experience and mistakes alike.

Livestock Market Reforms

I still have the pen that Governor Vilsack gave me that he used to sign
the livestock market reform and price reporting legislation that I worked
on in the Iowa Legislature in 1999. I know from the experience of working
on that legislation and during subsequent debates over livestock market
reforms that Governor Vilsack has consistently supported crucial
livestock market reforms.

I asked Governor Vilsack how USDA should address the challenge of more
effective enforcement of the Packers and Stockyards Act, considering the
abysmal record of the Packers and Stockyards Administration

over the last decade. He pointed out that the 2008 farm bill
contains, for the first time ever, a livestock competition title and that
the first priority for USDA’s enforcement of the Packers and Stockyards
Act will be proper implementation and aggressive enforcement of the
provisions in that title. And, he added, that prioritization includes
writing effective rules for enforcement of the Packers and Stockyards
prohibition of "unreasonable preferences" in order to prevent
price discrimination by packers against family farm livestock
producers.

He also told me, "I agree with President-elect Obama’s support for
the provision in the farm bill that would have prohibited packers from
owning livestock - support that he expressed both during the farm bill
debate and his campaign. And I agree with Senator Harkin and Senator
Grassley who, along with a number of other Senators from farm and ranch
states, have been ardent supporters of ending this kind of direct
vertical integration by prohibiting packer ownership of
livestock."

Reforming livestock markets is another one of those crucial, fundamental,
structural issues that is, in my opinion, a litmus test for the next
Secretary of Agriculture. Governor Vilsack’s track record in this area is
good, if somewhat limited. His public statements as Governor and as a
candidate for President have been supportive of livestock market reforms,
but have never figured prominently in either his campaigns or his
gubernatorial priorities. Although, to be honest, that does not separate
him from most other elected officials or public figures at this
level.

Vertical integration decreases market access for family farmers,
decreases prices paid to independent producers, and fuels the
construction of more and more CAFOs and the demise of more and more
family farms. The Senate has twice passed the legislation banning packer
ownership of livestock - in two farm bills - but both times it was
removed in conference.

During the last 12 years, three Secretaries of Agriculture have said
virtually nothing and never lifted a finger to do anything about this
issue (despite considerable authority under existing laws and myriad
opportunities in both farm bill debates). Support from the Secretary of
Agriculture and the White House could make all the difference in finally
securing this necessary reform.

At the end of the day…

It is difficult, if not impossible, to predict when, where and from whom
leadership will emerge. The book on Tom Vilsack is not complete, and
perhaps that is a good thing. He does not get a perfect score on my
litmus tests. But, when I disagree with him in the future I will continue
to engage him, just as I always have, whether he is a private citizen or
the Secretary of Agriculture. And he will engage me, just as he always
has.

I hope that, at the end of the day, our next Secretary of Agriculture is
the kind of leader that can help create a future for rural America with
thriving family farms and ranches and vibrant rural communities. I
believe Governor Vilsack can provide that leadership. Perhaps he just
might get the chance.

http://www.cfra.org/blog/2008/11/19/different-view-vilsack

–
Brian Depew, Program Director
Rural Organizing & Outreach
Center for Rural Affairs

402.687.2103 ext 1015
briand@cfra.org

145 Main Street | P.O. Box 136
Lyons, NE 68038

http://www.cfra.org/blog

http://www.cfra.org/signup
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This message originated from or was forwarded by:
Chrys Ostrander
Chrysalis Farm @ Tolstoy
Organic Micro-permaculture
33495 Mill Canyon Rd.
Davenport, WA 99122
509-725-0610
chrys@thefutureisorganic.net

http://www.thefutureisorganic.net

"From each according to their ability, to each according to
their needs"
Louis Jean Joseph Charles Blanc - "The organization of work"
1839
Karl Marx - "Critique of the Gotha Program" 1875

"The purpose of agriculture is not the production of food, but the
perfection of human beings"
Masanobu Fukuoka (February 2, 1913 - August 16, 2008)  - "One
Straw Revolution" 1978

"We will never have an organic future and a stable climate until we
pull all the troops out of Iraq
and redirect our annual $650 billion military budget to greening the
economy and guaranteeing
a sustainable environment and economic justice for everyone."
Ronnie Cummins, National Director, Organic Consumers Association
at the "Farms Not Arms" public forum and protest in Manhattan,
September, 2007

Please consider making a contribution towards my sustainable agriculture
organizing work.

https://www.paypal.com/cgi-bin/webscr?cmd=_s-xclick&hosted_button_id=424800

Thank you.

An Update on the Proposed Organic Livestock Rule from Ed Maltby,
Northeast Organic Dairy Producers Alliance Executive Director.

[Please note that Ed, always the diplomat, at times is somewhat selective

in what he communicates. I'm sure we might hear a different take on
the
proceedings related below from the Cornucopia Institute, so stay tuned.
Chrys]

[Oh, and for NODPA's initial detailed assessment of the rule, go to:

http://www.nodpa.com/pasture_rule_details_110708.shtml]

As promised, I’ll try to sum up the hectic few days in DC spent talking
with
many folks and having some great positive discussions. What was very
encouraging was the willingness of all interested groups coming from
many
different sectors of the industry to sit down together and discuss ideas
and
brainstorm together for the best possible result for our industry
and
community. For many years there hasn’t been the level of trust that
folks
will respect each other opinion’s while not necessarily agreeing with
them
but be able to conduct a civil and constructive discourse for all of
our
benefit.

Hopefully this is something that we can carry forward to other issues
and
promote an organic community working together. As I describe what
happened
at the community meetings, I will not attribute any views to any one
person.
We all agreed, as is traditional for these meetings, that what is said
at
these meetings stays in the meeting, to give folks a safe place to
exchange
ideas and opinions. We also all agreed that we would not publish our
separate ideas for changes until we have shared one more round of
conversations.

I would also like to thank all members of the NOSB for their dedication
to
the organic community. Monday night they were still hearing public
comments
up to 8:00 pm I believe, 3 hours after they should have ended. The
meeting
adjourned at 5:00 pm tonight. The NOSB members all have their own day
jobs
and family lives and freely dedicate their time to this essential,
complicated and detailed work. If you see an NOSB member past or
present,
please stop them and say thank you.

Similarly, all those that have commented on the Access to Pasture
proposed
rule have recognized the extent of the work by NOP in writing the rule
and
shepherding it through the federal review process. Richard Mathews
and
Barbara Robinson are to be congratulated on their work and, indeed,
Barbara
was correct in saying the rule would be "everything we asked for and
more."
They have written a rule with the specificity producers and USDA
lawyers
asked for and we now have to put together our comments along with
supporting data to address some practical issues. NOC and most other
groups
do not support an extension of the comment period and we are confident
that
we can address all the necessary issue in the time period.

The first community meeting on Sunday was from noon to 5:00 pm and
was
hosted by National Organic Coalition, Sustainable Agriculture Coalition
and
the Campaign for Sustainable Agriculture and attended by over 50 people.
The
first 2 hours was focused on issues as diverse as Aquaculture
standards,
"Grower Groups" TAP reviews, IFOAM and materials. If you go
to

http://nodpa.com/in_NOP_comments.shtml you can take a look at some of
these
in more detail.

From 2:00 to 5:00 pm we discussed the proposed pasture rule with input
from
everyone at the table about their opinions, not just on the actual
proposed
rule but the future of the organic label and whether it is appropriate
to
use rulemaking. We used a draft document put forward from the work of
FOOD
Farmers to highlight areas of alignment and areas that were thought to
be
too prescriptive or impractical. We floated some new wording around
some
definitions; looked at how producers are measuring Dry Matter;
practicality
of livestock care under winter conditions; difficulties and challenges
for
western producers who have a different climate and soil conditions; plus
how
certifiers and NOP could enforce the new regulations to the satisfaction
of
the USDA lawyers. There was complete agreement that NOP needs to continue
to
enforce the existing Access to Pasture standards while the new rule is
being
worked on. Increasingly, we came back to the need for accurate and
detailed
organic system plans which are the basis for all organic
certification.
While there was airing of many different viewpoints there was consensus
that
it was too early in the process to start wordsmithing and we all agreed
to
take these new ideas back to our various groups to work on.

From 5:00 - 7:00 pm, the National Organic Coalition had a private
meeting to
look at how we can continue to move the process forward with an
invigorated
and positive community interaction and ways of bringing more
consumers
groups into the dialogue.

Monday morning was the start of the NOSB meeting which was held in a hot
and
crowded room, initially without a reliable sound system. While there
were
many issue raised and comments made (all of which will be posted on the
NOP
website), I will report mostly on what Barbara Robinson, head of the
NOP
gave in her report.:

. Since May, NOP has hired 6 additional staff for a total of 15

. The 3 branches, and 3 branch chiefs are:

o Richard Mathews, Chief Standards Development & Review Branch, plus
new
employee Shannon Nally

o Mark Bradley, Chief Accreditation, Auditing, & Training
Branch

o Ruihong Guo, Branch Chief Compliance & Enforcement Branch with five
new
enforcement employees

. Richard Mathews will be leaving the program in January and there
is no news as to who will take his place.

. Barbara has only one more year left with the program and her first
priority is publishing a final Pasture Rule followed by certifier
training.

. She gave a materials update and other information around sunset
reviews and publishing of ANPR’s.

. The NOP budget had a small increase for 2009 but with the present
economic climate she had no expectation for more dollars.

. Most of the 2007 certifier renewals have been finished and they
are working on the 2008 renewals.

. Cost-share got quite a big bump and cooperative agreements have
gone out to the states. They plan to improve how NOP works with the
state’s
on cost share and improve management of that program over the next couple
of
years.

. NOP will be spending a significant amount of funding to improve
certifier training and she would like to open up the NOP and make it
available to certifiers and eventually producers, processors etc so
they
know what is necessary to be in compliance. Barbara plans that NOP will
take
every section of regulation, break it down and put it together in a CD
Rom
format which is easily updatable. There will be training seminar and
hands
on training and the NOP needs to get feedback from all of its certifiers
who
need to talk with their inspectors.

Lunch was followed by some great meetings with different
individuals;
listening to the comments session at the NOSB (making a comment on behalf
of
NODPA and FOOD Farmers myself); and a large cup of coffee before we
came
back together for the OTA sponsored meeting from 5:30 to 8:00 pm. Again
the
room was full with all the diverse interest groups and the intent of
this
meeting was to take the conversation to the next level by looking at
areas
of alignment and then discuss our ideas around some issues that we
knew
would be troublesome. We decided that we would not be making any
position
statements but rather looking forward to the next stage of our work
together. We heard from consumer groups about their thoughts on the
future
of the organic label with beef and their initial assessment of how
this
proposed rule might affect the consumer confidence and growth of the
sector.
Other themes were around the paper work burden for small operations and
how
we can mitigate some of that without losing the specificity required by
USDA
counsel to enforce the standards. Conversations were open and frank with
a
high level of trust that everyone was meeting together in good faith.
The
OTA Task force pledged to continue their work and share conclusions
with
others in the community. Sometime after 8:00 we sought the solace of
a
reasonable restaurant to debrief.

Tuesday was spent in meetings "on the hill" which were all
productive and
gave us an opportunity to explain our positions directly to legislators
and
their staff. We also wanted to make sure that the Democratic transition
team
knew the importance of the pasture rule to producers, processors and
consumers and that they should give it the "green light" to
move forward. I
found that the cheapest place to eat in DC is the House cafeteria where
I
met my congress person eating his breakfast, I don’t think I gave
him
indigestion when I asked him to help move the rule forward in whatever
way
he could. He, of course, pledged his ongoing support.

I hope that this gives an insight into what happens at these meeting and
I
want to thank Kathie Arnold for making the long drive down to DC to lead
and
take part in the discussions. Her knowledge and dedication to bring
the
community together around this issue is a shining example for
everyone.

Ed

Ed Maltby
Northeast Organic Dairy Producers Alliance
Executive Director
30 Keets Rd
Deerfield, MA 01342
Tel: 413-772-0444
Cell: 413-427-7323
Fax: 866-554-9483
Website:
www.nodpa.com or

www.organicmilk.org

Sustainable base pay-price; level playing field; organic
integrity

Thinking of transitioning to organic dairy?

Got questions on Organic Dairy?

Contact NODPA first and get the independent, unbiased facts.

The purpose of the NODPA is to enable organic dairy family farms,
situated
across an extensive area, to maintain the sustainability of organic
dairy
farming.

Do you really need to print this e-mail?

This message originated from or was forwarded by:
Chrys Ostrander
Chrysalis Farm @ Tolstoy
Organic Micro-permaculture
33495 Mill Canyon Rd.
Davenport, WA 99122
509-725-0610
chrys@thefutureisorganic.net

http://www.thefutureisorganic.net

"From each according to their ability, to each according to
their needs"
Louis Jean Joseph Charles Blanc - "The organization of work"
1839
Karl Marx - "Critique of the Gotha Program" 1875

"The purpose of agriculture is not the production of food, but the
perfection of human beings"
Masanobu Fukuoka (February 2, 1913 - August 16, 2008)  - "One
Straw Revolution" 1978

"We will never have an organic future and a stable climate until we
pull all the troops out of Iraq
and redirect our annual $650 billion military budget to greening the
economy and guaranteeing
a sustainable environment and economic justice for everyone."
Ronnie Cummins, National Director, Organic Consumers Association
at the "Farms Not Arms" public forum and protest in Manhattan,
September, 2007

Please consider making a contribution towards my sustainable agriculture
organizing work.

https://www.paypal.com/cgi-bin/webscr?cmd=_s-xclick&hosted_button_id=424800

Thank you.

Dear [Odairy@yahoogroups.com] list -

I thought dairy farmers might be interested in a short report from the
National Organic Standards Board meeting currently going on in Washington,
D.C.

First, the National Organic Standards Board will not be considering the
newly released rule pertaining to pasture and livestock. Even though this
is arguably the most extensive rewrite of the organic standards since they
were adopted, this will not be weighed, debated or even discussed by our
expert citizen advisors to the USDA on the NOSB.

Second, there have two meetings outside of the NOSB where the proposed rule
has been the subject of intense discussion. As was mentioned earlier on
this list, both the National Organic Coalition/National Campaign for
Sustainable Agriculture (on Sunday) and the Organic Trade Association (on
Monday night) held gatherings to review the rule.

A number of concerns about the proposal were raised at both meetings and it
is clear that many farmers and citizen groups are still trying to figure out
the breadth and impact of the proposal. The proposal contains many clearly
identified objectionable and/or impractical pieces that have to be changed
– a number of these needed changes are seemingly agreed on by many of the
parties involved in these discussions. But there are other critical areas
of continuing dispute. The listing of these would be considerable and I
will leave that for future communications but it is clear that farmers truly
need to examine this rule and assess its impact on there operations.

This rule may dramatically impact you and your farming operation!!!

I must also comment on who was sitting at the table during these
discussions. At both the NOC/NCSA meeting and the Organic Trade Association
meeting, the fox was sitting in the room with all of us hens.
Representatives from the largest factory farm dairies were present. Some
may think that is OK, we don’t.

Now I am really not concerned that they were at the OTA meeting, that is,
after all, more their venue and they are some of the largest dues paying
members. In fact, the OTA meeting was mostly chaired by a representative of
the largest dairy processor in the United States, a company that owns a
giant industrial dairy and is buying a significant part of its milk from
factory farm dairies.

I can tell you that at both meetings, all of the citizen groups, small
farmers, certifiers and retail interests were pumped for and encouraged to
express their particular concerns about the rule. But the representatives
of the factory farm interests expressed almost no views on the rule as to
how it would affect their particular dairy operations. I directly asked for
their views at the OTA meeting and my question was met with instant
hostility and left unanswered.

Folks, we wouldn’t be sitting here today debating the issue of and perceived
need for a new rule if it weren’t for the abuses of the existing rule by the
now 14-17 operating factory farms with 2000+ cow herds. The vast majority
of family farm dairies are following the spirit and intent of the organic
law. Furthermore, we wouldn’t be watching the continued compression of pay
price and income if it weren’t for the millions of gallons of fluid milk
being dumped on the organic market by the factory dairies— we estimate
this makes up 30-40% of the current organic milk market!

Will this rule proposal change this? How will it impact your dairy?

The last thing I will note is that it is even more unclear that the primary
author of the draft rule, Richard Matthews, will be around to see this to
conclusion. He is retiring at year’s end. Earlier, some of us thought that
he would be kept on as a contractor/consultant to oversee whatever comes out
of this process. Last night he told others that he would not be staying on
next year.

All in all, this is a murky mess and no matter what else we communicate to
the USDA about the draft rule we should all, in unison, be demanding strict
enforcement of the CURRENT regulations.

- Will Fantle

The Cornucopia Institute
608-625-2042 Voice
866-861-2214 Fax
P.O. Box 126
Cornucopia, Wisconsin 54827
www.cornucopia.org

This message originated from or was forwarded by:
Chrys Ostrander
Chrysalis Farm @ Tolstoy
Organic Micro-permaculture
33495 Mill Canyon Rd.
Davenport, WA 99122
509-725-0610
chrys@thefutureisorganic.net
http://www.thefutureisorganic.net

“From each according to their ability, to each according to their needs”
Louis Jean Joseph Charles Blanc - “The organization of work” 1839
Karl Marx - “Critique of the Gotha Program” 1875

“The purpose of agriculture is not the production of food, but the
perfection of human beings”
Masanobu Fukuoka (February 2, 1913 - August 16, 2008) - “One Straw
Revolution” 1978

“We will never have an organic future and a stable climate until we
pull all the troops out of Iraq
and redirect our annual $650 billion military budget to greening the
economy and guaranteeing
a sustainable environment and economic justice for everyone.”
Ronnie Cummins, National Director, Organic Consumers Association
at the “Farms Not Arms” public forum and protest in Manhattan, September, 2007

Please consider making a contribution towards my sustainable
agriculture organizing work.
https://www.paypal.com/cgi-bin/webscr?cmd=_s-xclick&hosted_button_id=424800

Thank you.

Hi Jill, Folks,

In response to Jill’s call for us to send in “comments in favor of
these proposed [organic livestock] rules”, I want to really caution
anyone about sending in comments “in favor” of the new proposed
rules. This is a massively complex proposed rule that has many organic
producers and advocates deeply concerned. There are some provisions that
are very good and long overdue. There are others, however, that appear to
be deeply flawed. Rather than anyone sending in blanket support for this
rule, we really should follow the lead of folks who are “in the
know” about what this rule really says, and what the impact of some
of the provisions would be, and tailor our comments accordingly.
Organizations like the Organic Farming Research Foundation, the National
Organic Coalition, the CROPP Co-op (Organic Valley) are still studying
the proposals and receiving input from producers and consumers before
they formulate specific comments on the rule. Initial press releases from
organic advocacy groups that came out at the time the proposed rule was
released in October, were supportive, however, as folks have had time to
carefully read the proposals, concerns are arising. Probably the best
thing to advocate for at this point, even though we’ve already waited too
long for this process to proceed, is an extension of the comment period
to allow the organic community to more carefully review the proposals and
draft revisions. When these organic advocates and our producer allies
have specific revisions available for us to review, that’s when we should
submit our comments and reiterate the revisions being sought by our more
knowledgeable allies.

Chrys

At 10:59 AM 11/18/2008, Jill Richardson wrote:

To comment, go here:

http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&o=0900006480776e33

If the link doesn’t work, go to Regulations.gov and it’s docket
AMS-TM-06-0198 (docket type:
rulemaking, document ID: AMS-TM-06-0198-0001)

Please, please send in comments in favor of these proposed rules and if
you work with an organization that has an email list, get the word out
for others to send in comments as well.

Thanks,
Jill

SUBSCRIBING AND UNSUBSCRIBING TO
COMFOOD:

You can subscribe to COMFOOD by going here:

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This message originated from or was forwarded by:
Chrys Ostrander
Chrysalis Farm @ Tolstoy
Organic Micro-permaculture
33495 Mill Canyon Rd.
Davenport, WA 99122
509-725-0610
chrys@thefutureisorganic.net

http://www.thefutureisorganic.net

“From each according to their ability, to each according to
their needs”
Louis Jean Joseph Charles Blanc - “The organization of work”
1839
Karl Marx - “Critique of the Gotha Program” 1875

“The purpose of agriculture is not the production of food, but the
perfection of human beings”
Masanobu Fukuoka (February 2, 1913 - August 16, 2008)  - “One
Straw Revolution” 1978

“We will never have an organic future and a stable climate until we
pull all the troops out of Iraq
and redirect our annual $650 billion military budget to greening the
economy and guaranteeing
a sustainable environment and economic justice for everyone.”
Ronnie Cummins, National Director, Organic Consumers Association
at the “Farms Not Arms” public forum and protest in Manhattan,
September, 2007

Please consider making a contribution towards my sustainable agriculture
organizing work.

https://www.paypal.com/cgi-bin/webscr?cmd=_s-xclick&hosted_button_id=424800

Thank you.

Date: Sun, 16 Nov 2008 22:11:04
-0800
From: "Naomi Starkman" <nstarkman@gmail.com>
To: comfood@elist.tufts.edu
Subject: [COMFOOD:] NYT Editorial: Our Home-Grown Melamine
Problem

http://www.nytimes.com/2008/11/17/opinion/17mcwilliams.html
 
November 17, 2008
Op-Ed Columnist

Our Home-Grown Melamine Problem

By JAMES E. McWILLIAMS

Austin, Tex.

CHINA’S food supply appears to be awash in the industrial chemical
melamine. Dangerous levels have been detected not only in milk and eggs,
but also in chicken feed and wheat gluten, meaning that melamine is
almost impossible to avoid in processed foods. Melamine in baby formula
has killed at least four infants in China and sickened tens of thousands
more.

In response, the United States has blasted lax Chinese regulations, while
the Food and Drug Administration, in a rare move, announced last week
that Chinese food products containing milk would be detained at the
border until they were proved safe.

For all the outrage about Chinese melamine, what American consumers and
government agencies have studiously failed to scrutinize is how much
melamine has pervaded our own food system. In casting stones, we’ve
forgotten that our own house has more than its share of exposed glass.

To be sure, in China some food manufacturers deliberately added melamine
to products to increase profits. Makers of baby formula, for example,
watered down their product, lowering the amount of protein and nutrients,
then added melamine, which is cheap and fools tests measuring protein
levels.

But melamine is also integral to the material life of any industrialized
society. It’s a common ingredient in cleaning products, waterproof
plywood, plastic compounds, cement, ink and fire-retardant paint.
Chemical plants throughout the United States produce millions of pounds
of melamine a year.

Given the pervasiveness of melamine, it’s always possible that trace
elements will end up in food. The F.D.A. thus sets the legal limit for
melamine in food at 2.5 parts per million. This amount is indeed
minuscule, a couple of sand grains in an expanse of desert that pose no
real threat to public health. Moreover, the 2.5 p.p.m. figure is
calculated for a person weighing 132 pounds - a cautious benchmark given
that the average adult weighs 150 to 180 pounds.

But these figures obscure more than they reveal. First, while adults eat
about one-fortieth of their weight every day, toddlers consume closer to
one-tenth. Although scientists haven’t measured the differential impact
of melamine on infants versus adults, it’s likely that this intensified
ratio would at least double (if not quadruple) the impact of legal levels
of melamine on toddlers.

This doubled exposure might not land a child in the hospital, but it
could certainly contribute to the long-term kidney and liver problems
that we know are caused by chronic exposure to melamine.

On a more concrete note, melamine not only has widespread industrial
applications, but is also used to buttress the foundation of American
agriculture.

Fertilizer companies commonly add melamine to their products because it
helps control the rate at which nitrogen seeps into soil, thereby
allowing the farmer to get more nutrient bang for the fertilizer buck.
But the government doesn’t regulate how much melamine is applied to the
soil. This melamine accumulates as salt crystals in the ground, tainting
the soil through which American food sucks up American nutrients.

A related area of agricultural concern is animal feed. Chinese eggs
seized last month in Hong Kong, for instance, contained elevated levels
of melamine because of the melamine-laden wheat gluten used in the feed
for the chickens that produced the eggs.

To think American consumers are immune to this unscrupulous behavior is
to ignore the Byzantine reality of the global gluten trade. Tracking the
flow of wheat gluten around the world, much less evaluating its quality,
is like trying to contain a drop of dye in a churning whirlpool.

More ominous, the United States imports most of its wheat gluten. Last
year, for instance, the F.D.A. reported that millions of Americans had
eaten chicken fattened on feed with melamine-tainted gluten imported from
China. Around the same time, Tyson Foods slaughtered and processed hogs
that had eaten melamine-contaminated feed. The government decided not to
recall the meat.

Only a week earlier, however, the F.D.A. had announced that thousands of
cats and dogs had died from melamine-laden pet food. This high-profile
pet scandal did not prove to be a spur to reform so much as a red
herring. Our attention was diverted to Fido and away from the animals we
happen to kill and eat rather than spoil.

Frightening as this all sounds, the concerned consumer is not completely
helpless. We can seek out organic foods, which are grown with fertilizer
without melamine - unless that fertilizer was composted with manure from
animals fed melamine-laden feed (always possible, as the Tyson example
suggests).

We could further protect ourselves by choosing meat from grass-fed or
truly free-range animals, assuming the grass was not fertilized with a
conventional product (something that’s also very hard to know).

But as all the caveats above indicate, these precautions will only go so
far. Melamine, after all, points to the much larger relationship between
industrial waste and American food production. Regulations might be lax
when it comes to animal feed and fertilizer in China, but take a closer
look at similar regulations in the United States and it becomes clear
that they’re vague enough to allow industries to "recycle" much
of their waste into fertilizer and other products that form the basis of
our domestic food supply.

As a result, toxic chemicals routinely enter our agricultural system
through the back channels of this under-explored but insidious
relationship.

So, sure, let’s keep the heat on China. And, yes, let’s take with a big
dose of skepticism the Chinese government’s assurances that they’re
improving the food supply.

At the same time, though, instead of delivering righteous condemnation,
the United States should seize upon the melamine scandal as an
opportunity to pass federal fertilizer standards backed by consistent
testing for this compound, which could very well be hidden in plain
sight.

James E. McWilliams, a history professor at Texas State University at San
Marcos, is the author of "American Pests: The Losing War on Insects
From Colonial Times to DDT."

SUBSCRIBING AND UNSUBSCRIBING TO COMFOOD:

You can subscribe to COMFOOD by going here:     

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You can unsubscribe to COMFOOD by going here : 

https://elist.tufts.edu/wws/signoff/comfood

This message originated from or was forwarded by:
Chrys Ostrander
Chrysalis Farm @ Tolstoy
Organic Micro-permaculture
33495 Mill Canyon Rd.
Davenport, WA 99122
509-725-0610
chrys@thefutureisorganic.net

http://www.thefutureisorganic.net

"From each according to their ability, to each according to
their needs"
Louis Jean Joseph Charles Blanc - "The organization of work"
1839
Karl Marx - "Critique of the Gotha Program" 1875

"The purpose of agriculture is not the production of food, but the
perfection of human beings"
Masanobu Fukuoka (February 2, 1913 - August 16, 2008)  - "One
Straw Revolution" 1978

"We will never have an organic future and a stable climate until we
pull all the troops out of Iraq
and redirect our annual $650 billion military budget to greening the
economy and guaranteeing
a sustainable environment and economic justice for everyone."
Ronnie Cummins, National Director, Organic Consumers Association
at the "Farms Not Arms" public forum and protest in Manhattan,
September, 2007

Please consider making a contribution towards my sustainable agriculture
organizing work.

https://www.paypal.com/cgi-bin/webscr?cmd=_s-xclick&hosted_button_id=424800

Thank you.