Organic Consumers Association: Suggested Comment Letter
on Proposed National Organic Standards (Docket # TMD-00-02-PR)

Note: If you wish to let the USDA know by email what you think of their
March, 2000 proposed National Organic Standards, please send your comments
to the Organic Consumers Association at <info@organicconsumers.org> and we
will forward these on to the USDA. Or you may also go to the USDA website
at http://www.ams.usda.gov/nop and enter your comments there.

To send comments by fax to the USDA: 703-365-0760
To send comments by regular mail: Keith Jones, National Organic Program,
USDA-AMS-TMP-NOP, Room 2945-So., Ag Stop 0275, PO Box 96456, Washington,
D.C. 20090-6456

The 90 day comment period ends on June 12, 2000. Below is our basic
recommendation for what you should tell the USDA. Further information is
available in BioDemocracy News #25 posted along with other information on
our website <http://www.purefood.org>
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Dear USDA National Organic Program,

Although the USDA's March, 2000 proposed National Organic Standards are a
vast improvement over the first proposed rules issued in December, 1997, as
an organic consumer I am very concerned that the USDA adhere to the
following principles:

(1) Do not weaken or dilute any of the proposed organic rules published in
the USDA's March 2000 document in any manner whatsoever.

(2) Private (i.e. non-governmental) and state organic certifiers must have
the legal right to exercise their free speech and certify and label
products to higher or stricter standards than the minimum "USDA Certified
Organic" standards and be able to state on their label that this product
"meets or exceeds" or "exceeds" USDA organic standards.

(3) So-called "natural foods" with less than 50% organic ingredients should
not be allowed to use the word "organic" anywhere on their package or
product labels--given that the the non-organic ingredients of these
so-called "natural" products may be genetically engineered, irradiated,
derived from sewage sludge, or produced with pesticides, growth hormones,
or antibiotics.

(4) Although the proposed regulations on organic animal husbandry require
"access to outdoors," no clear definition of what constitutes "pasture" are
offered, nor does the USDA delineate exact space or spacing requirements
for humane housing and outdoor access for poultry, pigs, cattle, and other
animals.

(5) Although the USDA claim they don't intend to impose economic hardships
on organic certifiers and farmers, the added costs of USDA oversight will
fall heavily on small certifiers and farmers. The USDA should provide
accreditation services to organic certifiers free of change as well as
subsidize 100% of the costs of any farmer who wishes to become certified as
organic. Beyond this the USDA should allocate funds to pay farmers a
premium price for their products during their "transition to organic" phase
as an added incentive for the majority of farmers to begin making the
transition to sustainable and organic farming practices.

(6) Although genetic contamination of organic crops by "genetic drift" from
farms growing genetically engineered crops is one of the most serious
environmental threats to organic agriculture, no liability provisions nor
residue limits for genetic contamination are delineated in the USDA's
proposed federal regulations. The USDA must hold biotechnology patent
holders and seed companies accountable and financially liable for the
environmental and economic damage inflicted on organic farmers and
producers caused by genetic drift.