Heartland Institute Reacts to
New Federal Organic Certification Rule
The U.S. Department of Agriculture this month entered into the Federal Register a new rule requiring organizations that certify organic producers to annually test residue on at least 5 percent of organic farms. The tests, estimated to cost $500 each, would be paid for by the certifying organizations, not their clients. The rule goes into effect in 2013.
The following statement from Mischa Popoff, policy advisor to The Heartland Institute and former advanced organic farm and process inspector, maybe used for attribution. For more comments, refer to the contact information below. To book a Heartland guest on your program, please contact Tammy Nash at email@example.com and 312/377-4000. After regular business hours, contact Jim Lakely at firstname.lastname@example.org and 312/731-9364.
"The USDA recently announced plans to begin testing 5 percent of the farms and processors it certifies under its decade-old National Organic Program. [Federal Register Volume 77, Number 218 (Friday, November 9, 2012) Rules and Regulations, pages 67239-67251, from the Federal Register Online via the Government Printing Office at www.gpo.gov, FR Doc No: 2012-27378.] But in the interests of keeping organic food in America as pure and as nutritious as possible, we at Heartland have to ask: What about the other 95 percent?
"Of the 5 percent of farms and processors the USDA plans to test, officials say they will require that some of them are subjected to pre-harvest testing. But surely it would be advisable to do mostly pre-harvest testing. After all, the benefits of organic production all occur in the field. So what better way to ensure that organic crops and livestock are indeed purer and more nutritious than to do all testing in the field?
"With the exception of genetically modified organisms, almost everything that’s prohibited in organic production dissipates and in many cases becomes undetectable over time. So there’s little point wasting time or money testing organic crops post-harvest. In order to prevent cheating in the organic industry, all testing – not just some of it – must occur prior to harvest. This is what Dr. Jay Lehr, science director at The Heartland Institute), and I refer to as field-testing in a three-part series of articles we wrote for the Heartlander digital magazine (see here, here, and here.)
"Whether it’s herbicides, pesticides, hormones, improperly composted manure, or the big money-maker, synthetic ammonium nitrate, only an unannounced inspection and field test will deter fraud and gross negligence in the multibillion-dollar organic sector. And the concern for potential for fraud and gross negligence only grows when one considers the great amount of organic food that’s imported into the United States every year, under USDA oversight, from countries like China, Mexico, and Brazil.
"Consider that Olympic athletes are tested before and during the games, not after. And the good news in the case of organic farming is that doing such tests in the field – 100 percent of the time instead of just 5 percent of the time – will drastically reduce a farmer’s cost of being certified, because field-testing costs about one-tenth what the current system of record-keeping and record-checking costs.
"But for some reason I cannot fathom, the USDA seems intent on adding organic field-testing to the existing system of record-keeping and record-checking, a bureaucratic system that costs upwards of $2,000 upfront, per farm, per year. Heartland urges the USDA to instead begin to replace record-keeping and record-checking with annual field-testing, thereby bringing down the cost of organic certification.
"USDA officials claim the cost of this new plan will be about $500 per test. But a broad-spectrum herbicide analysis costs just $125. And surely a certifier providing USDA-certification to multiple organic farmers and processors will be able to get an even better price than that. And what about testing for fecal coliforms? That costs just $16 per test, money well-spent when one considers the risks inherent in improperly composted manure.
"The Heartland Institute does not suggest testing for everything every year on every organic entity the USDA certifies. As long as the party being inspected doesn’t know what’s being tested for, a broad-spectrum herbicide analysis or a fecal coliform test, or any of a host of other inexpensive tests, would suffice to prove or disprove a farmer’s or processor’s adherence to the USDA’s NOP and keep everyone honest.
"Lastly, there remains the outstanding issue of ‘royalties’ being collected by USDA-accredited certifiers. How can anyone expect private, for-profit companies that oversee the USDA NOP to be objective as long as they continue to collect 1 to 3 percent of a farmer’s gross revenue from each transaction they certify? Organic field-testing must be carried out by independent inspectors, not by certifiers that have a vested interest in pushing more product to market."
The Heartland Institute is a 28-year-old national nonprofit organization headquartered in Chicago, Illinois. Its mission is to discover, develop, and promote free-market solutions to social and economic problems. For more information, visit our Web site or call 312/377-4000.
November 15, 2012