Completed Action Alerts Archive

Close the Loophole Allowing Conventional Cows on Organic Farms

Sunday, June 21st, 2015

The comment period is closed.

[UPDATED] Comment by July 27

Origin of Livestock – Proposed Rule

One of Aurora’s “organic” dairies, each managing many thousands of cows (producing private label milk for Walmart, Costco, Target and others)

In April 2010, the USDA National Organic Program’s new director, Miles McEvoy, promised that releasing a tightened set of rules on the organic origin of livestock would be a “top priority.” Now, over five years later, a draft rule has finally been released — and it’s likely to be at least two more years until this goes into effect. That’s seven years since Mr. McEvoy declared its prominence, which was also the rhetoric from the USDA in the last years of the Bush administration.

The USDA’s stated intent is to tighten the rules that govern how conventionally raised livestock can be brought into organic production systems, but major loopholes remain. These loopholes could allow significant abuses to continue to the detriment of organic family farmers, who follow the spirit and letter of the law, and their loyal organic customers seeking authentic organic food. Read Full Article »

Nominations Open for Five Vacancies on the National Organic Standards Board

Wednesday, June 3rd, 2015

[This action alert is now closed]

Application Deadline is June 17

500px-USDA_organic_seal_svg - wikicommonsTwo positions for organic farmers are among the five vacancies the USDA is seeking to fill on the National Organic Standards Board (NOSB).  Appointees will serve a five-year term beginning in January 2016.  Vacancies for the 15-mem­ber organic advisory board must represent a particular constituency as identified by Congress, and the current openings are for:

  • Two (2) organic farmers/ producers,
  • Two (2) public or consumer interest group representatives, and
  • One (1) USDA accredited certifying agent.

The NOSB is responsible for determining allowed and prohibited substances/inputs used in organic agricultural production and food, as well as advising the USDA Secretary on organic regulations and policy.

If you are interested in applying for one of the vacancies, click here for detailed instructions.  Individuals can nominate themselves for one of the appropriate slots.  Nominations must be postmarked by June 17. Read Full Article »

Tell the USDA to Support Stronger Conservation of Biodiversity in Organic Agriculture Systems

Tuesday, February 17th, 2015

[This action alert has been completed. The comment period is now closed.]

Comments Due by February 27, 2015

Source: USDA

Long held principles of organic farming commonly articulate values and goals that link organic farms with protection of biodiversity. “Organic production” is defined in federal regulations as a “production system that is managed to respond to site-specific conditions by integrating cultural, biological and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity.” [Emphasis added.]

Over the years, the National Organic Standards Board has issued guidance statements and has urged the USDA’s National Organic Program to strengthen biodiversity conservation by issuing formal, enforceable guidance.  (Adapted from “Implementation of Biodiversity Conservation in Organic Agriculture Systems, NOSB March 5, 2009.)

The National Organic Program has now issued a Guidance that applies to all phases of the organic system, including both the production and handling/processing of organic food.  This proposed Guidance to conserve biodiversity is a significant step forward, but needs further strengthening.  Please show your support for the following key points.

Click here to submit your electronic comments by February 27. Read Full Article »

Food Safety Petition and Action Alert

Friday, December 5th, 2014

[This alert is over–comment period now closed]

Food Safety Modernization Act: New Draft Rules
Comments Due on December 15 to FDA

FDA3Please take action by reading the full Action Alert available on the Cornucopia website:

Although improved over the first draft the FDA’s proposed food safety rules are still onerous enough that they could jeopardize the existence of many of our safest, local organic farms.

Tell the FDA that small farms are not food processing “facilities” necessitating expensive oversight and testing. (It could cost a family farm over $12,000 a year to comply!). Irrigation water should not have to meet the same safety standards as a community swimming pool. And it should be clear that older farmers, without Internet access, or the Amish, can submit reports on paper rather than the web.

At a minimum, please join farmers and their urban-allies by signing on to the letter below. Additionally, we especially encourage fresh market vegetable farmers to also, very carefully, read the full action alert and submit your individual comments, based on your own farming experience, to the FDA. Your livelihoods are at stake.

TO: The Food and Drug Administration
RE: FSMA Food Safety Rules, Dockets FDA-2011-N-0921-0973 and FDA-2011-N-0920-1553
We the undersigned are concerned by several areas of the FDA’s revised food safety rules and endorse the following comments.

  • The cost to farmers for implementing the proposed rules will endanger the livelihoods of organic farmers and their customers’ access to safe and nutritionally superior local and organic food. This regulatory burden, as much as $12,384 for farms with sales of $500,000 or less, is an unacceptable imposition of financial hardship on producers with no history of food safety problems.
  • Farms are not facilities. Growing, harvesting, packing, or holding raw agricultural commodities are clearly part of many farm activities. Furthermore, the regulations should allow for non-contiguous farm parcel locations to be treated as one farm and not discriminate against cooperatives or food hubs.
  • The FDA must clarify that CSAs and direct market farmers are not facilities.
  • The proposed use of the EPA’s recreational water standard is an inappropriate and overly restrictive measure for testing the safety of irrigation water. Before establishing a numeric testing standard for the safety of irrigation water, the FDA must conduct a risk assessment for water used specifically for agricultural purposes, and follow the instructions from Congress that a science and risk-based approach be used for regulation.
  • Recordkeeping requirements should be reasonable, limited to one year, and allow for paper records.
  • The FDA must establish a fair process for any enforcement actions against farmers that allows due process, full documentation of any alleged food safety issues, and the opportunity for a hearing to contest erroneous information.
  • The FDA must respect the exemption from the food safety rules for smaller farms, as guaranteed by the Tester-Hagan amendment. That exemption must be determined by the level of sales of produce covered by the rule, not the total sale of all food grown and raised on a farm.
  • On-farm conservation practices need explicit support in the food safety rules. The grazing of livestock must not be considered manure application.
  • The FDA’s proposed changes made to the manure handling regulations are a needed improvement. The study committee that will be established to assess the risks of manure usage must include sustainable and organic farmers.
  • The FDA should remove the supplier verification program from the Hazard Analysis and Risk-Based Preventive Control (HARPC) food safety rule. This backdoor approach would allow for large produce buyers to impose more stringent and costly food safety regulations than outlined in the FDA’s proposed rules.
  • The FDA’s new definition of a small business is an improvement over previous proposals.

* denotes a require field

Thank you for your help! 

If you are interested in doing even more, please read the full action alert below: Read Full Article »

Action Alert — Food Safety Modernization Act: New Draft Rules Comments Due on December 15

Friday, December 5th, 2014

FDA3[This alert is over–comment period now closed]

In response to recent widespread, and sometimes deadly, outbreaks of foodborne illness, Congress passed the Food Safety Modernization Act (FSMA) charging the Food and Drug Administration (FDA) with improving their oversight of the food industry.

But the intense blowback the FDA received last year from family-scale farmers and consumers over their proposed food safety rules for produce led the agency to withdraw and rewrite their proposed rules. Your comments last year had an impact!

The FDA has now released their new draft, which addresses many of the objections. However, a number of problems and pitfalls for farmers remain in the new draft. The proposal will also be of interest to the customers of local, organic food purchased through farmers markets, CSAs and co-op grocers.

Public comments are due by December 15 on the draft rules.

The Cornucopia Institute, working with other groups, has requested a 90-day extension to allow for fuller and careful analysis of the latest proposal.

You can comment online, but be sure to do so at both of these locations as the regulations impacting family scale farmers are intertwined in both of these FDA dockets:!submitComment;D=FDA-2011-N-0921-0973!submitComment;D=FDA-2011-N-0920-1553

Or you can comment by mail to Division of Dockets Management (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852. Make sure you note that you are commenting on dockets FDA-2011-N-0921-0973 and FDA-2011-N-0920-1553. Your letter needs to be postmarked no later than December 15.

According to the analysis performed by the National Sustainable Agriculture Coalition, growers with sales up to $500,000 would likely spend 4% to 6% of their gross revenue to comply with the new food safety rules.  For small farms, FSMA could consume more than half of their modest profits. It is important that family-scale farmers producing our nation’s fda2best and safest produce be protected from unnecessary and onerous regulations — this could put some farmers out of business and/or reduce the availability of organic and local food and/or increase pricing.

Key Points to Mention in Your Comments:

  • Tell the FDA that the cost to farmers for implementing the proposed rules will endanger the livelihoods of organic farmers and their customers’ access to safe and nutritionally superior local and organic food.

Read Full Article »