Current organic standards lack strong language to address animal welfare on farms; as a result, factory farms are producing certified organic meat, eggs and milk. Some poultry operations, for example, house tens of thousands of chickens in buildings with tiny concrete porches — so small that they often accommodate less than 1% of the building’s chickens, and often accessible by one single small door in the corner of the house — and that supposedly counts as legally required “access to the outdoors.”

This is just one example of how the current organic standards do not adequately address animal welfare.

While factory farm livestock producers have profited from the weak organic rules, the majority of family-scale organic farms — ethical producers who are true to organic principles — have been faced with resulting unfair economic competition in the marketplace.

The Livestock Committee of the National Organic Standards Board (NOSB), the citizen expert panel that recommends changes to the organic standards, appropriately decided to act on the gaping inadequacy in the regulations. They developed a set of recommendations to improve animal welfare through stronger standards. They plan to offer these recommendations to the full NOSB board for a vote at their November meeting in Washington, D.C.

The Cornucopia Institute supports their initiative. We agree with the NOSB’s Livestock Committee that animal welfare is a basic principle of organic production, and that stronger regulation is needed. Industrial-scale producers — especially in dairy and poultry — have taken advantage of the vagueness of the rules for too long. Some industrial-style dairies are milking as many as 7200 cows.

But while stronger animal welfare regulations are long overdue, the recommendations as currently written contain weaknesses that could result in unnecessary loopholes for factory farm producers. Some of these weaknesses are identified below.

Since animal welfare regulations will affect all organic livestock producers, we believe that the Livestock Committee should invite and consider input from all stakeholders before sending final recommendations to the Secretary of Agriculture.

We encourage you to read the recommendations and submit comments (instructions below). In your comments, please urge the NOSB to either hold off on voting on final recommendations until all stakeholders have been invited to comment, and these comments have been reviewed, considered, and incorporated where appropriate, or to secure a commitment from USDA leadership that a draft rule will not be published until adequate input from the public has been gathered.

Needless to say, factory farm operators will fight any recommendations that will benefit animal welfare at the expense of their large-scale production model and profits. They will likely use the usual arguments — that animals are safer inside buildings where they are protected from predators, that animals are better off inside where they are sheltered from diseases and parasites carried by wildlife, that food safety is better controlled when animals are continually confined, etc. Therefore, it is important to let the NOSB know that you support stronger animal welfare regulations that are true to organic principles.

Taking Action is Easy:

Submit your comment to the National Organic Standards Board members.

Comments may be submitted via the Internet at www.regulations.gov until 11:59 p.m. EDT on October 19, 2009. The process is less complicated than it seems at first; simply follow the steps below.

1. To submit a comment, go to www.regulations.gov.
Under “Select Document Type,” choose “Notices”
Under “Enter Keyword or ID,” type in “AMS-TM-09-0060″
Click “Go.”

2. You will see one search result, titled “Notice of the Meeting of the National Organic Standards Board.  “On the right side, there is a blue link, “Submit a comment.” Click on this link.

3. You may now enter your comment. The comment box is not large enough for the full sample letter. To use our sample letter, attach this file to the comment page (save it to your computer, and on the comment page click “browse”, find the document, and click “attach”). Remember that personalized letters carry more weight than form letters, so we encourage you to write your own comment in – either by editing the sample letter or typing in the comment box. You can also email cultivate@cornucopia.org to receive the formal comments submitted by The Cornucopia Institute.

Sample Message to the NOSB
(please cut and paste and feel free to edit)

Dear NOSB members,

I welcome and support the Livestock Committee’s initiative to strengthen the organic standards for improved animal welfare. Clear, concise and quantitative standards to support animal welfare are long overdue, and I urge the NOSB to work diligently toward stronger regulations.

While the recommendations will clearly result in improved animal welfare on organic operations, some weaknesses in the proposal should be addressed before recommendations are finalized and forwarded to the Secretary of Agriculture.

I believe that organic producers and other stakeholders should have the opportunity to review the recommendations and share input. The Livestock Committee shared their recommendations with the public on September 14, and comments are due October 19 — giving the public little over a month to review the proposal and provide input (the tight timeframe did not allow for adequate two-way communications within the community or communication with farmers without e-mail access). Moreover, while the Livestock Committee consulted with experts on animal welfare and visited several organic farm operations, the Committee did not solicit input from organic farmers and ranchers.

Since any change in the organic standards will likely affect all organic livestock producers, we request a stronger collaboration between the NOSB and all organic stakeholders. We encourage the NOSB to vote on the recommendations only after input from organic stakeholders has been requested, reviewed and incorporated where appropriate. That being said I would respectfully request that this input be solicited and incorporated on an expedited basis with a finalized proposal ready to be voted on at the next NOSB meeting.

Improvements needed in the recommendations include, but are not limited to:

1. The minority opinion that dairy cows should not be milked more than two times per day should be included into the recommendations. Milking three times per day, an integral element in high-production operations, causes unnecessary stress, health problems and substantially shortens the animal’s life. As the minority opinion pointed out, this shortened life span and unnecessary stress “are too high a price for her to pay on an organic dairy.”

2. Factors other than space requirements must be considered to ensure meaningful outdoor access, such as adequate entry/exit popholes (doors) for chickens. There are currently poultry houses that have one or two doors for tens of thousands of chickens; even if these operations were to offer the required outdoor space per bird, this would be meaningless without adequate entry/exit doors. I suggest that the Board review and consider the European organic standards’ pophole requirements: “at least 4 m per 100 m2 area of the house available to the birds.” Moreover, the current recommendations for outdoor access for poultry includes the phrase “or other exercise area,” which could be interpreted by industrial-scale producers as a concrete porch, or other inappropriate and unsatisfactory alternatives. I urge the NOSB to delete this phrase from the recommendations. The recommendation should read: “Poultry reared in houses shall have complete access to water and pasture or open-air runs subject to the species, weather, parasites, predators, and ground conditions, and shall have such access for a minimum of one third of their life.”

3. Transportation, euthanasia and slaughter requirements should be considered and incorporated. The current recommendations are silent on all three issues. Organic consumers expect animal welfare to apply to the full life span of the animal.

• Transportation: Standards should specify acceptable conditions during transport, including stops for food, water and rest, etc.
• Euthanasia of sick or injured birds: Certain methods of euthanasia, such as suffocation, blows to the head with blunt instruments and crushing the neck with pliers or burdizzo clamps should be prohibited.
• Slaughter: Certain regulations for slaughterhouses should be specified, such as stunning chickens prior to slaughter (with a possible exception for on-farm slaughter).

The draft proposal being forwarded by the livestock committee is very specific, as it should be, and there might very well be other areas of emphasis that should be addressed based on producer input. A community-wide discussion of these recommendations has not yet taken place.

If advice and suggestions are solicited from all stakeholders, it may very well lead to additional revisions and additions to the recommendations that will result in stronger recommendations. Moreover, it will provide the Board with a clearer picture of what the organic community supports in terms of strengthened animal welfare standards.

Again, I applaud the NOSB Livestock Committee for taking this initiative. Thank you for considering my comments.
Name and Farm Name, if applicable

Specific Weaknesses in the Current Recommendations

Dairy cows: Cornucopia supports the minority opinion’s recommendation that organic dairy cows be milked no more than twice per day. We believe that the vast majority of organic dairy producers would agree. We concur with the minority opinion that “While an animal must be healthy to give large amounts of milk while being milked more than 2 times per day, her shortened life span and continual high stress level are too high a price for her to pay on an organic dairy.” This is an important area where we encourage the NOSB to solicit public comment before ignoring this important minority opinion.

Egg-laying hens and poultry: The current standards have been easily interpreted by some certifying agents as allowing producers to keep chickens indoors at all times. It is therefore important that the new rules are strong enough to ensure that industrial-scale henhouses really do provide meaningful outdoor access. For example, some current houses have two stories, with a single-file ramp leading to a concrete porch. If these houses set aside the required acreage as outdoor access, but do not change their buildings to increase the number of doors to grant outdoor access, the new rules will be meaningless to the chickens inside, and only a very, very small percentage will actually have legitimate access to the outdoors. We therefore suggest that the NOSB also recommend a certain amount of entry/exit popholes for the birds. This is likely not the only important detail that was left out — either by compromise amongst the livestock committee members or unintentionally. To ensure that the recommendations are as strong as possible when they are voted on, we suggest that the NOSB accept and review public comment.

Transportation and slaughter of organic animals: There are currently no recommendations for ensuring humane transportation and slaughter of organic animals. Organic consumers expect that farm animals are treated humanely on the farm, but their expectations for humane treatment apply also to transportation and slaughter. We encourage the NOSB to include humane transportation, euthanasia and slaughter standards.

The USDA has announced a series of hearing sessions in September and October across the country to allow members of the public—especially fresh vegetable growers and handlers—to comment on a proposed agreement that would authorize the development and implementation of production and handling regulations for a long list of fresh vegetables, primarily leafy greens.

The proposed marketing agreement would allow corporate leafy green handlers to attach a USDA-backed “food safety seal” to lettuce, spinach, cabbage and other vegetables while prohibiting organic and local farmers at farmers markets, CSAs and roadside stands, and those selling directly to retailers, from using the same seal. This corporate-backed marketing ploy may lead many consumers to assume that vegetables from industrial-scale monoculture farms in, primarily, California are safer than the leafy greens at local farmers markets.

As if this weren’t bad enough,the industry proponents that are pushing this initiative have not been able to show that any set of standards would actually prevent food borne illness. Standards in California, which would likely provide the basis for the national program, have not prevented contamination—today (September 18), a signatory to the California Leafy Greens Marketing Agreement recalled 1,715 cartons of spinach due to salmonella contamination.

Such corporate marketing gimmicks could do real harm to the growing local and organic food movement while having a questionable impact on protecting consumers.

The USDA is not accepting written comments at this time—only in-person testimony will be considered. Hearings will be held in seven locations (CA, FL, OH, CO, AZ, NY, NC), specifics on hearing locations and dates are available at www.cornucopia.org. We

encourage growers and handlers of leafy greens to appear in person at a hearing session to deliver your message.

The safety of our food supply is a vitally important issue, which is why the USDA should not allow corporate handlers to mix serious food safety concerns with self-serving marketing interests.

The Cornucopia Institute has prepared a set of talking points for growers and handlers to use when giving testimony. We urge anyone who is able to attend these hearing sessions to deliver a unified message, which must be heard loud and clear: we do not support a marketing agreement as an appropriate vehicle for improving food safety.

Industry proponents claim they represent more than half, by volume, of the leafy green business in this country. And they may succeed in establishing this marketing agreement.

We must share the following concerns with the Leafy Greens Marketing Agreement:

In the event that the powerful industry players succeed in convincing the USDA to adopt their proposal, we also must propose substantive changes to the marketing agreement, including:

The USDA is especially interested in hearing testimony from growers and handlers of leafy greens. Your testimony at one of the hearings will be an invaluable part of the democratic process—we need as many growers and handlers, and their urban allies, to deliver this important message on the record.

CLICK HERE to see Cornucopia’s detailed TALKING POINTS.

CLICK HERE for specifics on hearing locations and dates.

PLEASE RESPOND to cultivate@cornucopia.org if you are planning to attend one of the hearing sessions or have additional questions.

The “Leafy Green Marketing Agreement,” which requires producers to follow a set of rules (metrics) in the name of food safety, has already shown to be injurious for the environment, biodiversity, and organic growers in California. The USDA is now considering a similar “Leafy Green Marketing Agreement” that would extend beyond California and Arizona to cover the entire United States—let’s help make this rule work for growers of all sizes!

The USDA has scheduled a series of hearing sessions, around the country, inviting you to this perfect opportunity to share your concerns and suggestions.

Click here to view the USDA announcement in the Federal Register.

Make your voice heard!—if you are able to attend, we urge you to speak on behalf of the organic and family-scale farming community. (See below for locations and dates.)

Producers’ experiences in California, where these metrics have been in place for several years, reveal what is at stake. While food safety is a legitimate national concern, organic and small-scale farmers bear a disproportionate economic burden of these metrics. Consider this:

The environmental impacts of the Leafy Green metrics have also been alarming. Since wildlife, non-crop vegetation (wild habitat), and water bodies could be viewed as food safety risks, many environmentally positive, conservation and habitat-oriented practices that growers have implemented in California have been forced to be destroyed or abandoned by growers threatened with the rejection of their crops.

If these metrics are adopted nationally, organic farmers across the nation could face difficulties balancing organic requirements, to promote biodiversity, with metrics seeking elimination of wildlife and non-crop vegetation.

Although the USDA has defined this regulation as “voluntary,” it is important to realize that in California, this has not been the case. Large grocery chains and distributors have refused to purchase produce from growers unless they are a signatory to the “leafy greens” program, making this a defacto rule. Don’t let the voluntary nature of this program dissuade you from recognizing the impact this proposal could have on small, local and organic growers.

The USDA organized public hearings to glean citizens’ concerns and suggestions. The USDA invites you to present evidence at the hearing on the possible economic impacts of the proposal on small businesses.

When and Where:

All hearing sessions are scheduled for 8:30 a.m. – 5 p.m.

Stay tuned! The Cornucopia Institute, in partnership with other public interest groups, will shortly issue a more comprehensive action alert including talking points, information to submit written comments, sample letters and detailed instructions and help regarding appearing at the public hearings (including the precise location of each hearing).

We encourage other NGOs that would like to collaborate on this project to contact us. A number of other groups have also invested in developing an excellent knowledgebase and networking together will leverage our work on behalf of family farmers and consumers.

This week, as soon as Tuesday, the House will vote on HR 2749 — the Food Safety Enhancement Act.

We strongly encourage you to call or email your Representative as soon as possible and ask that they support the Farr-Kaptur amendment to HR 2749.

New food safety legislation should not penalize or threaten the nation’s organic and local, sustainable farmers. While we believe that it is not the intent of new food safety legislation to harm these producers, the Farr-Kaptur amendment helps protect organic, local and diverse family farmers by clarifying the legislative intent of HR 2749.

For a further summary of the Farr-Kaptur provisions, click here.

If you need to find contact information for your elected Representative, click here.

Just a reminder and some particulars on the emergency rally for organic dairy farmers this coming Thursday, July 16. The rally will be held from 11 AM through noon. The event will take place at the La Crosse Interstate Fairgrounds in West Salem, Wisconsin.

The fairgrounds are located on County M just north of Hwy 16. The easiest way to find the fairgrounds is to get off I-90 at the West Salem exit. Take the frontage road that runs parallel on the south side of the interstate. When you come to County Road M go north (right) and cross over the interstate. You will pass through one set of traffic lights (Hwy. 16) in the fairgrounds will be on your left side.

The rally in support of organic dairy farmers (see flyer below) will be held in the beer tent at the fairgrounds, located behind the building that holds the commercial exhibits and the fair office. You should be able to ask any of the exhibitors, or other officials, how to get to the beer tent and/or the office.

The fair itself is free and parking is free as well. Maybe you and your family might enjoy attending the fair in addition to the rally.

If you are a farmer please bring a quart of your own milk to “symbolically” dump and another quart for an out-of-state farmer. We will be spreading this milk on organic farmland to retain its nutrient value after the rally.

Also, please bring one or more nonperishable food items in an expression of concern for many others in our rural communities who are also suffering from the current economic downturn. We hope you will be generous as the need is great.

We will be video recording the entire event and a copy will be given to USDA Secretary Tom Vilsack. All farmers will have an opportunity to make a brief statement. If we run out of time during the rally itself the video photographers will remain to take additional testimony. All farmers will be able to speak on the record if they desire.

All other speeches will be very, very short. Secretary Vilsack, who will be at the fair, has been formally invited to say a few words during the rally.

If you are not an organic farmer, or you are a farmer producing something other than milk, we hope you’ll attend this rally and stand in solidarity with the hard-working dairy families who now have their backs up against the wall, including some that are facing the loss of their farms.

We must send a message to the USDA that this is a legitimate emergency and that we need them to take immediate action to crack down on illegal factory farms producing “organic” milk.

This is not a “protest.” We’re not mad at Secretary Vilsack. So far the Obama administration has made some excellent choices for policymakers at the USDA and all their plans for managing the organic program have been positive. However, this is a “demonstration.” We hope to impress Mr. Vilsack with the immediacy of this crisis—illustrating that some farmers are about to lose their land—and asking him to take decisive action.

We encourage everyone to act in a dignified and respectful manner. But that is not to say that we shouldn’t be upset with the past performance at the USDA or the corporations that are now exploiting dairy farmers. Don’t be shy. Feel free to speak your truth!

We hope to see you in West Salem this Thursday,

Mark Kastel
The Cornucopia Institute

DONATE: Whether or not you can attend, your donation will help underwrite the rally and keep the pressure on the USDA, Congress and in the marketplace, so that when someone buys an organic product, they can be confident in its credibility and that the hard-working families, who get their hands dirty and crack a sweat, will be fairly compensated.

***************

Save the Organic Family Dairy Farm

EMERGENCY RALLY

Thursday, July 16 – West Salem, WI
11 am – La Crosse County Fairgrounds

A perfect storm has created a tidal wave of surplus organic milk that’s
now washing some organic family farmers off the land. A handful of
giant factory farms, milking thousands of cows each mostly in the
arid West, are flooding the market with suspect milk.

The USDA, during the Bush Administration, looked the other way while
these giant, industrial scale operations grew in number and influence.

Meet in West Salem, Wisconsin to deliver this strong message to USDA Secretary Tom Vilsack: We implore you to clean up the mess
at the USDA’s organic program. Justice must be served.

1. Immediately investigate and shut down illegal “organic” factory farms

2. Ask the Justice Department to investigate antitrust violations (organic predatory pricing) by Dean Foods, the nation’s largest milk processor

3. Bring in new management at the National Organic Program who will respect and protect organic farmers and consumers

Organic Milk Dump!

Local family farmers will symbolically dump some of their beautiful organic milk, and shed a few tears. The value of their milk has deteriorated along with the value of their farms.

For the “symbolic” milk dump—farmers, please bring a quart from your bulk tank and a second quart for an out-of-state farmer. Everyone, please bring at least one non-perishable food item to share with others in our community who are also struggling in the current economic climate.

Farmers from out-of-state—send us an e-mail and a local farmer will donate milk to be dumped in your name and you will be acknowledged—the full proceedings will be recorded and given to key leaders at the USDA and in Congress.

Organic farmers (non-dairy), organic business people/employees, consumers and retailers are encouraged to attend—please support our hard-working farm families—a lot is at stake!

The rally will be held at 11 AM, July 16, at the La Crosse Interstate Fair in West Salem, Wisconsin. It immediately precedes a town hall meeting on rural issues with Vilsack, Commerce Sec. Gary Locke and Transportation Sec. Ray LaHood. Secretary Vilsack has been invited to say a few words to the farmers prior to the town hall session.

Please Make Your Voice Heard!

Location: La Crosse County Fairgrounds,
Hwy 16 & Cty Rd M, N4985 Cty Rd M, West Salem, WI

e-mail: cultivate@cornucopia.org for directions and more information
or call the rally hotline: (715) 514-2627

Cosponsored by: The Cornucopia Institute, Family Farm Defenders, Midwest Organic Dairy Producers Alliance, Church’s Center for Land and People, Center for Rural Affairs, Missouri Rural Crisis Center, National Family Farm Coalition, Interfaith Program Action Council

Donate: Whether or not you can attend, your donation will help underwrite the rally and keep the pressure up at the USDA, Congress and in the marketplace so that when someone buys an organic product, they can be confident in its credibility and that the hard-working families, who get their hands dirty and crack a sweat, will be fairly compensated. –

– Thank you, The Cornucopia Institute

National Organic Coalition

In the waning months of the Bush Administration, the U.S. Department of Agriculture (USDA) released a proposal to completely overhaul regulation of genetically engineered (GE)crops. The plan significantly weakens USDA oversight.

The proposed rules would virtually ensure that contamination of organic and conventional crops will become even more frequent, and even excuses the Agency from taking any action to remedy such contamination. The rules would continue to allow the dangerous practice of producing drugs and industrial chemicals in food crops grown in the open environment, and in many cases even allow the biotechnology industry to decide whether their GE crops are regulated at all.

You can comment on this rule and make your voice heard. The public comment period, noted below, has been extended until June 29.

Over four years ago, USDA promised stricter oversight of genetically engineered crops; unfortunately, improvements considered early on have vanished and the regulations have instead become weaker. The proposed rule now has even more gaping holes than the regulations it is replacing. And it creates a few new loopholes as well, resulting in more public exposure to untested and unlabeled genetically engineered foods. Instead of tightening controls to protect the public and the environment from contamination and harm, what USDA has offered further endangers your right to choose the foods you and your family eat and farmers’ right to their chosen livelihoods.

As currently proposed, the rules allow biotech companies to self-assess the safety of their own experimental GE crops to determine whether USDA should even regulate them. The proposed criteria are open-ended, subjective, and would substantially reduce USDA’s oversight of a wide range of GE crops. Most egregiously, it is not genetic engineering that triggers regulation under the rules; the developer would make that initial decision. This is a clear abdication of regulatory responsibility. The proposed rule would also allow companies to grow some GE crops with no oversight whatsoever.

To make matters worse, USDA published the proposed rules before providing to the public the full Environmental Impact Statement (EIS) on this matter, as required by law. Clearly, there is something wrong with this picture.

We are calling on the Obama Administration to reject the irresponsible “anything goes” biotech policy, and to put in place rules that will create real change in the regulation and oversight of GE crops. And we are requesting a moratorium on commercial planting of any new GE crops until such comprehensive regulations are in place.

The comment period has been extended to June 29, 2009. Please send your comment to USDA today – the Agency is listening, let’s demand better oversight of GE crops to protect citizens, farmers, wildlife, and the environment!

Take action now at: http://ga3.org/campaign/Aphis3

UPDATE:

Last fall, we urged members of the organic community to write to the National Organic Standards Board (NOSB) in support of the first petition in the history of the USDA’s Organic Program to remove a food ingredient from the National List of Approved and Prohibited Substances (conventional soy lecithin). Our action alert, thanks to you, was a success. The NOSB Handling Committee received more comments on this topic – in favor of this petition – than all other comments combined. And they heard you!

The Committee, which reviewed the petition this past winter, unanimously recommended that the removal of conventional lecithin be approved at the vote of the full NOSB, at their meeting next month. We must show the NOSB that organic stakeholders are still engaged – tell them we expect them to cast their final vote in the interest of organic consumers and innovative organic companies.

Our action alert below outlines why this precedent-setting vote is so important for the future of organics. If you submitted a comment last fall, thank you, and we hope that you will take the time again to reiterate your support of this petition. If you did not comment last fall, please take a moment now to submit your comment (instructions and sample message below): “I expect the highest percentage possible of organic ingredients in my organic foods, which is why I support the petition to remove soy lecithin from the National List.”

Since this petition is opposed by a number of large corporations that would like to continue using solvent-extracted, conventional soy lecithin in organic foods (which is cheaper than the organic version), it is crucial that the NOSB hear our voices again as it prepares to cast its final vote on this important issue.

Background:

Take a look at the bar of organic chocolate in your desk drawer or the carton of organic ice cream in your freezer, and you’ll likely see a little-known but very common food ingredient: lecithin.

Lecithin is an important minor ingredient in many processed foods. It is used as an emulsifier to prevent separation of oil and water, and is especially common in chocolate to improve its texture and increase its shelf life.

Unless the ingredients list specifically states “organic soy lecithin,” the lecithin was processed from hexane-extracted soybeans, which were grown conventionally and likely sprayed with pesticides in the fields – ”in organic food??? Hexane is a neurotoxic chemical byproduct of gasoline refinement.

Currently, food manufacturers can legally add conventional soy lecithin to organic foods because, in the past, an organic version was not available.

To be labeled “ORGANIC,” and to carry the USDA organic seal, food has to be made up of at least 95% organic ingredients. The only non-organic ingredients are ones that are unavailable organically and cannot make up more than 5% of the product.

When the organic standards were developed in 1995, organic soy lecithin was not commercially available. But times have changed.

Over the years, one pioneering organic company has not only developed a truly organic soy lecithin, but has invested in the manufacturing capability to supply the organic version to every food manufacturer that needs it. Organic soy lecithin is not extracted with the use of hexane, a toxic and polluting solvent prohibited in organic production. And the organic version comes from organically grown, non-GMO soybeans (genetically engineered ingredients are also banned in organics).

Now that organic lecithin is commercially available, the National Organic Standards Board (NOSB), the expert citizen panel that Congress set up to decide these issues, needs to determine whether to recommend removing lecithin from this list of conventional substances that are allowed in organic foods. This is the first time in organic regulatory history that a food ingredient has been petitioned to be removed from the National List.

The Cornucopia Institute urges members of the organic community to tell the NOSB members that you support the removal of lecithin from 205.605 and 205.606. If lecithin remains on the list, food manufacturers have no incentive to opt for the truly organic lecithin, and many will continue to put hexane-extracted, conventional lecithin in your organic foods – it’s cheaper.

There is more at stake than simply the type of lecithin you can expect to find in your organic foods in the future. If the regulations do not change when companies innovate and develop new organic ingredients, why should anyone bother investing in the expensive research and development that gives rise to the availability of new organic ingredients?

We need to send a strong message to the NOSB members and the USDA that we stakeholders in the organic industry expect the regulations to evolve with the times. And change should be in the interest of organic consumers and innovative organic companies.

Taking Action is Easy:

Submit your comment to the National Organic Standards Board members.

Comments may be submitted via the internet at www.regulations.gov until April 20, 2009. The process is less complicated than it seems at first; simply follow the steps below.

1. To submit a comment, go to www.regulations.gov. In the middle of the screen, you will see “Search Documents.” Type in “AMS-TM-09-0014″ and click “Go.”

2. Next, you will see “Narrow Results” on the left side of the screen. Click on “Notices” under “Document Type.”

3. You may now click on “Send a Comment or Submission” underneath the search result.

Sample message (cut, edit and paste):

Dear NOSB Members,

As a consumer/farmer/processor/retailer (choose one or more), I want the highest percentage possible of organic ingredients in my organic foods.

When a substance becomes available in organic form, I support a change in the standards which requires manufacturers to use only the organic version. This is consistent with both the spirit and letter of the laws governing organic food production.

Specifically, I understand that organic soy lecithin has become available, which is why I urge the Board to recommend to the USDA that they remove non-organic soy lecithin from the National List (7 CFR 205.605 and 7 CFR 205.606) of approved non-organic materials.

As an organic stakeholder, I wish to avoid conventionally grown and hexane-extracted ingredients whenever possible. Since organic soy lecithin is never hexane-extracted and sourced from organically grown soybeans, I strongly urge the Board to vote for removing conventional soy lecithin from the National List.

Second, companies that invest time and money in the development of an organic version of commonly used food ingredients should be rewarded for their efforts in the marketplace. If the rules do not change with the times and continue to allow food manufacturers to purchase the non-organic version, why should anyone ever make the investments in the research and development of organic food ingredients in the future?

Voting to remove lecithin from the National List will ensure that processed organic foods contain organic soy lecithin. Just as importantly, it will send a strong message to organic companies that their efforts at developing organic versions of common food ingredients will not be in vain.