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in from non-organic environments before honey, pollen, propolis, royal jelly, beeswax or queen production can be designated as organically produced.

3.    Fermentation Products:  More Non-Plant Life 113

    Wine, beer, vinegar and soy sauce must be produced using 100% certified organicfeedstocks to qualify under the OFPA. Apparently, these products cannot escape the standards or organic production as "natural" simply because they are made by a "naturally occurring" process.
    The previously mentioned products are produced by a fermenting organism, usually yeast, and such organisms receive the same scrutiny under the OFPA as any "livestock".114 Yeasts can be organically fed simply by requiring organically produced feedstock just as in wine and alcohol manufacturing.
    Any exceptions for the National List clearly would come only for synthetics required to augment these fermentations, such as sodium carbonate, potassium chloride and ion exchange resins. It is a serious mistake to pretend that yeast or any cultured product cannot be produced without using non-organically grown feedstocks.
    The same reasoning must be examined for ascorbic and citric acid production. These processes produce livestock "products" as in the case of citric acid, or "livestock" as in the case of yeast. These processes, in their simplest terms, take a plant product and convert it into a livestock product as surely as producing honey, milk, eggs or mushrooms. The same principles of requiring 100% organic feed must apply.
    Interestingly, such an approach eliminates most of the controversial (and illegal) National List for synthetic processing ingredient—except for a few synthetic inorganic chemicals115 , which it seems doubtful were ever meant to be excluded from organic food by the drafter provided these materials were of food-grade quality.

1. Aquaculture

    All forms of aquaculture parallel the livestock production section with respect tothe organic standards illustrated in the above paragraphs. Organically fed breeding stock must be cultured using 100% organic feed in a controlled area that has definable boundaries and a three-year no-prohibited-material use history. Progeny that have been in the existing system for three years or more are disqualified as slaughter stock after the three-year term but can be sold in the conventional market. If this is too difficult, the

    113.    These products are produced as livestock products under the OFPA definition as non-plant life.  7 U.S.C. § 6502(11) (Supp. V 1993).
   114.    See id. (providing the definition for "livestock").
    115.    The term "inorganic" (as opposed to non-organic) here refers to chemical compounds not containing carbon atoms. Carbon-containing compounds (usually except for carbonate salts) are the subject of the branch of chemistry called organic chemistry.

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