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system must be rid of the species to be cultured, and new frey or eggs must be introduced into a three-year-tolled enclosure. Pesticide and synthetic contamination (higher than background) must be excluded from the impoundments.
Selection of the impoundment or construction of the facility is just as crucial as the selection of the field for field crops, but the key is 100% organically produced feed.
- CERTIFICATION, ACCREDITATION AND THE NATIONAL LIST
The cumbersomeness, complexity, cost and timetables for implementation of the OFPA are all alleviated by a shortened National List of permitted toxic materials. The elegance and honesty of the organic program are inversely proportional to the length of the lists of permitted (‘otherwise prohibited") materials.
The OFPA should be implemented with a clean-plate National List so that organic-growth practitioners who qualify without complications can begin production. Any further delays are unfair to both producers and consumers, and lawsuits will inevitably and properly emanate therefrom. The history of the organic movement is littered with stories of successful conversions to organic production, fostered by deprivations (loss of access, unjustifiable cost or unavailability) of disqualifying inputs.
Costs of certification116 and accreditation117 are markedly lowered by simplification engendered by high standards and short lists. Any standards based on lowest-common-denominator theories or other artificial means of "inclusiveness" will doom both the individual producer’s ability to sell to sophisticated organic consumers and the overall organic movement itself.
Long-term growth of organic farming can only be achieved by codifying high standards and eliminating inappropriate practices and products, not by lowering standards and squeezing questionable inputs onto the National List, as the current NOSB seems determined to do.
Jim Marsden, vice-president of scientific affairs at the American Meat Institute was quoted recently saying, "So many of our problems today come from USDA’s failure to follow a regulatory or scientific process."118 One would hope this same failure does not spill over into OFPA regulation. Carol Tucker Foreman, former assistant secretary of agriculture for food and consumer services, has lamented, "The only thing I don’t
116. See 7 U.S.C. § 6515 (Supp. V 1993) (noting the requirements of certifying agents). See also 7 U.S.C. § 6507 (Supp. V 1993). Section 6507(a) provides: "The governing State official may prepare and submit a plan for the establishment of a State organic certification program to the Secretary for approval. A State organic certification program must meet the requirements of this chapter to be approved by the Secretary." Id.
117. 7 U.S.C. § 6515(a) (Supp. V 1993) (accreditation program). "The Secretary shall establish and implement a program to accredit a governing State official for purpose of certifying a farm or handling operation as a certified organic farm or handling operation." Id.
118. Patricia Peak Klintberg, The Ayatollah of American Agriculture, BEEF TODAY, Nov/Dec. 1994, at
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