Keith Jones
Program Manager, National Organic Program
USDA-AMS-TMP-NOP
Room 2945-So., Ag Stop 0275,
P.O. Box 96456
Washington, D.C. 20090-6456

RE: docket number (TMD-00-02-PR)

Dear Mr. Jones,

Last year 275,000 people wrote to the USDA to comment on its proposed rules for the National Organic Standards. Most of the commenters wrote to ask the USDA to reverse its inclusion of genetically modified organisms, sewage sludge, and food irradiation as acceptable materials and practices.

The revised rules were released on March 13. In them, sludge, irradiation, and genetically engineered (GE) organisms are "excluded" materials and practices. But closer inspection of the rules shows loopholes and language that call for further changes.

Irradiation, sludge, and genetic engineering are not safe for human health or for the environment.

The 50% rule -- which allows the word "organic" on the label of composite foods that may have ingredients (less than 50%) that utilized irradiation, sludge, and genetically engineered organisms -- should be eliminated. "Organic" should be nowhere on the label if these practices or materials are included in the food. Either it is organic or it isn't.

In section 205.2, the USDA must enact a definition of irradiation that includes ionizing radiation and all other irradiation techniques, including "cold pasteurization". The USDA must also expand its definition of sewage sludge to include ash from burned sewage sludge and other sewage treatment byproducts generated by the waste treatment process. Additionally, it is critical that the USDA expand its current definition of excluded methods to include all NOSB examples of prohibited genetic engineering techniques.

In section 205.271[c], the USDA must be clear and not grant organic food handlers broad discretion to use synthetic pesticides such as methyl bromide.

Further, irradiation, sewage sludge, and excluded methods should all be defined as "synthetic" so that the NOSB will have the legal authority to analyze any future changes to the prohibition status and so that a public, transparent procedure is in place for any future determinations (sections 205.2; 205.204[b]; 205.206[f]; 205.236[b][3]; 205.270[b][2]).

It is important that the USDA protect organic farmers from GMO pollution by establishing a county level notification system for all users of GMO crops. This will ensure that farmers will know the locations of potential GMO pollution. The USDA should also develop a system to compensate organic farmers for certification loss or crop loss due to GMO pollution.

The USDA said this is a marketing rule, not a food safety rule. If so, then this rule should be a floor, not a ceiling. If others want to say their products are better than the federal "organic" label mandates, let them. The public will at least know that the food passes the federal test. Meanwhile, small organic farmers or producers with higher standards can market their products and let the public decide what's best.

Sincerely,
Laura Orlando
Executive Director
The ReSource Institute for Low Entropy Systems

CC:
Senator Edward M. Kennedy
Senator John F. Kerry
Representative Edward J. Markey
Representative Michael Capuano
Representative John Joseph Moakley
President Clinton
Vice President Gore
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