OCA PETITION TO USDA REGARDING PROPOSAL TO ALLOW 38 NEW CONVENTIONAL INGREDIENTS IN ORGANIC PRODUCTS
Speaking
from the perspective of organic consumers, we support the NOP for
clarifying to producers that if an item is not on the National List, it
cannot be used in conventional form. However, we do not support all of
the NOSB's 38 recommended additions to the National List. Notably, we
are opposed to the addition of casings from processed intestines, hops
(without specific listings), fish oil, beet juice, lemongrass, rice
starch and whey protein.
AMS-TM-07-0062 claims that these
exceptions must be added to the list to offer concessions to countless
companies who have violated the National Organic Standards in the past
by using conventional ingredients that were not on the National List.
These same companies have been given months to petition the NOSB for
inclusion of desired conventional ingredients on the National List. In
contrast, the general public has only been allocated 7 days to comment.
Specifically, we are opposed to allowing the following conventional ingredients in organic production:
1) FOOD COLORINGS
We
believe additional criteria should be added to any of the added food
colorings to the National List. Food colorings should be treated in a
manner similar to flavors by the NOP. Before a food coloring is added to the National List, it should be stipulated that
there are no synthetic solvents, preservatives or additives.
2) CASINGS FROM PROCESSED INTESTINES
The
proposed addition to the National List is focused on bovine, ovine and
porcine animal intestines used as sheaths for products such as sausage
links. Surveys of organic consumers find that a high percentage of beef
eating organic consumers choose organic products to avoid diseases
associated with conventional meat production. Specifically, the organic
beef industry has enjoyed a considerable boom as more consumers are
concerned with bovine spongiform encephalopathy (BSE) which has only
been detected in animals raised conventionally. BSE is transmitted via
the consumption of prions in infected body tissue. There is no
scientific evidence that excludes bovine intestine as a possible source
of BSE transmission.
In short, many consumers are choosing to
pay notably higher prices for organic beef based meats to avoid
conventionally raised beef. By allowing conventional casings on the
National List, these consumers will be misled into believing that the
meat product they are eating was raised in accordance to the National
Organic Standards, when, in fact, the intestinal casing may be from an
animal that lived its life on a factory farm in intensive confinement,
consuming pesticide laden foods, and treated with an assortment of
antibiotics and drugs.
A meat labeled as "organic" should truly
be organic, and the allowance of conventionally produced intestinal
casings violates consumer rights.
3) HOPS
Hops (Humulus
lupulus) should not be included on the National List in such general
terms. Only specific low-supply varieties should be listed. Although
organic hops is in high demand, there are over a dozen varieties of
organic hops available on the market (available in both pellet and
whole flower form).
Hops is one of the main ingredients in
beer. It is misleading to allow a beverage to be labeled as "organic"
when its main ingredient was grown with pesticides and synthetic
fertilizers. By including hops on the National List, consumers will not
be able to distinguish truly organic beer from a beer with a main
ingredient that is conventionally grown.
Also, putting hops on
the National List offers unfair advantages to large-scale breweries.
There are many micro-breweries now selling truly organic beers (with
organic hops). These companies cannot compete with the prices of larger
companies stepping into the "organic" beer business, like Budweiser,
who will be allowed to use less expensive, conventionally grown hops
(non-organic hops costs less than half as much as organic hops).
Breweries need to put more effort into developing organic hop resources
here in the USA before they try and make organic beer with inorganic
hops.
We believe specific varieties of hops that are in well
documented low supply on an organic level could be listed here, but
including all varieties of hops on the National List is unnecessary and
harmful to organic hops producers.
4) FISH OIL
We do not
agree with the recommendation of listing fish oil on the National List.
Fish oil has not undergone any TAP review, which is required for any
substance proposed for the National List. Also, there are no organic
standards for fish under the USDA NOP. Also, there must be criteria for
the fish oil when/if it is allowed. For example, is it solvent
extracted, and has it been tested for contamination from heavy metals,
PCBS, and dioxin. This is a substance that is still undergoing review
and definition and should not be considered for listing until it has
gone through these required processes.
5) Lemongrass, Rice
Starch, Beet Juice & Whey Protein Concentrate We believe the above
ingredients are available in quantities sufficient enough to serve the
organic industry. These ingredients should be re-evaluated using the
criteria established by 7 U.S.C. 6517 and 6518 of the OFPA and NOP
criteria (72 FR 2167).
We ask that you remove each of the
above ingredients from the AMS-TM-07-0062 proposal.
Thanks for your consideration,
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USDA & INDUSTRY TRY TO SNEAK BANNED CONVENTIONAL INGREDIENTS INTO ORGANIC BEER, SAUSAGE, & PROCESSED FOODS