To the Organic Community,

It was with great interest that I read Fred Kirschenmann's recent essay entitled, "Statement of Principles Regarding the Organic Certification of Organisms Harvested in the Wild," and sample "Area Organic Plan". Fred provides an excellent literary explanation on the importance of "wildness", which I cannot, and will not, dispute.

Fred has failed, however, to convince me why and how wild animals, including ocean going fish, should be certified organic. I understand, as Fred states, that "wild or domesticated game" are included in the OFPA definition of "livestock", but that is where the applicability of OFPA ends. Fred does not mention the sections of OFPA which would exclude wild animals from organic certification.

Section 6509(c) Practices, states, "For a farm to be certified under this chapter as an organic farm with respect to the livestock produced by such farm, producers on such farm (1) shall feed such livestock organically produced feed that meets the requirements of this chapter;".

This section is universally interpreted in the United States as a requirement that livestock must be fed 100% organic feed. Fred did not address that fact that wild animals are not, and will not be, fed organic feed.

For feed to meet the requirements of OFPA, it must be raised on land to which prohibited materials have not been applied 3 years prior to harvest. Fred does not address this huge issue either.

Section 6509(f)(1) Livestock Identification, states, "For a farm to be certified under this chapter as an organic farm with respect to the livestock produced by such farm, producers on such farm shall keep adequate records and maintain a detailed, verifiable audit trail so that each animal (or in the case of poultry, each flock) can be traced to such farm."

I cannot envision how a wild animal "harvester" could ever be in compliance with this standard. Should producers of domestic livestock be held to a higher standard that harvesters of wild animals? Fred does not address this issue.

Section 6509(f)(2) Records, states, "In order to carry out paragraph (1), each producer shall keep accurate records on each animal (or in the case of poultry, each flock) including (B) all feeds and feed supplements bought and fed."

There is absolutely no way that a wild animal harvester will be able to keep records on the feed consumed by the wild animals they seek to harvest. This is a fundamental requirement with which all other certified organic livestock producers must comply.

In addition, OFPA defines "producer" as "a person who engages in the business of growing or producing food or feed." A harvester of wild animals certainly does not fit the definition of a "producer."

OPFA anticipated allowing wild crops to be labeled organic, provided they meet certain criteria spelled out in 6513(f) "Management of Wild Crops." This section clearly applies to wild crops, and not to wild animals. Besides the inclusion of "wild or domesticated animals" in the livestock definition, there is no language OFPA which provides for the certification of wild animals. To the contrary, there are provisions which cannot be met by wild animal harvesting systems, as cited above.

In organic agriculture, we have worked hard for years to show that "organic by neglect" is not certifiable. Operators must implement and document proactive organic management systems. Harvesting wild animals and calling them "organic" takes us back to the concept of organic by neglect.

Under OFPA, even wild crops must harvested under a plan that will "sustain the growth and production of the wild crop." Fred has attempted to address this with his "Area Organic Plan." I see this as a laudable, but mis-placed effort.

I accept many of Fred's arguments, but feel that wild animal harvesting should not try to attach itself to the organic label. Fred's positions, especially those developed in the "Area Organic Plan", should be developed into a "Certified Wild" label. The draft plan should be re-titled "Wild Animal Plan."

Inspection protocols and a full set of standards should be developed for species and ecosystem specific wild animal harvesting operations.

Organics cannot be everything for everybody. It has its limits. I have been to the Tokyo Fish Market, which is the largest in the world. I thought about organic wild-harvested seafood standards while I was there, as most of the products for sale would likely qualify under Fred's plan. Let me tell you, it would be an absolute nightmare to implement organic certification in such a situation.

Organic is an agricultural production claim. There is a lot of room on the organic bandwagon, but there are certain systems which just don't fit. "Certified Wild" is one of those. It needs to grow its own market.

Respectfully,

Jim Riddle