National Organic Program

Discussion on USDA's rule implementing the National Organic Farming Act of 1990

Letter to NOP re: Conflict of Interest, National Campaign for Sustainable Agriculture
May 31, 2001

While it is critical that a firewall be maintained between certification decisions and all parties with commercial interests in the outcome of the decisions, the existing language goes too far and places an undue burden on farmer-run and membership-based certifying agents and the operators they serve. If implemented as written, it would mean the end to regional certifying agents that rely on the involvement of their members for their existence. Of the 6,888 certified parties identified in the 1999 US Organic Certifiers Directory, published by the Organic Farming Research Foundation, it is estimated that 5,251 or 76% of certified operations in the US are currently served by agencies that would not meet this requirement. A successful implementation of the proposed organic rule will not be possible if these experienced agencies, including those that are currently internationally recognized as ISO-65 compliant and/or IFOAM accredited, are no longer able to operate.