Comments on Organic Rule/Issues

Charles Benbrook
Benbrook Consulting Services
December 31, 1997


About a month ago Fred Kirschenmann and I were discussing the challenges facing the organic, consumer and environmental communities in reviewing and responding to the proposed USDA OFPA rule -- expected out 12/15 or 12/16. We decided to try to articulate a set of "first principles" that could be applied in reviewing the rule.

In our capacity as individuals and friends, we developed and now share the below short "thought piece." If it is useful, fine; if not, hit delete and let's get on with life. I thought it appropriate to share it with SANET since many of the points and thinking were shaped by the long dialogue we have shared these past months.

On another matter, there is a stunning "Perspective" piece by four lang grant/ USDA/ARS scientists, and a colleague from the Netherlands -- W.J. Lewis, van Lenteren, Platak, and Tumlinson -- in the Nov. Proceedings of the National Academy of Sciences entitled "A Total System Approach to Sustainable Pest Management." (Pages 12243-12248; will be on the PMAC web page in a few days; accessible now via the PNAS website, search by autghor is easiest). It presents the most sober and accurate appraisal I have ever seen by scientists within the system of the current "state of the art" in pest management. Their expressed view of the potential of biointensive IPM and biotechnology is virtually 100% in accord with the views commonly expressed on this list, and in the Consumers Union book "Pest Management at the Crossroads."

In the same issue of PNAS, maybe the one before, there is another key paper by Tabashnik, et al on Bt resistance which further reinforces the conclusion that resistant alleles are much more common than once thought, hence reaffirming the risk of rapid emergence of resistance if Bt-transgenic varieties are widely planted, given the inadequate resistant management plans now in place.


1/1/98