As we anticipate the publication of the organic rule which will define the Organic Foods Production Act of 1990, it occurred to us that a set of principles for judging the appropriateness of various provisions might be useful. Such principles may also be helpful in shaping recommendations for change in the language proposed by USDA.

The complexity of the rule, the scope of its impacts, the short comment period, and the range of views held in different communities are bound to result in a wide range of suggested reforms. Widely different perceived or hoped for impacts of the OFPA will be described. The circle of individuals hoping to influence the outcome of the process is growing rapidly, as is the diversity of issues likely to arise in the comment period.

How will USDA respond to the expected, large volume of recommended reforms? How will the public debate over controversial provisions, and needed solutions, influence the views of consumers, most of whom are just learning about the program?

USDA's ability and willingness to accept recommended changes in the rule will be a function of three things---unanimity, consistency with the statute, and the justifications offered for changes in light of the general goals of OFPA and "good government."

Accordingly, we felt that a shared understanding of a set of "first principles" to apply in reviewing the rule may be useful to a wide range of communities who will structure their comments and recommendations largely independent of one another and without the benefit of time and dialogue to recognize mutualities. To that end we offer the following principles to anyone that finds them useful.

Perhaps they will also prove helpful to USDA as the department works to integrate the expected recommendations into a cohesive set of changes that collectively will---we all hope---make the rule simpler, clearer, and more effective in achieving the stated purposes of OFPA.

ORGANIC PRINCIPLES

1. Ecological Principle. Organic production should fit into and benefit from nature's systems. Dual goals should guide farm management decision-making: producing high quality, safe food in a manner that tends to preserve the integrity and stability of the biotic community, and builds, or at least sustains, the inherent productive capacity of the soil and biological resources used in the production process.

   Organic processing should, as much as possible, retain the integrity of the product so produced.

   Any deviation from this ideal, in production or processing, should only be allowed when there is clearly demonstrated need, and must not undermine the long-term goals of building soil productivity and producing nutritious, safe food that consumers can buy and enjoy with confidence.

2. Precautionary Principle. Any materials used in the production or processing of organic food must be proven safe. No materials will be allowed simply because they have not been proven unsafe or because benefits may appear to outweigh risks.and uncertainties. The burden of proof shall always be on the party wishing to use the material. and contending it is safe.

3. Systems Principle. The acceptability of practices, processes and inputs in organic production should be judged, first, on their impacts on whole organisms and the biological and ecological process that govern interactions within living systems. Those that are found to contribute to the health of organisms and systems should then be evaluated in terms of their intrinsic properties independent of their use and impacts on living systems.

ADMINISTRATIVE PRINCIPLES

1. Don't-Fix-What-Isn't-Broke Principle. First do no harm. Focus on quality outcomes rather than process or compliance with norms. Allow for the continuity and preservation of processes and decision-making models that have established a record of integrity in meeting the basic goals of OFPA, that demonstrate both transparency and responsiveness to all concerns and communities, and which enjoy the respect of those involved in and affected by them.

2. Perpetual Improvement Principle. The rule should encourage the continued improvement of the organic craft of both producers and processors of organic food. The rule should avoid freezing practices in place based on current knowledge and research.

3. Flexibility-Within-Integrity Principle. The rule should embrace diversity and simplicity to the full extent possible without eroding consumer confidence or violating organic principles.

4. Equitable Fee Structure Principle. In all instances those who benefit should pay. In general, the industry should continue to cover the costs of certification. Provisions in the rule should strive to keep costs to a minimum while providing adequate resources to insure credible certification. Necessary costs imposed on growers, processors, the trade or taxpayers should, as a basic goal, be shared equitably and in relation to the benefits received from the costs imposed. USDA, working with public funds, should bear the administrative costs of the accreditation process, and on an ongoing basis, should collect and share data, and carry out and commission independent analyses helpful in documenting the magnitude of direct and indirect costs and benefits associated with OFPA implementation.

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