The International Federation of Organic Agriculture Movements (IFOAM) has just begun its process of reviewing the USDA's proposed rule for organic production, but a first reading indicates that it is well below the standard of IFOAM and that there are a number of causes for alarm. We would like to call attention to two of them here: the failure to exclude genetic engineering and the prohibition of private seals based on standards higher than or in addition to the national requirements.

IFOAM's position on both these points is unequivocal. Our Basic Standards for organic production, which are voted by our General Assembly every two years, prohibit all forms of genetic engineering at every stage of production and processing, with no possibility for case-by-case authorizations. The reasons for this refusal are varied and complex; they include health, environmental, ethical, and market considerations, they are both scientific and trans- scientific. According to the Basic Standards, the technology is inherently opposed to the principles of organic agriculture because manipulations at the molecular level bypass the wholistic approach to organisms and systems on which organic agriculture is based. All certification bodies which are accredited in the IFOAM Accreditation Programme must reflect IFOAM's genetic engineering ban in their own standards and inspection procedures.

In any case, our market is demanding this guarantee as strongly as they have ever demanded anything in the history of our movement. This demand was reflected in the recommendation of the National Organic Standards Board to prohibit genentically engineered organisms and products derived from them in organic production and handling, and is repeated in the Codex Alimentarius organic guidelines, which are nearing the final decision-making stage. Nonetheless, the USDA has chosen to ignore these signals and delay taking a clear position. While appearing to be open to further consideration of the issue in the Preamble, the USDA tips its hand by permitting genetic engineering in the rule itself, which admits a number of genetically engineered products such as bacterial toxins and chymosin.

USDA seems to be excusing itself for rejecting the NOSB recommendation on the basis of an implied contradiction with the US government's policy of "regulating GEOs based on risk, not on how they are produced." But this is a false contradiction, because the organic rules are not about regulating genetic engineering; they are about regulating organic agriculture, which is, by definition, based on the way the product is produced. In addition, the organic system as a whole is voluntary in the sense that no one is bound by law to be an organic farmer or to buy organic products. In legislation of this type the thing that matters is what the creators of the demand and those who supply it want it to be, and that is based on values and principles not restricted to notions of risk.

The acceptance of genetic engineering in the proposed organic rule is rendered even more unnerving by the fact that private bodies are prohibited from using seals based on higher or additional standards than the national requirement. These two things taken together, if allowed to stand, will drive a wedge through the heart of the U.S. organic movement and effectively destroy the hard-won consumer confidence in organics-presumably the reason for a law in the first place. In criminalizing the use of private organic seals based on adherance to higher organic standards than its own, the USDA has lost sight of its proper role. It is indeed ironic that the United States, the home of free enterprise, is the only country in the world which proposes to restrict the enterprise of private certification bodies in this way. IFOAM is convinced that a dynamic development of organics rests on maintaining this right, in conjunction with a provision for delegation of accreditation to private programs which fulfill international accreditation norms and under the supervision of the AMS.

Genetic engineering is rapidly penetrating the conventional food supply. Already more than three million acres in the United States are under genetically engineered crops. The government's policy against mandatory labelling of genetically engineered foods means that the only alternative for consumers who wish to avoid them is to buy organic. If now organics are legally prohibited from offering an alternative, there won't be one. Is that the method in this madness?

Of course we realize that a general ban on genetic engineering will usher in a whole new range of difficult challenges, such as what new inspection procedures are needed to back up the guarantee, how to maintain supplies of certain products, and how to deal with the gray areas. And as the chemical industry retools to genetic engineering, these difficulties may be expected to increase. But the refusal of the organic movement to bow to expediency is the foundation of our market. We should see in these hardships opportunities to expand into new economic sectors, such as the manufacture of enzymes with traditional technologies to service our own needs. Already suppliers are coming forward to offer certified non-genetically engineered rennet, yeast, and enzymes. The best way to ensure continued supplies of non-genetically engineered products is by maintaining a ban on genetic engineering in organics.

The greatest disservice that USDA could do the US organic sector is to adopt a national rules depriving it of the right to steer clear of genetic engineering. Not only would its own organic market be destabilized in very short order, but also US organic product would quickly come to be equated internationally with genetically engineered food. Why would they want to do this to one of the fastest and most sustained growth sectors in the US economy?

In the interest of the worldwide organic movement, we urgently request every reader of Organic Gardening to join us in writing the USDA before March 16th to demand that the National Organic Program Rules include a generalized prohibition of genetically engineered organisms and products derived from them at every stage in the production and handling of organic products and that it guarantee the right of private bodies to use seals based on standards that are higher than the national minimum, backed up by a system for delegating accreditation to private programs which fulfill international accreditation norms. With a massive outpouring of feedback, we will hopefully be able to protect the integrity and future development of organics.

Linda Bullard
Vice-President of IFOAM

NOTE: With 570 member organizations in more than 100 countries, IFOAM is the only worldwide federation bringing together all branches of the organic sector from farm to table. Its head office is located on an organic farm in Germany: Oekozentrum Imsbach, D-66636 Tholey-Theley, Germany.
Tel: 011 49 6853 5190;
Fax: 011 49 6853 30110;