by Alexis Baden-Mayer, Organic Consumers Association

Hello, my name is Alexis Baden-Mayer and I work here in Washington, DC, with the Organic Consumers Association. I'd like to talk about grower groups, aquaculture, the 100% organic claim, and methionine. I want to thank all of you for your hard work. I am encouraged by the National Organic Program's several new hires in compliance and enforcement and the plans to make trainings more accessible. I'm very impressed by the work of the Board, especially the improvements made to the grower group certification document.

Grower Group Certification

I had the opportunity in September to visit the Palestinian Fair Trade Association's certified organic olive oil production in the areas around Jenin. I saw olive trees that were a thousand years old and met farmers whose families have been making their livings from those trees for just as long. There are 1700 tiny family farms in that cooperative and they all share a central processing facility. They're building a new one and it's probably the biggest economic development project in the West Bank right now. In Palestine and a lot of other places in the Global South, they're organic by default, or you might say by neglect, just because they haven't had the means to improve their lands much at all, let alone with industrial inputs. By joining together to share resources and access international markets in a grower group, it's finally worthwhile do things like clear their fields of trash and fertilize their crop. In a place like Palestine where economic development and self-sufficiency isn't just a path out of poverty, but a path towards peace, you can't overestimate the potential impact of projects like this. I want to thank the committee for their great work and urge you all to support the grower group certification recommendation. I want to say, though, that the recommendations from Miles McEvoy, speaking for National Association of State Organic Programs, about explicitly limiting multi-site certification to producers, smallholders, and legal entities are good ones. The Palestinian Fair Trade Association, and all of the other grower groups I know of, would meet all of those requirements. I believe the way your recommendation is drafted, that's how it would be used, but it wouldn't be a bad idea to make that explicit.

Aquaculture Standards

Organic consumers are now 69% of the population. We're a diverse group of people, but we're consistent in our reasons for buying organic. Organic food is safer, healthier and more nutritious. The Organic Consumers Association wants to turn organic consumers on to the bigger picture, letting our members know that not only is organic safer, healthier and more nutritious, it's an important part of being able to feed the world, turn back global warming, reduce food-borne illnesses and diet-related diseases, and, ultimately,  increase stability, economic security and peace in the world. In order to enlist organic consumers in these larger causes, they have to be true believers in organic as The Way. There's a lot of green washing out there and there are a lot of marketplace claims that are trying to compete with organic. We're haven't changed our name to become the "green" consumers association or the "sustainable" consumers association, because we believe that "organic" is still the gold standard.

It's one thing to encourage consumers to go for "organic plus" like "organic plus fair trade" or "organic plus local," but it's different when the consumers are faced with a competing food standard that actually guarantees a higher quality of safety, health and nutrition. I'm afraid that if the current aquaculture recommendations become a rule, the Organic Consumers Association will be in the awkward position of having to explain to our membership that while we support organic for everything else, when it comes to certain kinds of seafood, like salmon for instance, we have to recommend the Marine Stewardship Council's certification. What is the Monterey Bay Aquarium seafood guide going to say about "organic" certified salmon that's farmed in the Atlantic in open-net pens? We're going to have the first US food production system where organic certification isn't the gold standard. Please don't let that happen. My recommendation would be to look at the fish that are already certified by the Marine Stewardship Council and letting those be the first to receive organic certification.

100% Organic

I want you to please consider preventing the use of atmospheric gases in 100% organic products. The logic in the recommendation is that the atmospheric gasses don't get into the food. I want to echo the comments of John Foster of Earthbound Farms when I say that I'm not so sure about that. My understanding is that the gasses are used to impact the freshness and appearance of the food. From the perspective of the consumer, if it's maintaining the freshness of the food and changing the way the food looks, it's in the food. I have no reason to believe that using nitrogen, carbon dioxide or ozone adversely impacts the consumer, but I think it would adversely impact consumer confidence in the organic label to learn that these gasses were filling packages labeled 100% organic.

The following comments from our members explain the purchasing decisions of consumers who look for the 100% organic label:

We fought hard to get the designation of organic products to keep organically-labeled really mean pure, untainted with pesticides, not tampered with by preservation or packaging.  We want to keep it that way. There are too many food scares out there that can be prevented by good inspection and labeling.  Don't let anybody dilute the veracity of the assurances we look for when buying food for our families.

— Anne McGowan, Normal IL

 I keep looking for prepared foods labeled "100 % Organic". Their scarcity prevents my purchasing of most prepared foods. Annually, therefore, several of my dollars are not reaching these markets.

Also, now that I have been reading about PFOAs (perfluorooctanoate) from many sources, I have decided to halt my purchases of "organic" packaged foods until I see labels stating "NO PFOAs". More of my dollars are not reaching these markets either.

I stopped purchasing tasty organic canned soups three years ago, after reading many articles about leaching from the lacquer lining of cans. I will wait for assurances on the labels that reasons for wariness have been eliminated. Until then, even more of my dollars not reaching these markets.

These comments come from someone who purchases and cooks as closely to "100 % Organic" as possible. ALL OF MY FOOD PURCHASES are guided by this goal.

— Jean Day

 I just read the CACC organic standards recommendations for modified atmospheric packaging and I can hardly breathe. With a severely problematic immune system, I must literally depend on organic foods and labeling to stay alive. Statistically, there are millions just like me in the U.S. The assumptions behind the new 9/15/2008   guidelines are faulty.  If adopted as standards for organic food, it will be an unmitigated, deadly disaster for people like me.

From page 3:

C) Packaging Materials and Modified Atmosphere Packaging Aids

Due to rising concerns about Food Safety and to the increased HACCP requirements for harvesting and packaging raw agricultural products such as fresh fruits, vegetables, and eggs, producers are frequently utilizing sanitizing agents as packaging aids:

1) Sanitizers (Chlorine, Peracetic Acid) in direct contact with fresh vegetable and fruit wash water prior to processing.

2) Modified atmosphere gases, such as carbon dioxide, carbon monoxide, or nitrogen gases added to prevent oxidation in vegetable and fruit clam shells; and

3) Ozone gases shot in egg cartons as a sanitizing agent.

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I WILL USE CAPS TO DISTINGUISH MY COMMENTS FROM THE GUIDELINES TEXT.

THE FOOD PROCESSING INDUSTRY IS USING BOTH CO AND CO2 ON GROUND MEAT, NOW, AND NOT JUST ON FRUITS AND VEGETABLES. THE PACKAGING IS EASY TO DISTINGUISH IN YOUR LOCAL GROCERY STORE BECAUSE IT FORMS A TIGHT BALLOON AROUND THE FOOD. IT IS USED AS A PRESERVATIVE AND WORKS VERY WELL.

 GASED FOOD LOOKS NEW AND ENTICING FOR AS LONG AS A YEAR, MAYBE LONGER, WHILE THE UNSEEN INTERIOR DECAYS. PRESERVING THE APPEARANCE OF FRESH FOOD WHEN IT IS NOT IS DECEPTIVE, UNETHICAL, AND A CAUSE OF SICKNESS AND DEATH.

VACUUM PACKING WORKS PERFECTLY AS A PRESERVATIVE. THERE IS NO NEED FOR THE USE OF CONVENIENT, CHEAP, INADEQUATELY TESTED GASES. WE DON'T WANT TO BE GUINEA PIGS FOR THE FOOD PROCESSORS – AGAIN.

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From page 6:

Atmospheric gases such as CO2, Ozone, Nitrogen and other inert gases present a situation which is different than those presented above. They do come into contact with the food, but do not become incorporated into the food and are no longer present by the time the food is consumed. At this time the committee does not see that the use of CO2 and Nitrogen would disallow the 100% organic claim.

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HOW CAN THE COMMITTEE CONCLUDE THAT GASES DO NOT BECOME INCORPORATED INTO FOOD?  ARE THEY REFERENCING SOME NUTRITIONAL CHEMIST? WHO?

GASES SUBTLY CHANGE THE MOLECULAR STRUCTURE OF FOOD. UNTIL I MADE THE CONNECTION WITH THE GAS ADDED TO GROUND TURKEY, I WAS HOSPITALIZED TWICE WHEN MY HEART TRIED TO STOP. MY CARDIOLOGIST COULD FIND NOTHING WRONG AND SAID SHE SUSPECTED AN ALLERGIC REACTION. I AM LUCKY TO BE ALIVE. OCA WOULD BE DOING MILLIONS OF US A FAVOR BY ADVOCATING LABELING FOR ALL GASED FOODS AND INSISTING THAT GASED FOOD BE DENIED ANY – ANY! – ORGANIC LABEL.

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4. Nitrogen, Ozone, Carbon Dioxide and other inert atmospheric gases, are not incorporated into organic foods and do not resemble ingredients because they are no longer present by the time the food is consumed. Their use should not prevent a food product from being labeled "100% organic: if that food meets the criteria for such labeling in all other ways.

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THIS CONCLUSION IS UTTERLY, ABSOLUTELY, UNEQUIVOCALLY WRONG. IT WILL WREAK HAVOC ON THE HEALTH AND WELL BEING OF MILLIONS OF PEOPLE WHOSE LIVES DEPEND ON ORGANIC FOOD AND ON THE GOOD JUDGMENT OF AN ORGANIC ADVISORY COMMITTEE. THIS RECOMMENDATION WILL RESULT IN DEATHS.  MINE FOR SURE.  AND IT WILL BE VERY HARD, IF NOT IMPOSSIBLE, TO CHANGE LATER. WHEN THE BODY COUNT RISES, TOXIC FOOD ADDITIVES AND PROCESSES WILL BE AMONG THE LAST THINGS CONSIDERED AS A CAUSE.

PLEASE REVISE YOUR ACCEPTANCE OF THE CASUAL ADULTERATION OF FOOD BY THIS OR ANY METHOD.

— Anonymous

Methionine

Please remove methionine [from the National List of approved substances in organic]. This article from the Rodale Institute is instructive:

"Another option to feed additives is pasture access. Birds that have access to pasture do not need additional methionine during the growth and finishing phases, reports Joe Moritz, assistant professor of poultry production at West Virginia University."

http://newfarm.rodaleinstitute.org/columns/org_news/2005/0405/methionine.sht ml

Remove Soy Lecithin (from OCA member Tracie Beasley)

The loopholes and weakened regulations that allow companies to hide additives under "spices" and "natural flavors", as well as the lack of prosecution for companies who include additives without listing them on the label, is a travesty to our citizens.

There are dozens of ingredients that are flavor enhancers, very similar to MSG, that are allowed in organic foods. Poultry producers are legally allowed to inject flavorings in their products without labeling what they are injecting into the meat! Studies in the US on these enhancers are limited, and the studies that have been conducted have been widely ignored. I for one, however, can tell you how unhealthy they are to humans.  MSG and other false glutamic acids alter brain chemistry to make individuals feel addicted to foods. Unfortunately, they also cause migraines in many AND have been linked to cardiovascular problems.  I for one, as a healthy 37 year old, get heart palpitations and elevated heart rate, in addition to headaches, when I have ingested these ingredients.  Unfortunately, because 1000s of grocery items have "spices" and/or "natural flavors" listed, people who are sensitive to these ingredients either can't eat them or must play "Russian roulette" to experiment on themselves to see if they have harmful ingredients in them.  I suspect that these ingredients are one of the reasons why so many Americans have heart conditions, but the additives are so ingrained in their lifestyles that they are unable to determine their impact.

Soy lecithin is now in massive numbers of foods.  This product has been sold as a health aid, and soy is touted as an incredibly healthy food. However, international studies are beginning to show otherwise.  There are different grades of soy lecithin. As a cost saving measure, food companies are purchasing this product, often low grade "waste" from soy food production, and adding it to everything from baked goods, to chocolate, to teas.  This product needs extensive research before being used in food products.  When I ingest foods containing this product, including basic teas, I become extremely lethargic, to the point that I can hardly stay awake or stand up. Either the food is unhealthy or the by-products associated with it since it is often the "bottom of the barrel" after soy production is unhealthy to the American public.

Both MSG and many other food enhancers, as well as soy lecithin (sometimes disguised as "natural flavors" are touted as "natural". However, just because the base ingredients came from a plant, doesn't mean they are natural after chemical processing.

It is critical to our health that consumers know exactly what they are eating and the food industry not be allowed to manipulate our food products in this way.  Please push for stronger labeling regulations, ESPECIALLY with organic foods.

Regards, Tracie Beasley