As an aware consumer imploring farmers to "put away that DDT now," Joni Mitchell sang, "give me spots on the apples, but leave me the birds and the bees…please."
Once upon a time, when I was an activist and small organic farmer, organic standards were a self-imposed system of rules developed primarily by organic farmers, those who had to work with them on the ground. Consumer expectations have always figured into organic standards, but there was a general understanding that consumer perceptions of what is "pure and natural" do not always fit the reality of organic farming, let alone food processing. Organic standards were not just about marketing products, either. We thought that consumers might well be ignorant about farming and food production, but they could learn—it was more important to support farmers who did the right thing than to pander to consumer fears. Just as the immortal Ms. Mitchell learned to ignore those spots on the apples.
Today, no one seems bothered by the assertion that consumer expectations, even those grounded in ignorance, are all that matters. Add to that the argument that consumers cannot understand and could care less about the nuances of organic methods, and only want to be assured that organic products meet the toughest possible standards. What it often adds up to is unparalleled hypocrisy, and betrayal of the early vision of organic in the name of an ideological anti-corporate agenda that actually works against the interests of both small farmers and "ordinary" consumers (not Joni Mitchell–think Joe the Plumber who shops at WalMart).
The gist of the problem is this: The activists have had it wrong all along. They believe without question that the only way to fend off the takeover of organic by global corporate evildoers is to keep up the pressure to make the standards as tight, strict, rigorous and undiluted as possible, and use consumer perceptions as their rationale. They mistakenly believe that regulation of the organic label is comparable to regulations that prohibit misdeeds by corporate polluters. Not true.
The difference is one that very few outside of government and some rarified academic fields seem to get, but which immediately makes sense to most people – even ignorant consumers – when it is explained. The short explanation is that, unlike a traditional environmental or consumer protection regulation that keeps giant corporations from threatening the health of consumers and the environment, the NOP is a marketing program that establishes minimum requirements for those wishing to enter the organic market.
In marketing programs, tightening the standards is a strategy commonly used to benefit established players and limit competition by potential new entrants. It has nothing to do with protecting consumer interests, and works against consumers by maintaining high prices and limited supply for products that may not be demonstrably superior (e.g., spotless apples drenched in pesticides). It also has nothing to do with protecting the environment, and may even harm it, as may be seen in some of the provisions in the new proposed rule on access to pasture, discussed below. In fact, tightening the rules creates more obstacles for small players to enter the market than for large players, who are accustomed to meeting bureaucratic requirements and have paid compliance staffs. They actually prefer to have tighter standards, to protect the substantial investment needed to get in.
Unfortunately, the activists have more power than they realize. Everyone connected with the organic industry–from the NOP administration to the companies, large and small, who are trying to make a buck and save the world at the same time (never mind if the two may be mutually contradictory—that's another discussion)—live in fear of being publicly accused of trying to "weaken" the standards.
The most recent examples of this can be found in discussions about the NOP's proposed rule on access to pasture and in some public comments about the NOSB's proposed standards for organic aquaculture. In my role as a consultant for OTA, which can ill afford to risk being painted as a tool of corporate agribusiness, I have to restrain myself. So I am writing this on my own behalf, in hopes of starting some small back draft in the hurricane of unfounded assumptions that envelops every discussion about how to improve organic standards.
What touched off my ire was an exchange about the current requirement for 100% organic livestock feed (with no exceptions, period), which the NOP proposes to tighten still further by disallowing feed purchased from organically managed but exempt operations. In other words, up till now an organic beef or dairy farmer could buy hay from a neighbor who used organic methods to produce it, but was exempt from certification because she sells less than $5,000 worth of organic products a year. Those arguing in favor of closing this "loophole" supposedly represent small organic farmers, who would be hurt the most by cutting off this option.
What's going on here? We can go back even farther than the firestorm that erupted around publication of the first NOP proposed rule, in the drafting of which I proudly claim a major role. But that's another chapter for another time, especially if someone finally agrees to publish the book I've been working on since I left the NOP nine years ago. The charge that USDA was trying to "weaken" organic standards at the behest of corporate agribusiness, while plausible to any activist who has battled corporate owned regulators, was wildly and hilariously inaccurate. Some of those who led the charge, I continue to believe, may themselves have been agribusiness plants. Amusing as that misinformation might have been, it has had some unfortunate consequences for the original organic vision, and for its potential to have a real impact on the food system.
When the public response to the first proposed rule erupted, the only people in the NOP who truly cared about small organic farmers and the organic vision were immediately sidelined from the program. Then the new management instituted a policy of supporting the strictest possible interpretation of the law, and responded to the argument that the rules should be feasible for small producers with a cynical, "we're just going to give them exactly what they want, and they'll have to live with it" attitude.
Ten years later this attitude is evidenced in the proposed rule for access to pasture that is excessively prescriptive and draconian in its requirement for year-round outdoor living for organic livestock in any climate. If implemented as written, it would likely eliminate a large number of small organic dairy farmers, as well as most organic beef producers. To this extent the strategy has succeeded: Activists are now being forced to ask that USDA make its rules just a wee bit looser. But they continue to cling to the delusion that tougher rules benefit small operators, and threaten those who disagree with public relations nightmares.
Another case in point is the recommendation on standards for organic aquaculture that was just passed by the NOSB. It was opposed by some groups, including the National Organic Coalition, who consider fish farming as it is practiced by conventional agribusiness concerns to be an ecological and health disaster—as well they should. But does it make any sense to oppose the possibility of environmentally sound fish culture because consumers think organic should mean "pure and natural?" No bones about it—I think this is nutty.
With the myriad crises we face, not least of them climate change, why on earth would anyone want to limit the possibility of the broadest possible transition to organic methods, without delay? There's much more I could say, especially about what organic does mean, if not "pure and natural." But as our local public radio storyteller, Willem Lange, famously closes—"I gotta get back to work."