Comment on proposed Rules for Implementation of the Organic Foods Production Act submitted to the USDA by Ed Loewenton - part 2

Specifically:
(1) "Killed B.t.". NOSB listed genetically engineered Pseudomonas florescens with a B.t. gene as synthetic and non-approved.

[Coincidentally, in the May 1998 issue of Scientific American (p.38), there appears an article on the dangers of using crops genetically engineered to produce Bacterium thuringiensis toxins. Six prominent entomoligists, in a report prepared for the Union of Concerned Scientists, warn that the result is likely to be the evolution of resistant species, resulting in the loss of a valuable organic pesticide, which has been in effective use for many years. One moth has already demonstrated resistance to the toxin. The evolution of pesticide-resistant species is a well-established phenomenon.]

USDA ignored the NOSB and proposes that toxins from genetically engineered bacteria be placed on the National List "so that [the agency] can receive comments on the proper classification of these substances, and whether they should be allowed, prohibited, or allowed on case-by-case basis" (sec 205.20 62 Fed Reg 65889) and specifically lists "Killed B.t. as an allowed active synthetic sec.205.22d 62 Fed Reg 65891).

A similar situation exists in the case of Piperonyl Butoxide and Chymosin: NOSB recommended they be listed as non-approved synthetics; USDA proposes in its present Rule that they be included on the National List of Active Substances allowed. This is unacceptable. It is also probably unlawful in light of the original language of OFPA. sec 6517(d): "The Secretary may not include exemptions for synthetic substances other than those exemptions recommended by the National Organic Standards Board"

4. GENERAL/CROPS/HANDLING/NATIONAL LIST
1. I support the NOSB's prohibition of the use of genetic engineering in the production of crops labeled "organic". Particularly objectionable is the development of crops resistant to herbicides, most notably Roundup. [see appendix A] In conjunction with the USDA's attempts to mitigate the NOSB's recommendation that such synthetic herbicides and pesticides be prohibited altogether, allowance of genetically engineered crops presents the danger that foods labeled "organic" will in fact have substantial residues of synthetic chemicals. Manufacturers' assurances that such substances are safe involve highly questionable assumptions, and analyses of tests that are at least open to a good deal of counter-argument. It is bad enough that such methods are permitted in the production of any food product; to allow their use at all in production of foods labelled "organic" will serve to render the term meaningless as a guide to intelligent consumer choice in nutrition.

2. I support the NOSB's prohibition of the use of composted municipal waste ("sewer sludge") in the production of foods labelled "organic". Not long ago in the news was an article about a farmer using composted municipal waste, whose crops began to fail after a year of such treatment. In the second year, many of them died. Testing revealed that the plants contained significant amounts of heavy metals (lead, mercury), and other toxic contaminants. This may be an isolated and extreme example, but such contamination is a matter of degree, and such toxins accumulate in animal tissue, both in livestock and humans. They are stored in animal tissue and excreted slowly. Lead and mercury bind to neural tissues, and are not in fact eliminated without medical attention. One of the principal reasons consumers choose organic foods is their belief that organic foods are free of such contaminants. Your attempts (sec 205.22) to mitigate NOSB's outright ban on composted municipal waste would render such consumer choices meaningless.

3. I support NOSB's prohibition of the use of irradiation in the preparation of foods labelled "organic". Industry statements to the effect that irradiation kills harmful microbes without otherwise altering foods are by no means conclusively supported by research. As has been the case, historically, with so many technologies, especially involving the radioactive elements and the industries that have evolved to make use of them, sooner or later we find out that industry's protestations of safety were in error, disingenuous, or outright lies of convenience. If the FDA and the USDA wish to permit the use of irradiation in food preparations, fine, but let there be a choice, so labelled and identified, of those foods which by law cannot be treated in this manner. Your efforts to mitigate NOSB's ban on irradiation "to solicit comments" (sec. 205.17) should be withdrawn, as they may result in a de facto allowance of the technology.   © 1998 18th Century Industries, Inc.     Please read copyright notice.

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