I still believe the rule can and will be substantially improved as a
result of public comments received. There will no doubt remain some issues
that Congress will need to fix, but that is routine whenever a major new law
is translated into implementation rules, and can be accomplished smoothly
soon after the rule is published as final, and perhaps even before. If most
of the problems can be fixed through the rule-making process, a "technical
corrections" bill could be passed dealing with the remaining issues that
USDA feels it can not fix without guidance from the Congress.
My guess at this point is that Consumers Union comments will focus
on a range of labeling issues; problems with the accreditation process; the
rules governing pesticide residues and testing; role of GEOs in organic
production; and ways to simplify and tighten up the rules so that it is
easier for consumers to know what "organic" means.
Because of the number of requests for recent Sanet posts re the
rule, we decided to post some of the key substantive components of the
dialogue the last couple of months that has played out on Sanet. Just this
a.m., we added a thoughtful piece by Fred Kirschenmann on some of the big
issues. We will continue to post additional items that add to the
discussion. This material is accessible at
<http://www.pmac.net/nosrule.htm>, or via the PMAC "What's Hot" page.
chuck
Note New Address!!:
Charles Benbrook 208-263-5236 (voice)
Benbrook Consulting Services 208-263-7342 (fax)
5085 Upper Pack River Road benbrook@hillnet.com [e-mail]
Sandpoint, Idaho 83864 http://www.pmac.net
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