June 4, 2000

U.S.D.A. National Organic Program

Program Manager Keith Jones

This Letter refers to Docket Number: TMD-00-02-PR, the proposed rules on a national organic standard.

My name is Gabe Gibler. I live in the state of Idaho. My writing is intended more or less only to add my voice to the numbers and let this government that presides over the land in which I live know what I desire, in the hope that it might have some effect on the national organic standards that are being created.

I work with a business called Paradise Farm Organics, producing backpacking pouches filled with organic dehydrated and freeze-dried ingredients. I have helped from time to time with the farm work on various farms, usually harvesting potatoes (not surprising, given that I live in Idaho, huh?!) and gathering herbs and vegetables from my mom’s garden. I also shop and volunteer at the local Food Cooperative. I do my best to buy as many organic vegetables, grains, and meat and dairy products as I can, in order to support the choice of growing our food in a healthy, mindful way.

I do not and can not presume to know all the ins and outs of farming, food or of the sustenance of healthy life (human or otherwise). I can only write what I want and ask for what seems appropriate to how I wish to live and the world I wish to live in.

First I’ll present what I consider to be the essence of organic defined.

- Webster Dictionary definition of organic 1: "noting or pertaining to a class of chemical compounds that formerly comprised only those existing in or derived from plants or animals, but that now includes all other compounds of carbon."

- Webster Dictionary definition of organic 2: "pertaining to, characteristic of, or derived from living organisms."

- Webster Dictionary definition of organic 8: "of or pertaining to the basic constitution or structure of a thing; constitutional; inherent; fundamental."

- Webster Dictionary definition of organic 9: "developing in the manner of living organisms."

- Webster Dictionary definition of nature 5: "the particular combination of qualities belonging to a person, animal, thing, or class by birth, origin, or constitution; native or inherent character."

- Webster Dictionary definition of nature 1: "the natural world as it exists without human beings or civilization."

- Webster Dictionary definition of natural 1: "existing in or formed by nature."

Keeping these definitions in mind and adding to them my own experience of organic farming, I would describe organic agriculture as: any method of growing, cultivating or raising living organisms that facilitates them in their own natural process of development, with as little interference in that development as possible, towards the goal of providing a rich source of proteins, fats, carbohydrates, fiber, vitamins, minerals and other trace nutrients and living organisms- all of a chemical composition appropriate for use by the natural human body- to maintain an energetic, happy, disease-free state of life.

Organic, by definition, pertains to life or any inherent aspect of life. Organic agriculture should be a method of cultivation that is an extension of the way (or methods) in which life already exists, but, of course, there must by necessity be a few more components added to the picture. Since agriculture is by nature an intensification of natural processes (the selection and concentration in an area of suitable plants or animals), there must necessarily be some methods of cultivation that are concentrations of natural processes (gathering up food or nutrients to replenish those depleted by use; defense against disease and damage; containment). So in keeping with the idea of organic, these methods of cultivation should be provided for in a manner as close to that of nature as possible.

I’m sure most mechanical tools and processes, like the traditional farm tools, tractors, sorters, storage tanks, etc. and weeding, fencing, plowing, selective breeding, etc., applied in an intelligent manner, would be in accord. Also permissible would be any concentration of chemicals and substances derived and extracted directly from natural sources and used only in quantities necessary to be effective for the purpose, but not incidentally destructive, such as manure or compost, the cleanest water possible, perhaps toxins produced by a native plant to defend itself, used in minimum quantities. But here my knowledge is limited.

The limits of inclusion should be set to exclude any methods where the processes of nature have been circumvented (such as genetic engineering), overwhelmed (pesticides and herbicides [poisons in greater concentrations than are ever naturally produced or sustained]; domesticated cattle obliterating a waterway) or where no such condition ever existed (chemicals created in a laboratory; irradiating food; chickens with no space to roam). If a step is added to the process of food preparation, a step not in nature or fundamental to the production of a recognizable product, such as grinding to make flour or carving out a steak, then apply the name of that step to that product. If it’s "organic", that’s the basics. If it’s been irradiated, that’s called "irradiated". If it’s natural characteristics have been modified out of the field and outside of the plant or animal’s natural life and reproduction cycle, that would be called "genetic engineering". If you can allow someone to patent it, it’s not organic because it’s not universal and it’s likely not natural. If a chemical is produced and concentrated but can’t be scientifically named or numbered exactly the same as the natural source, it’s not "organic".

I have always envisioned organic agriculture as a method of farming that could be practiced by any human at any point in our history, so long as they are familiar with the earth and it’s natural cycles; humans with an intimate knowledge of all the life that surrounds them, choosing to make their living in a fashion as undisruptive to their world as possible, yet providing as comfortable and certain a means of existence as desired.

I am not necessarily opposed to "technology", or exploration of the physical basis of our life and world. I am, however, strongly opposed to the hasty implementation of inadequately studied "technologies", especially for the purpose of individual short-term profit. I think it wonderful if people’s time may be freed up for doing more than merely surviving, but why rush forward until we know for sure whether dumping a load of herbicides on our food will destroy us or our vital health and the health of the planet we are dependent on for life? Humans have managed to exist for this long, so sit back, I say, and get to know the world you’re in first, before you manhandle and manipulate it and all the other life upon it.

It is stated multiple times in the summaries of changes that those people who commented on the previously proposed standards don’t want hormones, or sewer sludge, or genetically modified crops, etc. included in the standards because they feel that these are dangerous. Then, each time, the author so pointedly states that those techniques may offer benefits and there is no evidence to support claims of ill-effects, as though trying to promote and patronize the food "industries" and agriculturists utilizing such methods. Simply because there is no satisfactory evidence of damage done by these new technologies is no reason to exonerate them. If there is no proof for certain one way or the other, then why risk it? There may be benefits from using hormones and chemical compounds, but the costs just may outweigh the benefit. Is there any conclusive research demonstrating the balance of cost and benefit? Are all the benefits and costs even known? "Certified Organic" is a recognizable choice for all those who don’t wish to trust their lives or health to half-realized "sciences" and their technologies or the greedy ushering of corporations. Do not contaminate this classification with methods permitted for use anywhere else that the food "industry" could wish.

Recognized and pure organic standards are a haven for those who wish to proudly sell their wares for what they are, distinct from the now conventional products. If the companies and individuals producing and using chemical and intensive agriculture are so proud and sure of those practices let them stand on their own and proclaim what they use and how they do it. Let their product be labeled and don’t let them hide their creations behind a mask called "organic" that some people consider to be a friendly face (with reason).

Another thing I would like to mention is the very length of the proposed standards. I have not read most of the rules nor do I intend to waste my time doing so. Perhaps then it is unfair what I will say, especially since my own letter is so long. However, my letter is an attempt to validate and persuade, so everything needs to be explained and my view presented. However, definitions and laws should be more concise and accessible. If they are not, then I must question their intent. I must question the integrity of any law that cannot state it’s basic tenets in a few understandable words. Granted, the specific guidelines and rules for enforcement do cover a broad range of topics- farming and all it’s variables and methods; animal husbandry; the management for the entire plan- and so must be more intricate and wordy. However, these can be stated separately, and the official definition made clear by standing on it’s own.

Therefore, I would like to see a concise definition, a sort of ideal or moral guideline, created first and written into law that would then bind the authors of all the further definitions, specifications and rules to the ideal that is so obviously desired by those who want organic products; a law that would exclude from the formation of a national organic standard the manipulations and loopholes of those who seek only to profit or inevitably smother truly organic standards in favor of their own goals. They can have and work toward their goals, but they can do it over there and separate from we who care about what organic agriculture really is.

So I would like to see more accessible language, format and length. As an example, the summary seemed to say all that needed to be said, and with the addition of a list of what may be included for use in organic agriculture (i.e. "the National List"), and perhaps a list of exclusions to clarify the inclusions (all else being assumed to be excluded) and any necessary definitions, the summary would be a perfect statement of what a nationally defined organic standard should and is wanted to be. Then all the management details and laws can be worked out separately, so that it will be certain that the initial purpose of organic agriculture is solidified. I don’t think all the detailed implementation language needs to be made clear, since I can learn that vocabulary as I apply myself to that occupation, but I should be able to feel confident that an acceptable ethic is going to be enacted and enforced within them.

For the most part, so long as the essential spirit of organic farming is encapsulated in a primary definition and faithfully carried down through all the necessary specifications, with no room for weasels to sneak into the henhouse, and then made more easily available for the average citizen to check on, I think all will be well made.

I will give quick note to some final concerns.

- Be certain to create a system, if create a system you must, that does not put much of any financial burden on the small farmer or the certifiers that will keep the garbage out. If what I hear is correct, that conventional farmers are subsidized as much as they are, then I’m sure the government can make room in it’s budget for the small farms that will need a test done now and then.

- Do not include restrictions prohibiting any other kinds of language that state higher levels of certification or imply organic when a product is not officially certified so. I’m sure people can be smart enough to recognize the officially marked and licensed product, if that is what they seek.

- Imitating European standards would be perfectly acceptable, or even preferable, if the N.O.S.B.’s recommendations are not going to be followed. The Europeans have much more experience and seem to have more sense about maintaining a healthy environment for their crowded world.

Heck, if in doubt as to whether to include something as permissible for use in organic food, just ask yourself "Would I eat that? Would I expose myself to that? Swim in it, touch it, breathe it? Would I like that done to myself?"

Would you eat pesticides or heavy metals, even in the tiny quantities ‘allowed" in food? Would you allow yourself to be irradiated? Swim in sewer sludge, or touch it or breathe it? Would you permit yourself to be the experiment in a genetic modification test? Would you find it very healthy to be confined and injected with antibiotics? Would you eat or put baked human poop in your food? Or even near it?

If you answered "yes" to any of these questions, well just remember that you’ll probably have the option for a long time of buying food that has been so treated, but that some of us would like to be certain of our option to consume the alternatives and be confident in their integrity.

I believe that organic farming should be what humans have been able to do for thousands of years, with room to include new innovations that are appropriate to the style and intent of organic agriculture: to cultivate a vibrant healthy crop and raise vibrant healthy animals in a manner as similar to nature’s own design as possible and that sustains our own health and the integrity of the land upon which they are raised in every way for many generations yet to be.

ORGANIC AGRICULTURE- any method of growing, cultivating or raising living organisms that facilitates them in their own natural process of development, with as little interference in that development as possible, towards the goal of providing a rich source of proteins, fats, carbohydrates, fiber, vitamins, minerals and other trace nutrients and living organisms- all of a chemical composition appropriate for use by the natural human body- to maintain an energetic, happy, disease-free state of life.