Public testimony to the National Organic Standards Board

Six PCC representatives presented testimonies at the the National Organic Standards Board meeting in Seattle, April 26-29, 2011 on the following topics:

Animal Welfare

Aquaculture

Synthetic nutrient additives

NOSB testimony on animal welfare

from Roxanne Green, Redmond PCC Health and Beauty Coordinator

Hello, I am Roxanne Green, an organic consumer with comments on animal welfare.

"Organic" food is now a mainstream item that can be found in most any supermarket in the country. It is time for us to ask ourselves what we want this word to mean. Without a solid base to stand on, the word is virtually meaningless.

As consumers who want to make ethical choices in our purchases, we are willing to pay premium prices. However, we have an expectation that our dollars will be supporting farmers who are adhering to a much higher standard than the industry average.

Along with the regular requirements of organic certification — organic feeds, prohibition of using hormones, antibiotics, or genetically modified organisms — we expect that organic livestock be raised in a healthy, humane environment.

To produce animal products with integrity, the animals should be raised in an environment that allows them to engage in their natural behaviors, move about freely, and be subjected to stressful situations as rarely as possible. The current NOSB Livestock Committee Proposal for organic pork production does not even come close to the standards of industrial scale producers, and falls far below the European Union Organic Standards.

As informed consumers, we already are growing increasingly suspicious of label claims that do not meet our expectations. Consider the recent rash of 'heart healthy' labeling claims that were required to be removed from product packaging. "Humanely Raised," "Local," "Natural," "Free Range" and "Cage Free" don't mean what we have been led to believe they do.

We know what we want — transparency, integrity, ethics and honesty. Please give us some standards that we can believe in. Don't just pay lip service to organic standards, make them really mean something.

We deserve to have access to at least the same quality organics that are available in other countries, if not better. If we hope to ever have a clean and healthy food supply produced in a respectful way, it needs to start here and now.

- April 28, 2011, Seattle

NOSB testimony on animal welfare

from PCC Trustee Julianne Lamsek

I'm Julianne Lamsek, speaking as a concerned consumer. (I also serve on the board of PCC Natural Markets, the nation's largest co-operative grocer, with nine stores certified organic by the Washington State Department of Agriculture.)

I'm here to comment on animal welfare recommendations for poultry and swine.

I understand the pressure you are facing from the nation's largest livestock producers to make organic production as cost efficient as possible. At the same time, I expect that all organic livestock be treated humanely.

When I buy organic eggs or chicken, I expect those hens to spend a good portion of their lives outdoors foraging a vegetated range with sunshine. When they are indoors, I expect them to be in a healthy environment not reeking with ammonia.

I expect hogs to be able to roam about freely and socialize. It's hard for me to understand why the space recommendations are so low — especially compared to the standards of other animal welfare certifiers.

Standard factory farming practices in this country are inhumane. It's not acceptable for organic standards for the living conditions of poultry and swine to just be "a little above the average conventional," except for organic feed.

For these reasons, I advocate at least 2 sq ft per bird indoors for layers and broilers. I'm aware of the EU standard of 43 sq ft and I am dismayed that the United States is so far behind. I advocate for at least 5 sq ft per bird outside, since Organic Valley recommends it as feasible.

I'm pleased the NOSB is attempting to control ammonia levels but the 25 ppm level — cited in the recommendation as "high" — should not be acceptable at any time. Chronic exposure at 20 ppm affects the health and welfare of chickens.

Research shows "a precautionary guideline" for prolonged ammonia exposure at 10 ppm so I believe farm plans must demonstrate control at this precautionary level.

I ask the livestock committee to adopt these recommendations as the highest animal welfare standards in the nation. They are what I and other organic consumers want and expect.

- April 28, 2011, Seattle

NOSB testimony on aquaculture

from PCC Trustee Buzz Hofford

Good morning, my name is Buzz Hofford. I'm speaking as a Trustee for PCC Natural Markets, a certified organic chain of nine stores here in the Puget Sound area and the largest consumer-owned natural foods co-op in the country. In addition to representing 47,000 active members, we also serve more than 100,000 customers a week.

As leaders of Salmon Nation, we ask you to revise your previous recommendations for organic aquaculture, prohibit certification of carnivorous, migratory species and limit certification to closed, land-based systems with vegetarian diets.

Fish that spend their lives in floating ocean feedlots suffer unhealthy conditions, just like cattle in CAFOs and chickens in battery cages. Most ocean fish have strong instinctual drives: wild salmon migrate thousands of miles before returning to the streams of their birth. Confining these fish in cages prevents them from exercising their natural behaviors, violating a core organic principle.

Organic standards also prohibit antibiotics. Yet aquaculture today consumes more antibiotics per pound than any other feedlot industry. CAFOs at sea are no healthier than those on land.

The board's recommendation would encourage aquaculture to continue harvesting enormous volumes of wild fish for feed; this practice is both ecologically unsustainable and unhealthy for consumers. Feed pellets made of wild fish contain high concentrations of PCBs, dioxins and other contaminants, which are then passed on to consumers. These chemical contaminants further violate organic principles.

Floating feedlots violate the organic principle of protecting the natural environment by annually flushing millions of pounds of unfiltered fish waste directly into surrounding marine environments.

Salmon farms expose wild salmon to diseases and parasites, threatening their survival. Every year scientists report elevated levels of sea lice on wild juvenile salmon near salmon farms, resulting in declining populations of wild, native species. Native fish like our prized wild salmon already struggle for survival against ever-increasing environmental threats. Fish farms threaten the long-term viability of these populations.

We strongly encourage you to prohibit certifying migratory, carnivorous fish and limit certification to fish raised in closed, land-based systems with vegetarian diets.

- April 26, 2011, Seattle

NOSB testimony on aquaculture

from Public Affairs Specialist, Eli Penberthy

Hello, my name is Eli Penberthy and I'm speaking as a consumer and as a seafood advisor to PCC Natural Markets.

The board's recommendation to certify farmed fish is flawed as written and must be revised. The marine feedlots of open-ocean aquaculture violate fundamental organic principles. I ask you to revise the recommendation, so only vegetarian species in closed, land-based systems may be certified organic.

Carnivorous fish, such as salmon, tuna, cod and halibut, raised on pellets made from wild fish, must not be eligible to be certified organic. The dioxins, PCBs and other contaminants concentrated in the feed are passed along to consumers. The Environmental Working Group found farmed salmon have 16 times more PCBs than wild salmon.

The board's recommendation for farmed salmon would allow up to 25 percent of the feed to be wild-caught fish. This violates the principle that organic animals must be raised on 100 percent organic feed. It also results in an unsustainable loss of protein — to add a pound of weight to farmed salmon requires 3 to 9 pounds of small fish. Cod, halibut, tuna and other carnivorous species may need up to 15 to 20 pounds.

One-third of the ocean's harvest is herring, anchovies, mackerel and other small fish, which are made into fish meal and oil for fattening farmed fish and animals. The aquaculture industry already uses more than half the world's fishmeal and more than 80 percent of the fish oil. This is simply unsustainable and violates the core organic principle to restore, maintain and enhance ecological harmony and balance natural systems.

Floating feedlots endanger native marine species, flushing unfiltered fish waste into the environment, while Sea lice and other parasites and diseases are rampant and linked to die offs of juvenile wild salmon and other fish. Sea Lice are showing resistance to chemical pesticide treatments, such as the pesticide emamectin benzoate, or SLICE.

Confining migratory fish with strong instinctual drives, such as salmon, in cages prevents them from exercising their natural behaviors, violating another core organic principle.

Current recommendations are too broad and should not automatically include all species. They fail to meet the high standards that consumers expect.

A better approach would be to consider for certification closed, land-based systems that recirculate water, collect waste for fertilizer, can provide organic feed for vegetarian fish, and do not threaten wild stocks. Catfish and tilapia would be a good place to start.

- April 28, 2011, Seattle

NOSB testimony on synthetic nutrient additives

from director of public affairs, Trudy Bialic

Our company has nine certified organic stores, soon to be 10, and 46,000 active member owners. We're the largest consumer-owned and consumer-operated grocery retailer in the country. I'm speaking today for management.

We realize that the topic of synthetic nutrient additives was postponed till the fall meeting. But we've already had to face consumer questions and concerns so we're compelled to share our experience.

It's very easy to empathize with the expertise and time required to review individual additives. Yet the recommendation to allow any synthetic additive deemed a nutrient - without petition and review - we feel, is an abdication of responsibility vested in NOSB for good reason.

Organic consumers expect that if ANY synthetics are allowed, each one is vetted through the formal petition and review process. To surrender the power we fought so hard to give you, to protect the consumers' interest — hard-fought, hard-won — to surrender that authority voluntarily betrays the public trust.

When a grandmother recently asked if the DHA and ARA in a certain infant formula was safe for her grandson, we had to answer in all honesty - in the interest of transparency - that NOSB did not vet those additives, and yes, we realize there are complaints of side effects.

For these reasons, we feel that manufacturers that have been using DHA and ARA - knowing the petition and review process - should not get an automatic pass.

PCC Natural Markets has discontinued - suspended - the sale of organic products with these additives. We pulled the infant formula, flax oil and children's vitamins two weeks ago.

We support enforcement action that would require removing these questionable from products bearing the organic seal.

We ask you to honor the mandate given NOSB to protect the consumer's interest.

Please ensure that synthetic additives of any kind - nutrient or not - are the rarest exceptions, not business as usual, and that each one is reviewed individually from a precautionary position.

Consumers are very grateful for the NOP's Age of Enforcement. Thank you.

- April 28, 2011, Seattle

NOSB testimony on synthetic nutrient additives

from former PCC Nutrition Educator, Leika Suzumura

I am speaking today as a consumer, nutritionist, and most importantly a mother. I will be addressing my concerns for synthetic additives and nanotechnology within the organic standards.

I choose organics because I TRUST the values of organic, based principally on trusting nature, which always has nourished people throughout time.

I am concerned about the safety of additives allowed under the organic standards that did not go through the proper process, with focus on the DHA being added to milk. Mothers are trusting the "organic" label - that it is safe and properly screened by the organic standards.

Likewise, I am concerned that nanotechnology is allowed in organics - especially without any labeling — because although nano-sized particles exist in nature, we do not know what the long term health effects of lab- created nano-particles have on us at a cellular level, especially particles like titanium dioxide.

I am speaking today to show my support of the organic standards board to follow the legal procedures to ensure that what is included in organics reflects the integrity we are counting on as consumers. I say this not only for the health of myself and my children, but in thinking and honoring the health of my great, great grand children.

We cannot sit still on the ideology that they are leaders of tomorrow when we need to take action and leadership today.

- April 26, 2011, Seattle

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