[MPWG] MPWG:Transparency

[DianeDonCarlos at aol.com]

I am a "lurker" on this list, but had to jump in. Many good comments and 
thoughts re: organic. But isn't the issue transparency?
The USDA created a lengthy definition of, and then trademarked the word 
"organic." The "rule" is contained in 7 CFR (Federal Register) part 205 and reads 
for 136 pages if you include what I call the pre-ramble and the post scripts. 
The actual definition is contained in 25 pages. The National Organic Program is 
administered by the Agricultural Marketing Service which is an agency of the 
USDA. If I CHOSE to label my product with the word "organic" I must purchase 
the use of the word from the USDA according to the NOP definition and have my 
product inspected and my label approved. Hence the cost and the paperwork. The 
discussion re: farming/subsidies/poverty, fair trade, organic vs. 
conventional, standardized vs. whole plant, wildcrafted vs. cultivated, etc. etc. is all 
important, but I think missing the value of the NOP for the issues facing the 
herbal products industry. The document is a model for ensuring transparency, in 
this case to the "organic" standard. But any standard could be applied. 

Certified Organic products by NOP definition carry transparency from seed to 
shelf. All points in the growing, production, transport, processing, and 
labeling are inspected. Certified Organic on the label is the only single 
certification/seal to my knowledge which affords this level of transparency. As a 
consumer, I tend towards the Certified Organic label because it affords me that 
transparency, regardless of whether I feel I want "organic" or not.

Certified Organic herbal products may be from cultivated and/or wild crafted 
raw materials. Either way the certification dictates that the raw material is 
not genetically modified, and is grown and processed organically. If the raw 
material is wild harvested, the stand must be "sustainably harvested". The 
official definition reads not destructive to the environment and will sustain the 
growth and production of the wild crop. OK, much room here for refinement. I 
can hear all the comments re: the NOP sustainable definition-clearly the 
inspector must know something about the wild crop, and do we even really KNOW how 
much C. racemosa, for example, can be harvested in a single stand and meet the 
definition? But remember that the wild crafting standards are within the 
guidelines of the larger rule. All other definitions apply re: seed, soil, 
production, processing, labeling, transport etc. AND record keeping. If I was 
inspecting a wild crafter I would have to see........actually touch and smell and 
inspect........each specific area where the raw material was taken. And the 
associated permission/permits from the landowner, and then have to verify that the 
soil was free of prohibited substances for 3 years etc. etc. It is quite a 
probe!!

I have been inspecting organics for three years now. Everything from wild 
harvested NTFP's to salsa to baby food to soybeans. I meet yuppies, hippies, 
profiteers, off-the-grid barefoot folks in poverty, Quality Control Managers in 
suits, split operations growing organic and conventional side by side, and 
everything in between. What I ALWAYS find, or rather demand, is transparency. If I 
don't find it, the producer is cited for noncompliance and is unlikely to be 
certified. The system works, and I think it is a GREAT model for ensuring 
transparency.

And it is voluntary.  Remember you are paying for the use of the word, with 
it's USDA regulated definition. Anyone can grow food for themselves and others 
in any way they chose. Much the same as you can make moccasins for yourself 
and others. You just can't label them NIKE if NIKE doesn't say it's OK.

Diane Don Carlos
Herbalist, Organic Inspector
Sweet Farm
33735 Beech Grove Road
Rutland, OH 45775
740-742-1714
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