Your voice has an impact! Please read about the issues outlined below and contact your Representatives and Senators to incite action.
US Capitol Switchboard (202) 224-3121
Comment on 2,4-D Environmental Impact Study
Comment period extended to March 11, 2014.
The USDA has released its draft Environmental Impact Study (DEIS) on 2,4-D ready corn and soybeans. 2,4-D is known by Dow’s brand name “Enlist.”
Read USDA greenlights Dow’s 2,4-D seeds from Pesticide Action Network.
What farmers need to know about Dicamba and 2,4-D resistant crops (1 MB PDF) from the Pesticide Action Network and National Family Farm Coalition.
Points to consider:
- 2,4-D was the primary ingredient in Agent Orange, the defoliant used in the Vietnam War.
- 2,4-D has been linked to cancer, Parkinson’s disease, endocrine disruption, and reproductive problems. Children, in particular, are extremely vulnerable to 2,4-D exposure.
- 2,4-D is much more harmful to plant life than RoundUp (glyphosate). Specialty crops (like grapes, tomatoes, beans and sweet corn) and non-GE soy and cotton are extremely sensitive to 2,4-D.
- Both spray and volatilization drift can devastate adjacent ecosystems.
- Industry tests show that 2,4-D is contaminated with dioxins—often referred to as the most toxic substance known to science. Dioxin contamination in the rivers and soil around Dow Chemical’s headquarters in Midland, Michigan is the highest ever found by the EPA, and has been linked to increased breast cancer rates in the contaminated areas.
- Dow Chemical is calling GE 2,4-D corn and soy the solution to glyphosate-resistant weeds. GE crop systems caused the “superweeds” in the first place. Like Roundup before it, 2,4-D is only a temporary solution that will require more and more toxic chemicals leaching into our environment and food supply.
- The Organic Center’s agricultural scientist Charles Benbrook projects that widespread planting of Dow’s Enlist corn alone could trigger as much as a 25-fold increase in use of 2,4-D, from an estimated 4.2 million pounds at present to over 100 million pounds by 2019.
What you can do:
View the USDA news release regarding the Environmental Impact Study.
Submit comments online.
Submit SNAIL MAIL comments to:
Docket No. APHIS-2013-0042
Regulatory Analysis, and Development, PPD, APHIS, Station, 3A–03.8
4700 River Road Unit 118
Riverdale, MD 20737–1238
‘Enhancing Agricultural Coexistence’
Comment period is closed.
Read Harriet Behar’s Inside Organics blog: “GMOs, organic: ‘Coexistence’ in the belly of the beast.”
The USDA was seeking ideas on how GMO and non-GMO producers can coexist. GMO contamination threatens access to organic and non-GMO markets. Prevention, not communication, is what’s needed.
- The management and economic burden of GMO “coexistence” currently falls only on the nonGMO farmer, who needs to avoid contamination and create large buffer zones, which leads to some crop loss.
- The nonGMO farmer should not be asked to find and discuss planting protocols with whomever is managing the neighboring land; the majority of farmland is managed by renters who use a variety of custom operators.
- Asking GMO farmers to follow voluntary planting protocols has been shown to be ineffective. There needs to be some enforcement.
- GMO crops can damage non-target species such as monarch butterflies, pollinators, and aquatic ecosystems by loss of habitat and/or the insecticides present in GMO crops & residues.
- We need a regulatory framework that places the burden of contamination prevention on the USDA and the biotechnology industry. NonGMO farmers cannot control the weather and other aspects of farming that may lead to unintentional contamination.
- Farmers cannot guarantee a planting date, due to variables such as weather, equipment breaking down, fertilizer or seeds not arriving on time, or lack of time in a day.
- The stacking of numerous insecticides in one seed to deal with resistance, along with the introduction of 2, 4-D herbicide resistant corn and soybean, are proof that the more this technology is introduced into our environment, the less effective it becomes. This will lead to the need for more toxic materials to deal with a growing number of resistant weeds and insects.
Farm Bill Update
Learn more about how organic fared in the farm bill in the March|April Organic Broadcaster. (online story)
Feb. 6, 2014
President Barak Obama signed the new farm bill into law today at Michigan State University in East Lansing. It’s officially called theAgriculture Act of 2014.
Your phone calls and comments in support of organic agriculture made a difference in the final bill, which contains funding for many programs supporting organic:
- Organic Certification Cost Share for all 50 states
Organic producers and processors can get a “rebate” on the cost of organic certification. Although the payments and time frame are not clear, there is funding for crop year 2014 and beyond.
- Organic research
- Organic data collection
- Increased availability of crop insurance paid at the organic price
- Additional funding for the National Organic Program along with stronger enforcement tools to protect the organic label in the marketplace
- Further exemptions from conventional check-off programs were included for organic producers.
- The bill also would allow the organic community to develop their own check-off type program, to be managed by the USDA. Before any check-off would be implemented, there would need to be a clear proposal and an affirmative vote of all proposed organic participants.
Beginning farmer programs, farmer’s market promotion and other programs that make a critical investment in building a strong agricultural production base were present, as well as linking crop insurance to conservation compliance. Direct payments through the Farm Service Agency were cut. More money was given for funding food banks. A dairy income insurance program was included, providing for a safety net to help farmers when feed costs are high and milk prices are low.
Many Democrats who did not vote for the farm bill cited the lack of commodity payment reform and cuts to food stamps as their reasons. Many Republicans who did not vote for the bill cited the overall cost of this bill as their reason.ents in the bill include the lack of payment limitation reforms that were present in both the House and Senate bills that went to the conference committee. The removal of an item that was approved before conference by both parties is highly unusual. Payment limitations on crop insurance to millionaires was also not included. Conservation programs were not funded at the levels necessary to make the important investment to provide for healthy and productive working lands. Approximately 850,000 households in the U.S. will see a cut of $90 per month in their food stamp benefits, directly resulting from cuts to the SNAP program.
Click here to see a list of how each House member voted.
Jan. 13, 2014
Contact your representatives to get support for the National Organic Certification Cost Share Program. Tell them how this program:
Keeps Organic Production in the United States
Domestic production of organic products cannot keep up with growing demand for organic products. Unless we continue to grow organic production in the United States, we will continue to rely on imported product to meet this demand. These are jobs that can and should be kept here in the U.S.
Helps Ensure Integrity and Consistency of the Organic Label
If organic farmers and handlers move away from the rigorous organic certification processes because of cost considerations, it will undermine consumer expectations that food marketed as organic meets strong and uniform standards.
Encourages Value-Added Processing Infrastructure for Organic Farmers
In many cases, the costs of organic certification for a processing facility outweigh the benefits for the small volume of organic product handled. Without this cost share, organic value-added processing infrastructure could shrink, at the same time as consumers are demanding more product.
Keeps a Diversity of Farms Certifying as Organic
Certification cost share offers a modest, partial (75 percent) reimbursement of up to $750 annually per certification. Without this assistance, many small and medium scale operations may stop getting certified all together.Read more about the threatened programs that support organic farming.
Read more about this issue and see conference committee contact info on the National Organic Coalition’s website.
MOSES comments to FDA regarding FSMA
MOSES Organic Specialist Harriet Behar submitted two multi-page documents to the FDA regarding the proposed rules for implementing the Food Safety Modernization Act (FSMA), explaining strong concerns about the impact the rules would have on organic and sustainable farming.*
Among the major concerns with the proposed rules:
- They contradict existing National Organic Program regulations.
- They create incentives for mono-cultural farming operations, and don’t respect the value of diversified farms.
- They impose burdens and costs that would accelerate consolidation and concentration for generations to come.
- They skew against organic and sustainable farming practices that foster biologically active soils. Rather, they push our food system toward chemical-intensive farming practices, which creates soil sterility and may actually contribute to pathogen persistence in food.
- MOSES is concerned about the large-scale use and release of chlorine and/or other antimicrobial pesticides into the environment that may be used to comply with the proposed microbial standards and treatment requirements.
MOSES’ comments (see PDF) include detailed references to the sections of the proposed regulations that are of concern, and provide specific recommendations to improve these sections. Highlights of these recommendations include:
- FDA should not require farms to perform operational assessments or develop food safety plans in its final Produce Rule. FDA should not require farms to register with FDA in the final Produce Rule.
- The $25,000 gross sales exemption should be retained, but modified to apply solely to covered produce as provided by FSMA.
- Standards directed to agricultural water fails to meet the requirements of FSMA for a science- and risk-based approach and for flexibility in application, and must be thoroughly revised.
- FDA must align its biological soil amendments of animal origin standards with the National Organic Program requirements and on-farm practices widely used in diversified, sustainable, and conservation-based production systems.
- FDA should more strongly support conservation in the final Produce Rule by incorporating statements and concepts from the preamble into the regulatory text, in the definitions, training requirements, and domesticated and wild animal standards.
- Produce rule must support diversified crop-livestock farming systems and clarify grazing.
- FDA must clarify, as part of a revised proposed Preventive Controls Rule, that the sale and distribution of food through a community supported agriculture program, roadside stand, farmers’ market, or other direct-to-consumer platforms is included in the definition of sales direct to consumers for purposes of defining a “retail food establishment,” as required by the FSMA statute.
- FDA should adopt a threshold of at least $1,000,000 and apply it not to sales of “all food” but to sales of food regulated under the Preventive Controls Rule.
- To ensure sufficient flexibility for a diverse array of food businesses, FDA should establish an outright exemption from the Preventive Controls Rule for businesses with $25,000 or less in annual average monetary value of product covered by the Preventive Controls Rule over a three-year period, adjusted for inflation.
- FDA should retain the list of low-risk activities/food combinations and add additional low-risk, value-added processing activities such as pickling, baking with grains, extracting oils, and making syrups.
- FDA should change the definitions of “farm,” “facility,” and “manufacturing/ processing” to align with the common-sense understanding and practice.
*Many of these concerns were identified in documents from the National Sustainable Agriculture Coalition and the National Organic Coalition.