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Please read about the issues below and contact your Representatives and Senators.

U.S. Capitol Switchboard:  202-224-3121
U.S. House of Representatives: www.house.gov
U.S. Senate: www.senate.gov

Sunset Review of Organic Inputs

At the April 27-30, 2015 meeting of the National Organic Standards Board (NOSB), the board will review more than 200 inputs—fertilizers, pest control products, processing aids, and ingredients—currently allowed in organic production. If you rely on these products, you’ll want to let the NOSB know. If you’ve found an organic alternative, let the board know about that, too.

Inputs under review:




Summary of NOSB process

The deadline to submit written comments or sign up for oral comments is Tuesday, April 7, at midnight Eastern.


Enhancing Agricultural Coexistence

Comment through April 10, 2015.

Read Harriet Behar’s Inside Organics blog:  
“GMOs, organic: ‘Coexistence’ in the belly of the beast.”

The USDA  has reopened and extended its comment period on agricultural coexistence following the “Stakeholder Workshop on Coexistence” at North Carolina State University March 12-13. This workshop to examine how growers of organic, conventional, and genetically modified crops can coexist in U.S. agriculture sparked extensive debate; the USDA has received more than 4,000 comments on the issue.

Highlights from MOSES’ comments to USDA on coexistence:

    • 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.


2,4-D-ready Corn and Soy

Comment period is closed.

Despite pressure to block it from more than 60 members of Congress and half a million citizens, Dow AgriScience’s Enlist Duo™ pro­gram—herbicide-resistant corn and soybeans genetically engineered to tolerate the Enlist Duo combo of 2,4-D and glyphosate—has been approved. A 30-foot buffer zone is required around fields being sprayed.

Note: It’s allowed currently in 6 states—Wisconsin, Iowa, Illinois, South Dakota, Indiana and Ohio.

The EPA is taking comments on whether to register the herbicide in 10 additional states, including Minnesota and North Dakota. Contact your representatives to voice your opposition to allowing Enlist Duo.


Associated Press story, “EPA approves new weed killer for engineered crops

USDA news release on “Measures to Help Farmers Diversify Weed Control Efforts

Read about farmers concerns regarding 2,4-D in the July|August Organic Broadcaster.


Reasons for concern:

  • 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.
  • 2,4-D was the primary ingredient in Agent Orange, the defoliant used in the Vietnam War.
  • Both spray and volatilization drift can devastate adjacent ecosystems, yards and home gardens.
  • 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 30-fold increase in use of 2,4-D, from an estimated 4.2 million pounds at present to over 100 million pounds by 2019.

MOSES’ comments to USDA-APHIS  March 2014


Farm Bill Update

Learn more about how organic fared in the farm bill in the March | April Organic Broadcaster. (online story)



MOSES comments to FDA regarding FSMA

November 2013

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.