On November 6, just one day after Washington State’s I-522 GMO labeling bill was narrowly defeated, USDA moved to deregulate two new GMO soybean varieties and a GMO apple genetically engineered to resist browning. Additionally, reports indicate that FDA may soon approve GMO salmon – the first genetically engineered animal for human consumption.

In approving Monsanto’s GMO soy, MON 87712, genetically engineered to produce higher yield by splicing in a light-sensitive gene from Arabidopsis thaliana or the mouse-ear cress plant, a common weed in Europe, USDA said in a Federal Register notice that it evaluated data submitted by Monsanto, an analysis of available scientific data, and public comments in determining that the GMO soybean is “unlikely to pose a plant pest risk” and is of “no significant impact.” At the same time, USDA recommended deregulating an herbicide-resistant GMO soybean made by BASF, plus a GMO apple genetically engineered to resist browning when sliced. The comment period for the BASF herbicide-resistant GMO soy and the GMO apple ended on December 10.

Monsanto also hopes to garner approval in 2014 of GMO corn, soy and cotton genetically engineered to be tolerant to applications of dicamba and 2,4-D (also known as Agent Orange), two potent and toxic synthetic herbicides that growers have had to resort to, as weed resistance to glyphosate, or “Roundup” has increased dramatically as a result of its overuse in GMO crop production.

In fact, GMO crops have increased overall pesticide use in the U.S. by 404 million pounds from 1996 through 2011, said Washington State University researcher Chuck Benbrook, Ph.D., in his 2012 study, “Impacts of Genetically Engineered Foods on Pesticide Use in the U.S. – the First 16 Years. According to USDA, glyphosate use alone increased by more than 6,500% from 1991 to 2010. Contrary to biotech’s claims that GMOs reduce the need for chemicals, overall pesticide use in 2011 was 20% higher on each acre planted to a GMO crop, compared to pesticide use on acres not planted to GMO crops, reported Benbrook.

The GMO apple, marketed under the “Arctic” brand by Okanagan Specialty Fruits in British Colombia, uses controversial technology originally developed in GMO potatoes to suppress the gene that turns apples brown when sliced. The GMO apple’s creator says browning has economic costs and that it has already engineered Golden Delicious and Granny Smith apples, with Fuji and Gala varieties next in line. Opponents of the GMO apple say browning is a natural indicator of an aging piece of fruit, and along with organic growers are concerned about GMO contamination of orchards, both organic and non-GMO, while also fearing that negative consumer perception may lead to a decline in apple sales in general.

Independent studies have found risks associated with the technology used in GMO apples. While most existing GMOs are designed to make new proteins, reports Melody Meyer, VP of Policy and Industry Relations for UNFI and President of the Organic Trade Association, in her blog Organic Matters, GMO apples make dsRNA in order to alter the way genes are expressed. Recent research has shown that dsRNA can transfer from plants to humans and other animals through ingesting food or by inhaling dust from the plant or absorption through the skin, and while RNA is a normal component of all cells, in dsRNA form it can have effects that depend on the species and tissues exposed to it.

Additionally, recent reports indicate that FDA may approve GMO salmon before the end of the year or in early 2014. The AquAdvantage salmon, created by Massachusetts-based biotech firm Aqua Bounty, is genetically engineered with a Chinook salmon growth gene and an “antifreeze” gene from an eel-like fish called the ocean pout, which makes the fish grow twice as fast as naturally occurring salmon. Paving the way for the prospect of imminent approval in the U.S., in late November Canada became the first country to approve commercial production of genetically engineered salmon eggs, stating that a panel of independent transgenics and fish containment technology experts found no risk to the environment or human health when the eggs are produced in contained facilities. Canada has not yet approved GMO salmon for human consumption.

Aqua Bounty assures regulators the safety of its production system, which includes producing the GMO salmon eggs in containment facilities on Prince Edward Island in Canada and then shipping them to a facility in Panama for maturation and processing before shipping cut fillets to the U.S. and other markets that allow genetically engineered foods. However, opponents stress that GMO salmon could escape into nature and threaten native species, and that there may be higher risk of cancer and allergies associated with consumption of GMO salmon. Also, recent reports have documented troubles at Aqua Bounty’s facilities in Panama, including lack of legally required permits and inspections, including a wastewater discharge permit, “lost” GMO salmon, and routine, destructive flooding in the area of the facility.

Several major retailers, including Whole Foods, Trader Joe’s, Aldi and Target, have announced they will not sell the GMO salmon in their stores. Also, in November, U.S. Senators Jeff Merkley (D-OR), Jon Tester (D-MT) and Mark Begich (D-AK) co-sponsored a petition calling for the FDA not to approve the GMO salmon. To date, nearly 100,000 people in all 50 states have signed the petition.

But is it kosher? The Orthodox Union (OU) says GMO salmon is kosher, because it has fins and scales. However, eels, which lack scales, are not considered Kosher, creating a dilemma for observers who enjoy salmon lox with their bagels. “Creation of a part-fish, part-eel seems impermissible as a violation of the Torah’s prohibition to mix species,” says writer Lisa Kassner in the Jewish Journal. Natural Food Certifiers, is one of the few certifiers offering Organic, Kosher, and Non-GMO verification with its GMO Guard program, as well as Gluten Free and Vegan verification. NFC announced in April that it would not allow its “Apple K” logo to appear on products that contain GMOs, including the proposed GMO salmon.

AgriSystems continues to remind clients and consumers to make informed choices and let your voices be heard. If you prefer non-GMO ingredients, continue to look for and purchase currently available Certified Organic and/or Non-GMO verified products wherever possible.

OTA Food Safety Task Force urges FDA to base proposed produce safety and preventive controls (HACCP) rules on science and data, and not to conflict with existing USDA National Organic Program regulations.

While undeniably important as a major step in improving the safety of the United States’ food supply, FDA, as part of the Food Safety Modernization Act (FSMA), issued proposed rules that would have major impact on growers and handlers of organic produce.

In conveying the concerns of organic producers, the Organic Trade Association assembled a Food Safety Task Force, of which Agrisystems International served as a member, to analyze more than 2,000 pages of proposed regulations and provide FDA with key scientific data and comments to ensure the proposed rules align with the good and safe practices of certified organic growers adhering to strict USDA National Organic Program standards.

Consensus across the organic industry is that the current proposed rules as drafted could potentially decrease or eliminate organic products, and increase prices due to limited supply for consumers. Based on weekly task force meetings, member surveys to gain input on key concerns from organic industry constituents, and input from experts, OTA submitted comments before the November 22 deadline.

The key messages from Agrisystems International and the organic industry to FDA:  base food safety rules on science; don’t be overly prescriptive; and don’t conflict with existing USDA NOP regulations.

Full OTA Task Force comments to FDA on the proposed Produce Safety Rule can be reviewed here. Also, click here to review full comments regarding FDA’s proposed preventive controls (HACCP) rule and its potential impact on organic producers.

Proposed Produce Safety Rule

A primary concern for organic produce growers and handlers is FDA’s proposed imposition of a 9-month interval for the application of untreated manure to fields, and a 45-day interval for the application of compost containing any animal matter. Currently, the USDA National Organic Program requires a 90- or 120-day (situation dependent) minimal application interval for untreated manure and no application interval for composted manure. Feedback provided by OTA to FDA included:

  • Compost/Manure Application Intervals –OTA’s Task Force provided key data to reflect that FDA’s proposed 9 month application interval would be an economic burden to organic producers; may be in regulatory conflict with current USDA NOP precedent; and may not need to be that long to provide adequate food safety under certain controlled circumstances.
  • Agricultural Water – Under the proposed rule, testing methods and intervals are very prescriptive, said the organic industry task force, which recommended removing prescriptive metrics from the rule itself, and allowing industry the flexibility to create risk-assessment and testing controls based on the individual level of risk for that entity, similar to HACCP methodology.

Preventive Controls (HACCP) Proposed Rule

Agrisystems International, along with the OTA Food Safety Task Force, recommended the following guidelines to FDA in evaluating proposed preventive controls (HACCP) in organic production:

  • Don’t reinvent the wheel. Look to other regulatory rules already in place that address HACCP for processing (e.g., FDA seafood and juice; USDA meat), and ensure there are no conflicts.
  • Ensure that there is no conflict for mixed-use operations that both produce and package produce, so that it is clear whether they must meet one or both of the rules.
  • Focus on Risk and Supplier Verification, and less on “who owns the farm.”
  • Don’t discount other current and effective food safety programs that may already in place at the farm level, such as Good Agricultural Practices, or other third-party verification programs.
  • Periodic testing should be flexible enough to allow for the specific needs of the facility to be addressed in their food safety plan. Finished product testing is not an effective method of control.

In general, we are in agreement that food safety is everyone’s responsibility, and we appreciate the effort by FDA in the proposed rules to create structure to address food safety risks with human consumption of produce that is generally consumed raw. However, Agrisystems International will remain vigilant and involved on behalf of organic producers and our clientele in ensuring that any new food safety rules are aligned with regulations governing producers under the National Organic Program.

Not waiting for the government to take the lead in the labeling of genetically engineered or GMO foods, Whole Foods Market announced in March that it will require GMO transparency for any products sold in its stores by 2018, making it the first national grocery chain to set a deadline to label foods that contain GMO ingredients. Whole Foods also will require labeling for meat and dairy products if the animals were fed GMO grains. Certified organic foods will not have to carry the label since by definition, organic foods are prohibited from using GMO crops or ingredients. According to Co-CEO A.C. Gallo, the nation’s leading natural and organic products grocer is seeing sales increases of 15% to 30% for non-GMO verified products.

Whole Foods told USA Today that is currently sells more than 3,000 products that have gone through the non-GMO verification process, more than any other retailer in North America. Additionally, leading grocers including Whole Foods Market, Aldi’s, H-E-B, Trader Joe’s and PCC Natural Markets announced that they would not sell genetically engineered salmon, if FDA approves it. “We are committed to full GMO transparency within five years,” said Whole Foods Co-CEO Walter Robb. Following in Whole Foods’ footsteps, New Leaf Community Markets, a Santa Cruz, CA, natural foods retail chain, also announced that it will require labeling of GMOs by 2018.


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In an effort to reduce paperwork and other burdensome aspects of organic certification, the National Organic Program (NOP) in April introduced Sound and Sensible, a new program designed to make it easier on producers while maintaining high standards, ensuring compliance, and protecting organic integrity. The Sound and Sensible initiative involves identifying and removing barriers to certification, streamlining the certification process, focusing enforcement on egregious violations, and correcting small issues before they become larger ones. NOP highlighted its Sound and Sensible program on the USDA blog as part of the Organic 101 series.

Five Principles of Sound and Sensible

  • Efficient Processes: Eliminate bureaucratic processes that do not contribute to organic integrity.
  • Streamlined Recordkeeping: Ensure that required records support organic integrity and are not a barrier for farms and businesses to maintain organic compliance.
  • Practical Plans: Support simple Organic System Plans that clearly capture organic practices.
  • Fair, Focused Enforcement: Focus enforcement on willful, egregious violators; handle minor violations in a way that leads to compliance; and publicize how enforcement protects the organic market.
  • Integrity First: Focus on factors that impact organic integrity, building consumer confidence that organic products meet defined standards from farm to market.

May 2013

Agrisystems International founder Tom Harding finalized the sale of the international organic consultancy to his longtime colleague Alesia Bock of ASI Consulting LLC in DeForest, WI. The transition to serve clients has been seamless, and Alesia brings 24 years of experience in the food industry, including regulatory, certification and quality roles covering USDA, FDA and NOP. Tom Harding will continue to work closely with Alesia over the next few years in serving Agrisystems International’s growing worldwide client base.

 The number of certified organic operations increased 240% since the National Organic Program (NOP) began tracking data in 2002. Today, USDA counts 17,750 certified organic farms and processing facilities in the US, up from about 7,400 in 2002. USDA also estimates that there are now close to 25,000 certified organic operators in more than 100 countries worldwide.

According to NOP Deputy Administrator Miles McEvoy, most US certified organic operations are on the West Coast, in New England, and in the upper Midwest. In 2012, there was significant growth in the number of operations in California, Iowa, and New England, and slight growth in the number of operations in the southeastern US. There were decreases in the number of operations in part of the Midwest and some Mountain states.

 Internationally, since 2010, there has also been a decrease in the number of operations in areas with equivalency agreements, including Canada and the EU, as operations in these countries no longer need dual certification.

“There are two things that interest me: the relation of people to each other, and the relation of people to the land,” said Aldo Leopold, a pioneering conservationist. Leopold has influenced environmentalists since he published A Sand County Almanac in 1947 – a book that presaged industry’s impact on the land. A documentary of Leopold’s life and work, Green Fire, was released this year by the Aldo Leopold Foundation. Agrisystems International is hosting several screenings in China, Latin America, EU and the US, and the film is now on tour worldwide. Info: GreenfireMovie.com

Senator Jon Tester (D-MT)

The Organic Trade Association celebrated the launch of its new Organic PAC, a Political Action Committee dedicated to advancing organic agriculture and trade, by hosting a fundraiser in Washington, DC, for the re-election of Sen. Jon Tester (D-MT), the first organic farmer elected to Congress. The event, held in conjunction with OTA’s Policy Conference and Hill Days, also raised $11,475 for the Organic PAC.

“We continue to get less money allocated to organic research and the National Organic Program relative to organic’s percentage of the overall market and farm business, however, we continue to make progress and receive support from USDA and Congress,” said Thomas Harding, President of Agrisystems International and a member of the Organic PAC committee.

“The purpose of the Organic PAC is nonpartisan; it is to raise funds and promote the needs and objectives of the organic community across both sides of the aisle, including supporting candidates in local, state and national elections,” Harding said.

To donate to the Organic PAC, contact Laura Batcha, lbatcha@ota.com.

The White House on June 11 released a report highlighting the significant contribution of organic food and farming to the nation’s diverse agricultural economy. With organic farms now in all 50 states and 17,600 certified organic farms, ranches and businesses across the U.S., the report, Strengthening Rural Economies: Lessons from a Growing Farm Economy,prepared by the Council of Economic Advisers, USDA and the White House Rural Council, points to a number of examples of how organic agriculture and trade are expanding opportunities for agricultural production.

The report, delivered in the midst of the 2012 Farm Bill debate, noted that the U.S. organic industry grew by 9.5 percent overall in 2011—more than double the growth rate for conventional foods—to reach $31.5 billion in sales, making it a noteworthy contributor to the U.S. farm economy. According to the Organic Trade Association (OTA), the organic food industry generated more than 500,000 jobs in the U.S. in 2010 and reached 4.2% of overall retail food sales in 2011.

“The organic sector is fueling jobs and rural livelihoods at an astounding rate,” said Matt McLean, OTA board president and founder and CEO of Uncle Matt’s Organics in Clermont, FL. “Organic is also creating an important economic opportunity for rural Americans through new business opportunities generated from the recent organic equivalency trade arrangements with Canada and the European Union.”

According to crop values issued by the USDA’s National Agriculture Statistics Service, organic takes sixth place for the value of production, immediately after wheat and cotton and directly before almonds, peanuts and rice, says the OTA.

After holding its public meeting in late May in Albuquerque, NM, the National Organic Standards Program (NOSB) published Final Recommendations on June 6 renewing more than 200 listings on the National List of Allowed and Prohibited Substances that were scheduled to expire this year.

The rule also makes changes to the following substances. Unless otherwise noted, all renewals and changes are effective on June 27, 2012.

  • Pectin:  After receiving numerous comments from manufacturers, NOSB on June 22 extended its rule change for pectin by four months. Effective Oct. 21, 2012, only non-amidated forms of non-organic pectin, typically added to thicken jams and jellies, will be allowed when organic pectin is not commercially available.
  • Iodine:  The listing for iodine, which is used to fortify organic foods, has been clarified.
  • Chlorine:  The allowed use of chlorine in organic crop production has been clarified. For pre-harvest use, residual chlorine levels in the water in direct crop contact or as water from cleaning irrigation systems applied to soil must not exceed the maximum residual disinfectant limit under the Safe Drinking Water Act, except that chlorine products may be used in edible sprout production according to EPA label directions.
  • Lignin Sulfonate:  The allowed use of lignin sulfonate in organic crop production has been clarified for use as a chelating agent and dust suppressant.
  • Colors:  The allowed use of non-organic colors in organic processed products has been clarified. Organic colors must be used if they are commercially available. Colors derived from agricultural products must not be produced using synthetic solvents and carrier systems or any artificial preservative.
  • Streptomycin:  The allowance for streptomycin to control fire blight in organic apple and pear orchards has been extended until October 21, 2014.
  • Yeast:  Effective Oct. 21, 2012, yeast used in baked goods and other processed organic products must be organic, if commercially available and intended for human consumption.
  • Sulfur Dioxide:  Effective Oct. 21, 2012, sulfur dioxide (smoke bombs) will no longer be allowed for rodent control in organic crop production.
  • Hops:  Effective Jan. 1, 2013, hops, typically used in organic beer production, must be organic.

Additionally, NOSB submitted a letter to USDA Secretary Tom Vilsack regarding the establishment of a Genetically Modified Organism (GMO) ad-hoc sub-committee to ensure that GMOs are prohibited in organic production and handling. NOSB also recommended a set of criteria for identifying research needs and a process for NOSB to develop and publish yearly recommendations on emerging research needs.

Click here for a summary report of the NOSB Spring 2012 meeting in its quarterly newsletter. Click here to view the full version of NOSB’s final rule.