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Comments on USDA Agriculture Coexistence Requested

The OCIA International Board of Directors submitted a public comment on USDA agriculture coexistence March 3.

Coexistence is defined as "the concurrent cultivation of crops produced through diverse agricultural systems including traditionally produced, organic, identity preserved, and genetically engineered crops."

The OCIA board would like its members to submit their own response, sharing experiences with trying to prevent GE contamination.

You also have an opportunity to sign petitions:
Organic Consumers Association: http://salsa3.salsalabs.com/o/50865/p/dia/action3/common/public/?action_KEY=12789

Farm Aid: http://www.farmaid.org/site/c.qlI5IhNVJsE/b.8989403/k.2C67/Farmers_cant_Coexist_with_GMO_Pollution__Tell_the_USDA_to_Prevent_GMO_Contamination_and_Protect_Farmers_Now/

It's important that USDA hears from organic operations directly on this topic. First-hand experience can be important than thousands of signatures on a form letter.

See the docket to comment: http://www.regulations.gov/#!docketDetail;D=APHIS-2013-0047
Comments are due March 4 at 11:59 p.m., Eastern Standard Time. To track the status of OCIA's comment, type in "1jy-8ar6-tkcm" at regulations.gov. The comment will be viewable on Regulations.gov after the agency has reviewed it, which may be an indefinite amount of time.

OCIA International's Comment:

March 3, 2014

APHIS-2013-0047,
Regulatory Analysis and Development,
PPD, APHIS, Station 3A-03.8,
4700 River Road Unit 118,
Riverdale, MD 20737-1238.

Re: Enhancing Agricultural Coexistence; Request for Public Input

To Secretary of Agriculture Tom Vilsack,

We are producer, processor and handler members of the Organic Crop Improvement Association International, Inc., (OCIA.) OCIA functions in the United States as a network of chapter and direct members and as a USDA National Organic Program accredited certification agency that provides certification services to more than 1,000 organic operations in North, Central and South America, and Asia. Our comments on collaborating and communicating agricultural coexistence follow, with numbered docket questions and responses.

OCIA members are concerned about transgenic trespass in seeds because organic integrity starts with seed. Consumers expect organic products to be transgene free. Organics' integrity would diminish if seed is contaminated with transgenic traits and then saved. Organic producers are seed savers.

OCIA certifies operations in the United States and elsewhere to its own private organic standard that prohibits the use of genetically engineered organisms. Additionally, OCIA supports the position of the Demeter Association in its comment on agricultural coexistence, stating, "There cannot be co-existence between Biodynamic® agriculture and the contamination of the food and fiber there from with Genetically Engineered Organisms (commonly known as GMOs)" (Public Submission ID: APHIS-2013-0047-0183.)

Operators certified to the National Organic Program make efforts to prevent contamination with prohibited materials. The Organic Seed Growers and Trade Association created a handbook for producers to avoid contamination: http://www.osgata.org/organic-seed-integrity/. However, contamination can still occur and would increase with each year seed is saved. Agricultural operations that use genetically engineered crops have no regulations or protocols for preventing contamination of other operations.

OCIA members are also concerned about the chemicals used with genetically engineered crops by neighboring operations that drift onto organic operations.

OCIA supports the National Organic Coalition's urging that the USDA:

1) Implement mandatory contamination prevention measures to avoid the problem and protect the non-GE sector, and
2) Ensure shared responsibility for the unwanted spread of GE products, including a fair compensation mechanism that does not further burden those who must avoid, and sometimes are harmed by, contamination.

1b. What information regarding coexistence, in what format, is currently available (printed or electronic brochures, factsheets, blog posts, Web sites, discussion forums, etc.)? Is this information useful? Why or why not? What additional information, in what format, would be useful to you or members of your organization?
1b. More unbiased information is needed on the environmental, social and economic impacts of genetically engineered crops. Operators need information and workshops on avoiding and preventing contamination, not specifically how to coexist. OCIA has chapters that hold meetings and talk with other organic operations, buyers and consumers about contamination avoidance practices.

1c. Please indicate your preferences with respect to receiving information or communications from USDA. Would you be interested in receiving information or communications from non-USDA sources? How might you or your organization, as agricultural stakeholders, want to be involved in disseminating information?
1c. OCIA would prefer to receive information from the USDA through the Federal Register. OCIA would disseminate relevant information to its members.

2b. How might USDA assist farmers to better understand the contracts they enter into (e.g., contracts to provide organic products and IP products for specialty markets) and their commitments with respect to coexistence?
2b. Producers should be able to write their own contracts for their intended market.

2c. What geographic information, in what format, is available regarding the location of crops that are planted and grown using different types of agricultural systems (e.g., pinning maps)? Is the information updated regularly? What are stakeholders doing to make this type of geographic information more widely available? What can USDA do to assist in these efforts?
2c. Pinning maps have proven ineffective in a voluntary system.

3. Farmers and others in the food and feed production chain have an important role in collaborating to make coexistence work, particularly with reference to stewardship, contracting, and attention to gene flow. As we seek to improve collaboration among those involved in diverse agricultural systems, we are interested in hearing what practices and activities that support collaboration are available or in use and how USDA can help make collaboration and coexistence work for everyone involved. 3a. What are factors that might prevent or promote the broad adoption of local, voluntary solutions aimed at facilitating coexistence?
3a. Coexistence is possible when gene flow is controlled. Factors preventing coexistence include proprietary information held by seed developers that limits independent research and data for growers to plan what to plant. Growers are particularly divided when they are bound by contracts to biotechnology companies that hold seed patents. Growers bound by these contracts dominate other growers rather than collaborate. An unbound grower currently has the responsibility to remediate the environmental and economic damage by gene contamination on his or her private property.

Crop insurance as a compensation measure for contamination does not facilitate coexistence because it rewards bad behavior; the pollutee pays. OCIA members, for example, would not be able to sell their products as organic if they are contaminated by genetically engineered crops' pollen drift.

Producers should not solely be responsible for the uncontrollable pollen drift onto neighboring fields. Seed developers need to take responsibility, as an alternative to crop insurance for genetic contamination. Seed developers should not only educate their customers on contamination avoidance, seed developers could set up an escrow fund to test non-genetically engineered materials that are susceptible to contamination, with emphasis on organic products. The fund can compensate for the market value of crops, but you can't replace seed when it is contaminated. Genetic diversity is lost with contamination. There is no economic loss for lost seed; it is priceless.

A second use of funds should be long-term, independent, peer reviewed research on the economic, and environmental and social effects of contamination. That is a factor that promotes coexistence. Public forums also promote coexistence by bringing together seed professionals, growers and down the processing and handling chain, to consumers.

3b. Please provide examples of effective coexistence practices (e.g., between neighboring farmers or among regional networks of farms) and on-farm and off farm techniques for mitigating the potential economic risks from occurrences that affect successful coexistence. How might they be made to be more effective?
3b. USDA, Department of Health and Human Services, Public Health Service, Food and Drug Administration and the Environmental Protection Agency should implement the recommendations by the U.S. Government Accountability Office to improve the framework for monitoring and coordinating on contamination issues: http://www.gao.gov/products/GAO-09-60.

OCIA members make management decisions to avoid contamination. They can do such things as remove land from production with neighboring fields in their own field with buffer zones; they choose seed that pollinates at different times than neighbors and/or change their planting dates.

OCIA's membership passed a policy at its 2000 AGMM in Antigua, Guatemala, that includes information growers said they need to make planting decisions.

The Year 2000 AGMM meeting in Antigua, Guatemala urges each membership category within OCIA to work within their Local, State/Provincial, and/or National government, for immediate passage of legislation and/or administrative rule-making that establishes a Registry of Genetically Modified Organism (GMO) Seed Planting. A Registry of GMO Seed Planting should contain the following three critical elements:

1) Government registration of all crops planted with GMO seed including farmer's name, address, and location of planting(s); and notification process for any farmer within a one (1) mile radius.
2) Any farmer within a one (1) mile radius of a GMO seed crop is entitled to have his crop of similar type tested for genetic contamination at the expense of the seed manufacturer.
3) Indemnification to a farmer whose crop is genetically contaminated and suffers consequent economic loss holding the seed manufacturer as the liable party. (Policy number 00AGMM-01.)

3c. What types of coexistence practices could be supported in potential joint coexistence plans, i.e., voluntary written plans specifying farming practices (such as farmer-to-farmer communication, cropping plans, temporal and physical isolation, and harvesting techniques) that can be used to support coexistence and identity preserved production? What might an effective, supportable, joint coexistence plan look like? How might USDA encourage adoption of joint coexistence plans?
3c. Organic operators are required by the NOP to maintain an Organic System Plan that includes information on such things as non-genetically engineered seed sources and the location and history of fields. There's a lack of effort on the part of non-organic producers to prevent contamination.

4. We also welcome any recommendations regarding collaborative meeting formats that would best ensure coexistence issues will be frankly and fully explored at the public forum that USDA intends to hold following the close of the public comment period.
4. Public forums could be held at the local, regional and national levels to increase the variety of participants as agricultural coexistence affects growers across the U.S. Regional webinars or teleconferences on specific issues could accompany the in-person forums.

Coexistence is shared responsibility.

OCIA's question for the USDA and the public is: why should organic producers and others who refrain from using biotechnology be solely responsible for preventing its cost of contamination?

Signed,

Kevin Koester
OCIA International President

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