Letter to USDA's Office of Inspector General

September 1, 2016

Inspector General Phyllis K. Fong
U.S. Department of Agriculture
Room 117-W Jamie Whitten Building
1400 Independence Avenue SW
Washington, DC 20250

Dear Inspector General Fong,

We are writing to draw your attention to an emerging trend that is dramatically impacting organic markets in the United States. The Organic Farmers’ Agency for Relationship Marketing (OFARM) is a cooperative incorporated in the State of Minnesota as a marketing-agency-in-common and operates under the Capper-Volstead Act of 1922. OFARM has six member organic grain and livestock marketing cooperatives with organic producers in 19 states from Montana to Texas and Louisiana to Tennessee, Kentucky and Ohio and all states in between. USDA has cited OFARM as the largest organized block of farmer controlled organic grain in the United States.[1] Food & Water Watch is an advocacy organization that works to ensure that our food is produced sustainably, which includes advocating for strong organic standards and healthy markets for organic producers.

We are aware that the Office of Inspector General is conducting an audit into the USDA National Organic Program (NOP)’s oversight of an organic equivalency agreement between the United States and the European Union (EU). The audit was described in your annual plan as an effort “to ensure that European Union products marketed as organic in the United States meet the standards established in the arrangement.” In the annual plan, the review of the equivalency arrangement is listed as a step to “reduce program vulnerabilities and strengthen program integrity in the delivery of program assistance.” [2]

As part of this audit, we urge you to examine the dramatic increase in the import of organic commodities, especially grains. A key area of concern for U.S. organic grain growers, and increasingly for consumers, is whether these increased imports present an opportunity for fraudulently labeled organic products to enter the United States, undermining the opportunity for U.S. producers to get a fair price in the market.

The trend of increasing imports of organic soybeans and corn is dramatic:

• From 2013 to 2015, the dollar value of imported organic soybeans (except seed) more than doubled, from $110 million to $240 million.
• During the first six months of 2016, 12 countries exported organic soybeans (except seed) to the United States. Turkey was the leading exporter, followed by India, and Ukraine. In 2015, Turkey was the sixth largest exporter.
• During the first six months of 2016, there was a dramatic increase in the dollar value of imported organic soybean (except seed) imports from Turkey, with more than thirty-six times the value of imports from Turkey in the first six months of 2016 than the same time period in 2015.
• From 2013 to 2015, the dollar value of imported organic yellow dent corn (except seed) more than tripled, from $36 million to $112 million.
• During the first six months of 2016, 8 countries exported organic yellow dent corn (except seed) to the United States. Turkey was the leading exporter, followed by Romania and the Netherlands.
• During the first six months of 2016, the dollar value of imported organic yellow dent corn (except seed) nearly doubled from the same time period in 2015.
• During the first six months of 2016, there was a dramatic increase in the dollar value of imported organic yellow dent corn (except seed) from Turkey, with more than five times the value of imports from Turkey in 2016 than the same time period in 2015. The imports from Turkey during the first six months of this year were close to double the value from Turkey for the entire year of 2015. [3] 

As organic exports grow, so do concerns about the potential for fraudulent organic products to enter the United States, due to lack of inspections and the opportunities for fraud that occur in more complicated supply chains. These long international supply chains increase the opportunities for breaks in the chain of recordkeeping, organic certification and verification that the USDA organic seal is built upon.

We are aware that your audit focuses on the agreement between the United States and the EU. But there are connections between major exporters to the United States, such as Ukraine and Turkey, and the EU. Specifically, the rise of imports from Turkey raises concern. A 2016 report by USDA’s Foreign Agriculture Service summarized the potential for fraudulent activity in the Turkish organic sector:

“According to a EUROPOL report, some Turkish companies have been involved in relabeling or repackaging products as organic and bringing the counterfeit products into the European Union, even though the products do not meet the EU’s organic standards. Reports from the Research Institute of Organic Agriculture (FiBL) in 2013, Eurofins Scientific in 2012, the Cornucopia Institute in 2013 and the French Ministry of the Economy in 2015 uncovered fraud or unapproved production methods in organic products from Turkey. There have also been instances where a few Turkish companies were found to have been using fraudulent organic certificates. Turkish news articles report that consumers may be misled by conventional products that are marketed as organic, mostly in open air bazaars or independent stores where a vendor could more easily sell a fake organic product. Although inspections and transparency in the Turkish organic food sector are improving, the integrity of organic farming, production, shipping and marketing is not always guaranteed.”[4]

One Turkish organic certifier, ETKO, has been decertified by the EU.[5] The introduction of additional testing regimes in the EU has reportedly led some traders to prefer to ship to non-EU destinations (including the United States), as there is less risk of rejection in U.S. markets.[6]

As the organic market grows rapidly around the world, resulting shortages in the supply of various commodities can create a tempting situation for those who do not value the integrity of the organic standards and see a potential to ship products fraudulently labeled as organic. The potential for fraud is being acknowledged by some participants in the organic sector, with the establishment of an Anti-Fraud Initiative to “improve cross border communication among inspection and certification bodies, trade companies, label organizations and authorities to strengthen organic integrity.”[7] The fact that fraud is a serious enough concern to trigger the creation of this network, and international workshops with titles such as “Best practice examples to guarantee integrity of organic exports from Turkey,”[8] should provide sufficient motivation to the NOP to dedicate more effort to this issue.

The dramatic increases in imported organic grains are having impacts on the potential for U.S. organic farmers to sell their products for a fair price:

• One major international grain company attempting to make inroads into the U.S. domestic organic market recently told NFOrganics and OFARM member organization marketer Tim Boortz that he needed to get the prices for organic grain he was offering for sale down to the price they could pay for imported grain.
• Merle Kramer, Midwest Organic Farmers Coop organic grain marketer notes “many larger buyers of organic corn contracting 50,000 bushels from import brokers offer local farmers 20%-25% less then what they pay for imports, often not having room in their bins to buy domestic corn putting financial pressure on those farmers not being able to sell when they need cash.”
• John Bobbe, OFARM’s executive director had discussions with a major organic grain marketer in Ontario, Canada. The firm markets grain into U.S. markets as well as Canada. The marketer confirmed that in recent months any imported shipment with the semblance of “organic” in the documentation has been sold as organic, no questions asked as to the origin.

We urge you to take a careful look at the potential for non-organic products, especially bulk commodities like grains, to enter the U.S. market and be sold as organic. Specifically, we urge you to examine:

• What procedures does NOP have to assess whether the EU’s processes for accreditation and certification are adequate to ensure the integrity of bulk shipments of commodities that are pooled from many farms?
• Does NOP have an adequate system to track bulk commodity shipments produced in other countries outside the EU that are certified by EU-based certifiers, or shipped through EU countries?
• What other data collection should NOP set up to have a better understanding of source of imports, back to the certifier and farm level?

We appreciate your attention to this critical issue for both organic consumers and farmers in the United States. Please contact John Bobbe from OFARM, (715) 467-0031 or johnbobbe@gmail.com, for more information or if you have any questions.

Sincerely,

John Bobbe
Executive Director
OFARM

Patty Lovera
Assistant Director
Food & Water Watch

[1] U.S. Department of Agriculture. Rural Cooperatives Magazine. January, 2012.

[2] U.S. Department of Agriculture Office of Inspector General. “Annual Plan: Fiscal Year 2016.” 2016. https://www.usda.gov/oig/webdocs/2016_Annual_Plan.pdf.

[3] Data compiled from USDA’s Economic Research Service.

[4] USDA Global Agriculture Information Network. “Report # TR601, Turkish Organic Market Overview.” January 26, 2016.

[5] IOAS. “IOAS withdraw ISO 65 accreditation of ETKO Turkey.” May 25, 2016.

[6] Personal communication. Email to John Bobbe, OFARM Executive Director, from a U.K. organic farmer-owned company. August 8, 2016.

[7] Anti-Fraud Initiative. http://www.organic-integrity.org/

[8] Anti-Fraud Initiative. “Meetings and Events.” http://www.organic-integrity.org/meetings/#c2716

Organic Checkoff

OFARM has consistently maintained that there are better ways to promote "organic" then a federally mandated Organic Research and Promotion Order as proposed by the Organic Trade Association (OTA).  Here is another reason why.

“For Our Common Ground” is a website and Facebook page supposedly dedicated to “helping consumers sort through the myths and misinformation” about the food they buy.  It does have a token organic farmer or two and brief discussions of organic. However, one could read the statements on the website and conclude it is simply a ruse to cover the dismal track record of conventional agriculture regarding food safety and the merits of organic food produced with no pesticides, antibiotics or genetically engineered seeds.

Here are a few examples:

“Organic or traditional, all milk contains the same valuable nutrients.”  Yes, but studies show organic milk to be better and most consumers don’t want hormones and antibiotics used in production of their milk.

“The USDA, which certifies organic production, makes no claims that organically grown food is more nutritious than conventionally grown food. Organic food proves to be only different in how it is grown, handled and processed.” True but independent research shows otherwise.

Then there is an entire article devoted to dispelling the myths of GMO foods that consumers go to the grocery store to buy.  Read that, consumers are mis-informed and need to be told.

Here is another statement:

“Do I need to buy the most expensive food to get the best for my family

• While organic food prices are often higher than conventional food, there is no difference in nutritional value, according to a review of 400 scientific papers on the health impacts of organic foods, published in the journal Critical Reviews in Food Science and Nutrition.”

The bottom line is that some of the people on this website will viciously attack anyone who challenges the status quo of conventional agriculture and readily op disparage organic.  And there is always a strong defense of GMO’s and Monsanto.

The best part is their by-line:  “Brought to you by America's soybean and corn farmers and their checkoffs.”

Organic checkoff funds could not be used to rebut the false and misleading statements made on this website or any other. The idea of a conversation about food is always welcome.  Using farmer checkoff funds under the guise of a conversation about food to disparage “organic” is very questionable to say the least. For example, there is no discussion of alterative research about the food safety issues surrounding GMO’s and glycophosphates.  The attitude is just “trust us.”  Never mind that the World Health Organization (WHO) recently declared glycophosphates as a probable carcinogen.  

This is just another reason why the OTA proposed checkoff is a very bad idea and a waste of organic farmer’s money. 

Organic Checkoff Position

A proposal has been submitted to the USDA by the Organic Trade Association (OTA) for USDA to conduct a referendum for an organic research and promotion order checkoff.  OFARM along with a number of other organizations are not opposed to funds for research and promotion, but are opposed to the OTA proposal as presented for a number of reasons.

First, and foremost is why farmers have spent a lot of time decrying the intrusion of government into their business through rules and regulations  Now comes along a proposal that would require organic farmers to fund more government rules and regulations for research and promotion. Ultimately, organic farmers will be footing the bill. OFARM has been working with a number of like-minded organic farmer groups as there simply has to be a better way to do this. The conventional commodity checkoff programs have been rife with misspent money and lack of accountability. In the case of the pork checkoff, farmers voted out the checkoff and the courts blocked those efforts so farmers still are paying into a checkoff program they voted to do away with.

For years, the organic community has sought to make "organic" stand out to consumers.  Now to get a checkoff, OTA (an industry trade group) had Congress classify organic as a single "commodity" just like dairy, pork or beef.

To continue to be informed of the latest developments on this issue, go to www.noorganiccheckoff.com and also like the site on Facebook.

GENERAL MANAGER POSITION GRAIN FARMERS CO-OP

Midwest Organic Farmers Cooperative is seeking a general manager for its operations, including marketing division, grain cleaning plant, feed mill, seed division, logistics operations, and administrative office.  To qualify, the applicant must have prior management experience and proven personnel supervisory skills commensurate with the duties of this position.  Knowledge of grain farming and organic practices is a plus.

MOFC is a fast growing cooperative that markets organic grain for members and non-members throughout the U.S. midwest to buyers all over the country.  It has developed its own organic seed lines and markets them widely.  It cleans grain for farmers and end users, and is in the process of a large expansion of the cleaning plant to service the developing business.  Its feed mill is also expanding capacity to meet increasing business.

For a complete description of the general manager duties, salary parameters, or to submit a resume with references, contact:   johnx@midwestorganic.com

USDA seeks comments on Coexistence with GMO crops

I attended a USDA sponsored workshop at North Carolina State University on "Coexistence". Organic farmers know well the problem GMO pollen drift causes to their crops.

The workshop was a total disaster for USDA and things didn't go well. The concept appears to be that organic farmers should "go along to get along" with their neighbors.

USDA is now seeking comments on "Co-existence."  The deadline has been extended to May 11,  2015  Below is a link to the Organic Seed Alliance with how to file comments. OFARM supports the Organic Seed Alliance and its good work.

Please file your individual comments as they are important. The link also provides some easy talking points and an additional link to USDA's website to file the comments.

http://blog.seedalliance.org/2015/04/06/usda-seeks-comments-on-coexistence/

Your help is appreciated.

The DARK Act

If you don't know what the "DARK Act", you should. It is a bill proposed by Representative Pompeo (R-KS) that would pre-empt states passing laws about your right to know if the food you are buying has GMO's in it.  Several states including Vermont and Connecticut have already passed bills requiring GMO labeling. The bill is a ruse supported by the Grocery Manufacturers Association (GMA) using the ploy that it will raise the cost of food for families.  In fact it will cost only pennies if that and foods already have labels for other things.  One has to ask what the GMA and its minders such as the likes of Monsanto and Syngenta have to be afraid of if GMO's are safe.

In fact, the World Health Organization (WHO) just published a report that Roundup and glycophosphates as herbicides in growing GMO crops is of concern with regard to carcinogens. Here is a link to our friends at Food and Water Watch to take action on the Pompeo bill:

https://secure3.convio.net/fww/site/Advocacy?cmd=display&page=UserAction&id=1937&s_src=fb&s_subsrc=032515a

USDA's organic agriculture census

USDA is conducting its Organic Ag Census.  It is critical for all certified organic producers with sales above $5000 annually to fill out the census.  Section 10 deals with an especially important question of GMO contamination costs for organic producers.  I am told that many in the biotech industry and conventional farming community such as the American Soybean Association and National Corn Growers Association and their producers are "livid" over USDA even asking this question.

Just last week an organic producer had four loads of organic food grade corn rejected in one day at a loss of $5000  due to GMO contamination.  We in the organic community and especially farmers know this is a problem.  

Below is the link to the survey.  If you haven't responded, please do so.  

http://www.agcensus.usda.gov/Online_Response/

More Organic Farmers, Please

Merle Kramer, Midwest Organic Farmers Coop general manager wrote the following press release which appeared on www.usagnet.com in the news for Indiana and Illinois  It sums up the current state of affairs in organic where reports are that as much as 50-60% of organic grain is imported.

In order for more acres to transition into organic production farmers need to keep in mind that
orderly group marketing and a strategic marketing plan for their farm will be key to keeping
organic grain prices profitable.  OFARM member organization marketers can help you do that.

More Organic Farmers, Please
Indiana Ag Connection - 03/06/2015

Eastern Illinois-based Midwest Organic Farmers Cooperative (MOFC) is experiencing a severe shortage of organic acres in eastern Illinois and western Indiana for the organic soybean and corn markets.

Merle Kramer, 22-year organic grain veteran and marketing director for MOFC, Sibley, Ill., says that MOFC has a good market for an extra 200,000 bushels of organic soybeans and 500,000 to 1,000,000 plus bushels of organic corn to satisfy just two customers alone. Demand for organic grain crops is growing at double digit rates nationwide.

Kramer says that since the economic downturn in 2009 and its subsequent recovery, more and more consumers are interested in knowing where their food is coming from and wanting to support farming systems that are environmentally friendly, humane to animals and fair to people.

"More people from younger generations are getting involved in organic and local agriculture, many with small scale produce and retail food businesses they can afford to buy into," he notes.

Kramer goes onto say that "the grain and meat side of organic agriculture is looking for younger farmers who have that drive and entrepreneurial spirit and are in-search of new challenges." Kramer puts it this way "Organic offers them opportunities to see how well they can do both financially and personally off fewer acres, be more in-control by having access to more options and markets that organic and sustainable agriculture provide."

The future is going to be bright for those willing to make the transition to organic agriculture, as there is a growing awareness in the value of wholesome nutritious food for long term good health. A healthy lifestyle including good food translates into less chronic illness in our society and a more prosperous America from a heathy food culture.

For more information contact Kramer at 734-429-9110 or email at merle@midwestorganic.com.

More from this state at:
Indiana Ag Connection

Tell the USDA: You Support the Organic Exemption from Federal Check-off Programs

Note: Date has been extended until February 17, 2015

Tell the USDA: You Support the Organic Exemption from Federal Check-off Programs

The 2014 Farm Bill allows all organic farmers and businesses to pull assessed monies out of conventional check-off programs. In December, the USDA issued proposed rules to set this process up. 

A strong response from organic farmers and businesses will let the USDA know this exemption is important to organic agriculture, and these rules need to be put in place as quickly as possible. The instructions below will guide you on how to submit comments.  Here are talking points:

• These rules give the same opportunity to farms and businesses with split operations (organic and non-organic) as 100% organic operations were granted in the 2002 Farm Bill to request a refund on organic sales assessments.  This change corrects unequal treatment of organic certificate holders set by the 2002 Farm Bill.

• This exemption will provide a level playing field. It allows organically certified farmers and handlers to use check-off monies to benefit their own operations and future, similar to the benefit that non-organic operations receive from being assessed under the Commodity Promotion Law. 

• Organics is less than 5% of agricultural production and requires very specific research and marketing.  Farmers and handlers carry out a high percentage of direct-to-consumer and other marketing, or conduct research on their own farms.

• The exemption process should be as efficient as possible. Information on certified organic operations is now available in real time so certificate holders should only need to apply once for an exemption from the check-off, not every year.  Commodity boards can be informed by the NOP when the operation loses its organic certification.

• Organics should have a blanket exemption from all Research and Promotion programs.

• For Marketing Orders, the organic exemption should be the marketing portion average of all AMS Marketing Orders.

Comments must be postmarked no later than February 17, 2015

They can be electronically submitted at: http://www.regulations.gov/#!documentDetail;D=AMS-FV-14-0032-0038  Click on "Comment Now" on the right side of the page.

Submit written comments to this address:

Docket Clerk, Marketing Order and Agreement Division, Fruit and Vegetable Program
Agricultural Marketing Service
U.S. Department of Agriculture
1400 Independence Avenue, SW
STOP 0237
Washington, DC  20250-0237

Example of how to start your letter:

Re: Proposed Rule regarding Exemption of Organic Products From Assessment Under a Commodity Promotion Law: AMS-FV-14-0032-0001 (Dec. 16, 2014) (Federal Register Number 2014-29280) (79 Fed. Reg. 75006 et seq.)

Thank you for the opportunity to provide comments on USDA’s Proposed Rule regarding Exemption of Organic Products From Assessment Under a Commodity Promotion Law.

I fully support the proposed rule mandated by a bi-partisan vote by both houses of Congress.

Example of how to close your letter:

I thank USDA for the speed in developing this proposed rule and urge them to proceed to a final rule as quickly as possible, with immediate implementation.

Sincerely,

Name
Address 

Midwest Organic Farmers Cooperative Annual Meeting

I attended the Midwest Organic Farmers Coop (MOFC) annual meeting last Saturday, December 13th in Sibley, Illinois. Sibley is also the location of MOFC’s grain cleaning facility which they recently opened. MOFC is also in the process of completing a feedmill at Fairbury, IL. In addition, the coop offers a variety of seed including soybeans to its members specifically geared towards some of MOFC customer end users.

While conventional grain prices are in the tank, MOFC members had reason to celebrate their coop and members having a very good year in spite of the challenges of the weather. 

Some dedicated members drove 9 hours to attend the meeting from where they farm in Nashville, Tennessee. There were a number of new younger faces in the crowd as well.

I had the occasion to show OFARM’s “Organic the Real Natural” video series.  (Check them out at:  www.OrganicTheRealNatural.com)  MOFC member Harold Wilken and his son Ross were filmed on their farm  earlier this summer for one of the videos. As Harold noted, he likes the idea that Ross won’t have to handle a swimming pool full of chemicals because of farming organically ever.

Congratulations to MOFC and its members for a great year. MOFC is a proud member of the OFARM network of organic grain cooperatives. 

John Bobbe