2012

Resolution on Residue Testing by Organic Certifiers

Whereas, we support the National Organic Program’s (NOP) progress towards defining residue testing, we note that the National Organic Program is a process-based standard, rather than a product-based claim:

“The organically-produced label authorized under this bill therefore pertains to the production methods used to produce the food rather than the content of the food.” [Senate Report Accompanying S. 2830, the Food, Agriculture, Conservation and Trade Act, S. Report 101-357, p. 292].

And a mandatory product residue testing program as outlined in the NOP rule on residue testing comes perilously close to re-defining organic as a product claim.
And whereas, the NOP has not been clear as to the actual purpose of testing. Is it simply to avoid fraud or to also evaluate the possibility of contamination, either purposeful (through use of a prohibited substance or excluded method) or inadvertent (such as through drift, soil contamination, hygiene, or adventitious presence)?

And whereas, by requiring that 5% of all operations be tested, the costs related to this rule are not scale neutral. Data from the Accredited Certifiers Association (ACA) shows that the NOP estimate of this testing regime reflecting 1% of an ACA’s operating budget is only accurate for the larger certifiers, but can range to as high as 11% for the smallest of certifiers. In addition, given economies of scale, it will be the smaller certifiers who will pay more for tests, and will also be the ones who will need to increase their certification fees to implement this.
And whereas, the Organic Foods Production Act (OFPA) states that the National Organic Standards Board shall advise USDA “on the testing of organically produced agricultural products for residues caused by unavoidable residual environmental contamination.”
We hereby resolve that:

The NOP should withdraw its Rule on Residue Testing and ask the National Organic Standards Board to propose a residue testing regimen for Accredited Certifiers that includes the full range of testing of organic farms, including plant tissue, soil, water, inputs, or feed,  that is needed to assure the organic integrity of the USDA Organic label and to discourage fraud. This testing should not be random, but based on careful risk assessment or complaints from the public, consistent among all certifiers, including the certifiers of organic products imported into the US, and not place an undue financial burden on the smaller certification programs.

Pure Honey Law

Whereas honey is defined the natural sweet substance produced by honey bees from the nectar of plants or excretions of plant sucking insects on the living parts of plants, which bees collect, transform by combining such substance with specific substances of their own, deposit, dehydrate, store, and leave in the honeycomb to ripen and mature.

And whereas, approximately 60% of honey consumed in the United States is imported; domestic supply cannot meet demand. Unfortunately, some of this imported honey has been tested and found to be adulterated with other components such as corn and rice syrups, or beet sugar. There have also been contamination issues, as antibiotics such as chloramphenicol and quinolone have been found in some imported honeys.

And whereas, in New York State, if honey is tested and found to be adulterated, there is no definitive recourse, because there is no law in New York that technically describes what honey is. The current regulation, section 205: defining honey, is a one sentence dictionary style definition of honey, dating back to 1902, and has never been revised.

We thereby resolve

We support the upgrade of the honey detailed in law S3321/A5164 that lists the parameters by which any item labeled pure honey, must meet.  These parameters include sucrose level, moisture content, fructose/glucose levels, and floral exceptions and give the consumer confidence that when they buy a jar labeled “pure honey” there is truth in labeling in New York State.

On July 24 2010, the Empire State Honey Producers Association, the state beekeeping organization of New York, voted to adopt as a resolution the proposed honey definition. Other NY beekeeper groups voiced their support: Western New York Honey Producers Assn., Southern Tier Beekeepers, Southern Adirondack Beekeepers Assn. The Ontario Finger Lakes Beekeepers, with almost 500 members, also favor a new honey law.

Additional Resolution to the 2009 Resolutions on the SGEIS-Methane Mitigation

New number 11. Existing Policy 1-10:
Resolved:
 
The Northeast Organic Farming Association of New York condemns the New York State Department of Environmental Conservation’s (“DEC’s”) draft Supplemental Generic Environmental Impact Statement (“SGEIS”) concerning hydraulic fracking of horizontal gas wells as not protective of New York State’s agriculture, environment and people.  We demand that DEC:
 
1. Include in the SGEIS a comprehensive cumulative impact assessment of the numerous gas wells planned, not limit the SGEIS to the environmental impact of one well at a time (as currently is the case).
2. Include in the SGEIS a comprehensive assessment of impacts on human health by numerous gas wells.
3. Include in the SGEIS an assessment of the environmental impacts on the environment and human health of a vast pipeline, condenser and compressor system needed to service numerous gas wells.
4. Develop a practical plan for the disposal of all waste water (currently estimated to be in the billions of gallons) that will be generated by hydraulic fracking of numerous horizontal gas wells, inclusive not only of fracking fluids, but the radioactive waste that will be generated by drilling and fracking of the Marcellus Shale (which itself is radioactive).
5. Expand the parameters for testing of water from gas well sites, as well as explicitly declare that all mandated water monitoring and testing costs be the financial responsibility of gas companies.
6. Declare that all expenses to county and local government to implement the SGEIS be the responsibility of gas companies.
7. Ban the use of water from aquifers for the purpose of hydraulic fracking of horizontal gas wells.
8. Fully disclose to the public the complete list of chemicals to be used in fracking fluids.
9. Ban the use of carcinogenic or suspected carcinogenic chemicals in fracking fluids, as well as chemicals in fracking fluids that act as endocrine disrupters or mutagens.
10. Develop and publish DEC’s strategy to train and hire the many additional staff needed to enforce the SGEIS, as well as a description of penalties to empower the DEC to protect the public.
11. Understand and determine the means to prevent methane migration in the Marcellus Shale from horizontal hydrofracking before any horizontal hydrofracking occurs in New York State.  Since the first SGEIS was presented in 2008, a 2011 peer reviewed and published study from Duke University of contamination of aquifers in the Marcellus Shale determined that about 50% of the 68 wells studied in Pennsylvania were severely contaminated with methane from the Marcellus Shale, because they were within a kilometer of horizontal hydrofracking. The use of water in one's home must never be the source of explosive and dangerous gas.

Horizontal High-volume Slick Water Hydrofracking Ban Policy 

Resolution:

Whereas through the process of careful consideration of the scientific evidence pertaining to the recovery of gas from shale or “tight gas” formations, and listening to the direct experiences of farmers from regions where shale gas recovery is underway and under consideration.

And, Whereas Shale gas formations, despite being located deep, deep underground, host thriving communities of anaerobic bacteria adapted to life at these depths.  While little is known by biologists about the specifics of this ecological system, due to its remote and difficult to access location, some experts in the field estimate that the sheer volume of living material located in this ecosystem exceeds the volume of living matter located on the earth’s surface.  In keeping with our organic principles, we believe that the injection of massive amounts of biocides (poisons) into functioning ecosystems, to accomplish a wholesale eradication of all life in the area, is always counter-productive.  When we, as humans, work within and with respect for the ecosystems around us, rather than as poisoning conquerers obliterating those ecosystems, we maintain the delicate web of sustainable life on which we, as well as other creatures, depend for our survival as a species.  Horizontal high-volume slick water hydrofracking gas extraction technology depends upon the injection of tons of poisons into the little-studied underground ecosystems, as well as the application of tremendous physical force to crack and crush the rock environment in which the ecosystem is situated. Although little is known to science about the effects of this particular onslaught on the impacted ecosystem, we can extrapolate from other, similar human attacks on biotic communities to conclude that no good can come from proceeding in such a violent and death-dealing manner. 

And whereas, the introduction of manufactured poisons into ecosystems inevitably has unintended consequences, as natural cycles move air, water, soil and living germplasm from place to place.  Human transportation and industrial practices often accelerate this geographic mixing, as well.  We therefore understand that, while we may somewhat limit ecosystem damages locally by calling for a prohibition of the practice within our own municipality, state or country on the practice of horizontal high-volume slick water hydrofracking, it is ultimately necessary to stop the practice world-wide. 

And, whereas, in keeping with our concerns regarding the serious problem of global climate change, already having devastating effects on farmers around the world, we assert that it is absolutely necessary that we, as a species, find ways to decrease our dependence on the fossil fuels that create the greenhouse gases that cause the problem, rather than devise ever more destructive technologies to extract more fossil fuels. 

We hereby resolve that:

We reject horizontal high-volume slick water hydrofracking technology as an acceptable human activity.

We call for a world-wide agreement to cease the horizontal high-volume slick water hydrofracking technology because it is an unconventional, and unwise, means of extraction of fossil fuels. 

We support and encourage all local, state and federal efforts to end the practice of horizontal high-volume slick water hydrofracking technology, as well as all efforts at every level of government to contain and mitigate the environmental damages associated with the practice of horizontal high-volume slick water hydrofracking. 

We support institution of laws that will protect taxpayers, farmers, and owners of rural natural areas from unfairly being forced to shoulder financial or other responsibilities for environmental damages caused by horizontal high-volume slick water hydrofracking.

The state of NY, the USA, and the world should accomplish a drastic reduction in the use of natural gas by effecting an orderly and rapid conversion to organic farming methods, obviating the need for natural gas and other petrochemical inputs for use in synthetic fertilizers.  The experienced organic community of NOFA-NY stands ready to assist in this essential transition through education, outreach, and certification of compliance with organic methods.