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primarily political appointments with conflicts of interest in, or actual hostility toward, the promulgation of meaningful organic standards.
Astoundingly, at the fist NOSB meeting in March 1992, Assistant Secretary of Agriculture Joann Smith admonished the board to make sure it did not characterize organic food as safer than regular food, since there is no scientific proof to that effect. She added that there should be no attempt to make conventional food "look bad." In fact, she said the OFPA should not even be considered a "food safety" law.
The leaders of the first introductory meeting never made any serious effort to define organic farming or even walk through the law provision by provision.42 They did not discuss paradigm shifts and philosophy fundamental to organic production, nor the over-arching tenet that keeps organic farming special—its commitment to taking no unnecessary risks with the natural environment.
The NOPP staff at the Agricultural Marketing Service (AMS) consisted of mainstream bureaucrats schooled primarily in agricultural economics with no experience in organic production and no demostrable comprehension of free market supply-demand economics. Most staff members seemed focused on irrelevant pricing puzzles and persisted in basing organic "commodity" prices on surplus-based conventional prices. They referred to organic farming as an "industry" and their networking was usually based on these special interests. Direct marketing farming was a foreign concept to these individuals.
There seemed to be a constant and deliberate effort to delay promulgation. Bureaucratic inertia set in almost immediately and became overwhelming when the board prepared some final recommendations in June 1994. As of March 1995, still no rule had appeared in the Federal Register with respect to the standards the board earlier recommended.
The NOPP staff, NOSB chairman Michael Sligh and the majority of NOSB members failed to attempt to define terms and truly study the OFPA statute. Perpetual procrastination on how to address the "National List" process or content continues to
42. As of February 1995, a number of members of the NOSB had yet to review the OFPA statue.
43. The "National List" is a listing of allowed synthetic and prohibited natural substances for organic growers and processors. 7 U.S.C. § 6517(a) (Supp. V 1993). The OFPA provides guidelines for prohibitions and exemptions. 7 U.S.C. § 6517(c) (Supp. V 1993). For example, substances may be included on the National List that are otherwise prohibited under the chapter if:
(A) the Secretary determines, in consultation with the Secretary of Health and Human Services and the Administrator of the Environmental Protection Agency, that the use of such substances--
(i) would not be harmful to human health or the environment;
(ii) is necessary to the production or handling of the agricultual product because of the unavailability of wholly natural substitute products; and
(iii) is consistent with organci farming and handling;
(B) the substance--
(i) is used in production and contains an active synthetic ingredient in the following categories: copper and sulfur compounds.....;
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