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					                                  COMPILED COMMENTS
                                        ON THE


                        IFOAM BENCHMARK FOR STANDARDS

SA, UK: Replace BENCHMARK with Baseline. In English, a benchmark is what you
aspire to, not the floor. This standard is the floor.

NASAA, Australia:
‗IFOAM BASIC Standards‘ should be kept. The language baseline has been used and
benchmark(?, staff comment). Surely this distils into "basic" which still allows it to be a
benchmark if desired.

ARGENCERT, Argentina:
ARGENCERT does not agree with the use of the word BENCHMARK in the title of the
document. A benchmark is a position or document from which other higher level positions
or documents can be assessed. (Websters Dictionary speaks of a known height from
which other heights can be measured).

First of all, the IFOAM Benchmark for Standards is not a standard. Therefore, it cannot be
compared with any standard. It is not a basic or elementary, or simpler standard from
which other more complex or higher standards can be built up. It tells which areas must
be standarized, not how they will be as in a standard for production or certification.

Second, to use the same acronym is confusing. In the text of the Benchmark Stdrd. the
acronym IBS is used several times, and one cannot understand which IBS it is referring
to. Besides, in the general understanding, the IBS are the present 2005 approved basic
standards, which is supposed to be a standard against which to compare other standards.
This is not the case of the Benchmark Stdrd.


                             1st Revision Draft (16 April 2007)




START comment period: 16th of April 2007

END comment Period: 14th of June 2007
Organization                  Abbre     Country       Member/    Stakeh   Type of
                              viation                 Associat   older    commen
                                                      e                   t
Unilever – Sustainable        Unileve   UK                       X        Content
Agriculture Program           r
Pyongyang International       PIINTE    Korea         X                   Content
Information Center of New     C
Technology and Economy
Research Institute of Field   Selecti   Republic of   X                   General
Crops "Selectia"              a         Moldova
Living Planet                 None      Ukrania       X                   General
Opdebeeck Consulting Sàrl     Opdeb     Switzerland   X                   Content
                              eeck
Natratec International Ltd    Natrate   Israel        X                   General
                              c
Nanjing Global Organic        OFRC      China         X                   General
Food Research and
Consulting Center
Organic Foodstuffs Division None        Poland        X                   General
Faculty of Human Nutrition
and Consumer Sciences
University of Warsaw
Organic Trade Association OTA           US            X                   General
                                                                          + content
Organic Producers &           OPPAZ Zambia            X                   Content
Processors Association of
Zambia
EPOPA (Export Promotion       EPOP      Uganda                   X        General
of Organic Products from      A                                           + content
Africa) Biodiversity Group
Delegate for Inter Bio        IBB       France        X                   General
Bretagne to IFOAM
French Organic Farmers        FNAB      France        X                   General
Federation
Soil Association              SACL      UK            X                   General
Certification Limited                                                     + content
Soil Association Charity      SA        UK            X                   General
                                                                          +content
Rainman Landcare              RLF   South             X
Foundation                          Africa
Fédération régionale des      FRDAB France            X                   General
agrobiologistes de
Bretagne to IFOAM
Organic Agriculture Control   OACO      Dominican                X        General
Office                                  Republic
General Commission for        GCSA      Syria                    X        General
Scientific Agricultural       R
Research
Bioforsk Økologisk            Biofors   Norway        X                   General
(previously NORSØK)           k
Biologisk-dynamisk            Biologi   Norway        X       General
Forening i Norge              sk
Oikos - Økologisk Landslag    Oikos     Norway        X       General

Debio                         Debio     Norway        X       General
Canadian Organic Growers      COG       Canada        X       General

China Qulity Certification    CQC       China             X   General
Center                                                        + content
Bio Suisse                    Bio-      Switzerland   X       General
                              Suisse
NaturLand                     NaturL    Germany       X       General
                              and                             + content
Assoziation ökologischer      AoeL      Gernmany      X       General
Lebensmittelhersteller e.V.
Agrior.                       Agrior    Isreal        X       General
                                                              + content
KRAV ek för                   KRAV      Switerland    X       General
Schweizerische                BbV       Switzerland   X       General
BioberaterInnen-
Vereinigung".
Regional Standards            RSTW      Burundi,          X   General
Working Group                 G         Kenya,                + content
                                        Rwanda,
                                        Tanzania,
                                        Uganda
Nature & Progres France       NPF       France        X       General

Biokontroll                   BioKon    Hungary       X       General
                              troll                           + content
World Wildlife Fund           WWF       Germany           X   General
International
Schmidt, Attorney-at-law at   LOS       Germany       X       General
the court of Appeals
Jim Riddle - University of    JR-       US                X   General
Minnesota                     UoM                             + content
Fred Kirschenmann from        FKISU     US                X   General
Iowa State University
Swedish Organic Farmers       SOFA      Sweden        X       General
Association                                                   + content
Wild Farm Alliance            WFA       US                X   General
                                                              + content
IBOAA-Israeli Bio Organic     I.B.O.A   Israel        X       General
Association                   .A
KRAV ek för                   KRAV      Sweden        X       General
                                                              + content
Organic Material Review       OMRI      US            X       General
Institue
Brian Baker                   BB        US                X   General
                                                              + content
Equal Exchange Inc            EEI      US            X       General
                                                             + content
Biological Farmers od        BFA       Australia         X   General
AustraliaAustralia´s largest                                 + content
organic & biodynamic
certifier
Australian Certified Organic ACO       Australia     x       General
Japan Organic & Natural      JONA      Japan         X       General
Foods Ass.                                                   +
                                                             Content
National Association for      NASAA Australia        X       General
Sustainable Agriculture                                      +
Australia                                                    Content
Groupe de Recherche en        GRAB     France        X       General
Agriculture Biologique

WSDA - Organic Food           WSDA     US            X       General
Program                                                      +
                                                             Content
International Certification   ICS      US            X       General
Services, Inc.                                               + content
Organización Internacional    OIA      Argentina     X       General
Agropecuaria                                                 + content
Annie Kirschenmann            AnnieK   USA               X   General

Organic Consumers             OCA      US            X       General
Association                                                  + content
Forest Garden Product         FGPC     Sri Lanka     X       General
Certification System, Sri     S                              + content
Lanka
Mouvement de Culture Bio-     MCBD     France        X       General
Dynamique
International Organic         IOAS     US            X       General
Accreditation Service                                        + content
Food and Agriculture          FAO      Italy             X   Content
Organization of the United
Nations
Red de Agricultura            RAE      Peru          X       General
Ecologica del Peru
Forschungsinstitut für        FIBL     Switzerland   X       General
biologischen Landbau                                         + content
(FiBL)
The Rural Advancement         RAFI     US                X   General
Foundation International
Bureau of Export Trade        BETP     Philippines       X   General
Promotion
ARGENCERT                     ARGE     Argentina     X       General
                              NCER                           + content
                              T
Northeast Organic Dairy       NODP     US                X   General
Producers Alliance            A                              + content
Institute for Environment     IEDS     Banglades     X       General
and Development Studies                  h
Northeast Organic Farming      NOFA      US             X                      General
Association Interstate
Council
Federation of Organic Food     BOEL      Germany        X                      General
Enterprises                    W
Bund Ökologische
Lebensmittelwirtschaft e.V.
GROLINK                        GROlN     Sweden         X                      General
                               K                                               +
                                                                               Content
Fédération Nationale           FNIVA     France         X                      General
Interprofessionnelle des       B
Vins de l'Agriculture
Biologique
Institut Technique de          ITAB      France         X                      General
l‘agriculture Biologique
American National              ANSI      US                         X          Content
Standards Institute
General Comments

Selectia, Moldova: I was looking through the materials regarding the IFOAM Organic
Guarantee System and I found them good enough. I don't have any objections.

Natratec, Israel: I have read many times the IBS and my only comment is, welcome, go
ahead with that is a perfect work and good for everybody.

Ewa Rembiałkowska, Poland:
I've read carefully the draft and I generally agree with everything so I don't have any other
comments. The proposed standards are fine.

OACO, Dominican Republic:
After I read the IBS carefully I think that the structure and content of the document is
logical and complete, so as a basic guideline it will serve properly to those that are
interested to design their own regulation. Our opinion is that the document touch
every detail...

GCSAR, Syria:
In general, I found out that this document is comprehensive and it will surely facilitate
the access into organic world.

I do not have anything to say about the content, the page (questions and answers) in
the website, answered on my own questions, such as: what this new benchmarks
standards will do? And what will happen to the old ones.

PIINTEC, Korea:
Considering the situation of our country, we suggest to include ―genetic diversity‖ and
―organic seed‖ to the definition of the IFOAM Basic Standards. This is because the
genetic diversity as well as the biodiversity is important factor of organic agriculture.

Maintaining the genetic diversity of the variety consolidated in the process of the living
origin and evolution is one of the important ways to introduce organic production.
Today, organic agriculture must contribute to solve the food problem worldwide. For it, we
have to increase systematically the soil fertility in the field of crop production. At the same
time, we have to develop the new methods of organic production combined scientific and
synthetic techniques to increase the annual yield.

Selecting the organic seed and developing the breeding is main way to increase the
cereal production using less or no chemical fertilizer.

Linving Planet, Ukrania:
After necessary consultations and considerations we believe the following amendments to
the 1st Revision Draft (16 April 2007) of IFOAM BENCHMANRK FOR STANDARDS are
applicable:

1. Specifying the accreditation criteria – requirements for the certification body to conduct
certification in a trustworthy manner;
2. Inserting a clause ―Normative references‖;
3. Listing specific legislation and / or normative documents, such as EU Directives and
International Labor Organization (e.g., clause 9.1 of the present Draft);
4. Specifying definitions ―reasonable suspicion‖, ―deliberate use‖ or ―minimum use‖ in
measurable quantities or procedures for their calculation;
5. Giving substantiated methods used for testing and conformity assessment / approval of
the products at every single life cycle stage;
6. Providing detailed information about criteria for the products to meet;
7. Establishing quantitative measurable criteria or, at least, a certain range of applicable
indicators / parameters;
8. Recommending International Standardization Organization to introduce references to
applicable clauses of the present Draft;
9. Making a system of recording and identification: a database accessible for he general
public, with a transparent scheme of gathering data and keeping it up-to-date;
10. Establishing and bringing in the procedures of animals (husbandry, aquaculture etc.)
identification;
11. Supplying specific list of the allowed auxiliary materials: additives and processing aids
(e.g., in a number of clauses ―Standards must require that:‖)

OFRC, China: IBS was regarded as the basic statute for organic industry. So, it's thought
not revised frequently. But as I know it's revised almostly once in 2 to 3 years and every
time it has huge changes. I think it's not good for people to understand what's organic. If
it's possible to compile a leaflet to analyze most of the changes and explain the reason
why to change it so as to help people to understand the advance of organic farming.

FNIVAB, IBB, FRDAB & FNAB, MCBD, ITAB, GRAB France;
As a member of IFOAM, our organisation expects the "IFOAM Basic Standards" to
be maintained, protected, developed and regularly revised.

NPF, France: As a member of IFOAM, Nature et Progrès expect the IFOAM Basic
Standarts to be maintained, protected, developed and regurlarly revised.
We know that IFOAM Benchmark for Standards (IBS) oriented for Certification
Bodies but many Participatory Garantee Systems (PGS) exist in the world.
´
SACL, UK: Equivalence and the MLA:Soil Association has come under strong
pressure from other CB‘s to reduce its list of additional requirements under the MLA.
Unfortunately, it would appear that there are many areas within the benchmark that
are so open to interpretation in the name of market access that we will have no
choice but to increase the list of additional requirements under the MLA.

We strongly advise IFOAM to look at the changes it has made to the IBS and
consider the impact that this first draft will have on ACB‘s if changes are not made.
We feel that a lot more clarification is required in many areas. The clarification exists
in the current IBS.

SA, UK: This draft is based on a false premise. The motion on the revision of the Organic
Guarantee System that was finally approved at the 2005 GA in Adelaide (agenda point
27) read as follows:
That the purpose of the Organic Guarantee System should be to protect the integrity of,
ensure consumer confidence in and facilitate market access for, organic products.

This has subsequently, and therefore unconstitutionally, been amended to (from IFOAM
In Action no 89):

That the purpose of the Organic Guarantee System should be to facilitate market
access for organic products and to protect the integrity of, ensure consumer
confidence in and facilitate access to organic products.

In other words, the original priority of the review, namely to ‗facilitate market access‘, was
reinstated. This was precisely that which had concerned the GA and which caused the
amended motion to be approved.

Clearly, this IBS draft has been based on the unconstitutionally altered motion. It
would be nothing like this if it had been based on the real, and properly approved,
motion. In both intent and content, this draft is therefore fundamentally flawed and
must not proceed.

Bioforsk, Biologisk, & Debio, Norway:
Our comments and questions are mainly dedicated to the intentions and principles,
on which the proposal for the revision of ―IFOAM Basic Standards‖ into ―‖IFOAM
Benchmark for Standards‖ is based. However, we do have some general comments
to the structure of the new IBS as well. On the next occasion we will comment more
specifically on the content, provided that the summary of comments on the first draft
makes it possible for IFOAM to go on with a version 2, as planned.
1) Basically, we appreciate IFOAMs trial to develop a framework for standards in
    order to contribute to the harmonization of standards globally, including both
    private and governmental sector. If IFOAM succeeds in obtaining the necessary
    acceptance for such a concept from both sectors, and at the same time maintains
    the possibility of being a ―spear sharp‖, showing a united organic world the
    directions for a further dynamic, standard developing process to ―higher organic
    levels‖, much is probably achieved for everybody. However, we do have some
    questions related to this item:
  a. What about Codex for organic standards?
    Our understanding is that the new IBS intends to replace the role of Codex as the
    global, common framework and reference for organic standards.
  b. Is it likely to believe that the governmental sector and the UN-system will
    accept and support such intentions?
  c. Has IFOAM discussed such issues with relevant stakeholders?
2) The current IBS makes it possible, even for standard setting organizations in
    regions with governmental standards, to develop their own set of standards - as a
    private based supplement. Debio for instance, has developed additional
    standards to EU Reg 2092/91 according to IFOAMs Organic Guarantee System
    (IBS). If 2092/91 is accepted as equivalent to national (Debios) IFOAM-standards
    based on the new IBS-framework, the additional IFOAM-standards will loose their
    meaning. Consequently, the operations will loose the possibility of producing
    organically on a higher (―more organic‖) level than governmental levels, based on
    a reference to international framework and guidelines.
  a. How does IFOAM intend to cope with this challenge, and keep up the ―spear
    sharp‖-role in developing standards, globally and nationally, with the new concept
    of IBS? As we see, it will not be possible to develop the new IBS-framework more
    quickly than suitable and accepted from the whole ―Family of Standards‖,
    including the dominant, state authorities (governmental sectors) around the world.
3) Basically, we do have positive comments to the proposed structure of the revised
    IBS.
  a. However, the relationship between ―Principles applied‖ and IFOAMs 4 Principles
       of Organic Agriculture should be more obvious.
     I. Could a reference to one or more of IFOAMs 4 principles be given explicitly in
         the introduction (―Principles applied‖) in each chapter?
  b. It may be difficult to see the difference between ―Standards must require that:‖
       and ―Mandatory practices:‖
     I. Could ―Standards must require that:‖ be taken out, moving the necessary
       items to ―Mandatory practices:‖?

COG, Canada: While we appreciate the intent of developing a benchmark for
standards that allows for more variation in how standards are written to meet the
principles and objectives, we believe more work is needed on the current document if
it is intended to be a tool to maintain the integrity of organic production and
certification.

The use of the same acronym IBS, when the old and the new are conceptually quite
different, may also create problems and hinder the understanding of the intent. It
might be useful to include a few examples in the preamble of possible standards
wording that would meet the intent of ―Standard must require that ….‖ to
demonstrate the way you expect the document to be used.

There are also several sections where it seems it is assumed that the reader knows
what would be an acceptable approach because the benchmark does not provide
any kind of realistic benchmark. Conversion (3.2.1) is a case in point.

COG, Canada: There are also inconsistencies where this new IBS is more
prescriptive than the old…
Other statements could use more elaboration in order to understand the issue and
intent. For example …

CQC, China: We have read the draft of IFOAM Benchmarking for Standards
carefully. Our comments are as follows:
First of all, we thank you for your effort on the drafting of IBS. We noticed that there
are so many changes in the draft and this definitely need a lot of work to do.
Secondly, we do think that the IBS will be used world widely as a benchmarking for
standards setting, while not a standard for a single country. So we think that it should
not be revised for particular circumstances of some national standards. Based on the
experience of past organic movement, the IBS have many reasonable changes and
leave much space for the national standards setting, although there are still some
points which need to be measured.

Bio Suisse, Switzerland: We have studied the draft and discussed with FiBL
Research Institute of Organic agriculture in Switzerland.
After that, we fully support the FiBL position and also express our deep concern with
the way in which the IFOAM Basic Standards (IBS) have been redrafted and with the
oversimplification of the proposed revision.

NaturLand, Germany: Naturland values the opportunity to comment on the
presented draft of the IBS benchmark for standards. As an IFOAM accredited
certification body Naturland is among those that are most prominently affected by
changes of the IBS resp. the IFOAM Norms.

For concrete proposals for changes in wording we have focussed on the aquaculture
section and have entered proposals for improvements in alteration mode of that
section.
However, we would most prominently like to express our concern with the
development of such a benchmark for standards as a whole. From the viewpoint of
the objective of increasing the number of IFOAM accredited certification bodies it is
certainly comprehensible to develop a very basic and broad standard that provides a
simplified possibility for access to this system. The question however is at what cost
that growth will be achieved if the range of what may be called organic will increase
considerably and may as a consequence lead to increased pressure on CBs with
definite and consequent requirements, leading to an increase in lowest level and
cheap organic product on the market and a possible door opening for free riders to
the organic system.
From the viewpoint of an IFOAM accredited certifier like Naturland that has
contributed to this system for years and that developed detailed standards
requirements this new concept of the IBS as a basis for organic is disappointing.

The value of an IFOAM accreditation on the basis of these new IBS benchmark for
standards will be diminished considerably and will in the case of Naturland lead a
discussion of whether IFOAM accreditation is worth keeping up or only on the basis
of a ―best practice‖ accreditation which however again will separate rather than unite.
The benchmark for standards do in our view not provide for a sound basis for
equivalence of organic standards since the requirements are in general far too vague
to provide a trustworthy basis for acceptance of organic standards from the future
family of standards. The consequence will be elaborate, long lists of additional
requirements or exclusion lists that ACBs would have to fulfil in order to be
recognised by Naturland.

Many of the set requirements do in our view not distinguish organic from conventional
but rather bad conventional from good conventional practices since they are already
a set standard of many conventional operations as well. The indicative list of
substances may provide a good guidance but since it is not compulsory ACBs will
have to check on equivalence of requirements here as well. We do not see the
current draft of the benchmark for standards as a sufficient basis for a trustworthy
implementation of organic requirements. As a consequence we would expect a kind
of ―guidance document‖ for definite interpretation of the general requirements from
the IBS benchmark for standards since the contents of the requirements are not
sufficiently defined in the current draft (see e.g. conversion times not defined,
ambiguous clauses for fertilisation (how to interpret: maintain and enhance soil
fertility?) and plant protection (no definite positive lists), etc).
Without definite interpretation guidelines the work of an accreditation body like the
IOAS will be made much more difficult by this as well.

From the mechanism described in IFOAM policy 42 on ―approval of certification
standards on basis of the IBS‖ we cannot see a reproducible procedure on what are
e.g. acceptable times for conversion periods in order to be accepted to the family of
standards. We would appreciate to receive more information on this interpretation of
the requirements of the benchmark for standards when accepting a new standard to
the family of standards.

We doubt that an IFOAM accreditation on the basis of the new IFOAM benchmark for
standards will serve the purpose of increasing the number of qualified organic
certifiers worldwide while increasing the trust in organic and the value of an IFOAM
accreditation on the basis of that system at the same time.

AoeL, Germany:
The draft has been studied and discussed among our member companies.
In general we have problems with the presented document! We are fearful that this
new approach will weaken the position of the organic movement tremendously.
We like to focus our comments on some general topics.

We understand the IBS as a document with two different objectives.
One objective is to be a guidance document and an important reference for the
organic movement word wide.
The other function is the function of IBS as minimum standards within the OGS.
Therefore the actual IBS are based on ―aims‖, ―recommendations‖ and ―minimum
standards‖. In the actual structure there is no concept in place to transform
recommendations in minimum standards. In older times therefore the tool of ―draft
standards were used‖ to enable the accredited certifiers to adopt their systems to
justifications or new areas in the IBS.
Now we are facing a new structure which does not include recommendations or draft
standards at all. Now we find ―Principles applied‖, ―Objective is‖, ―The standards must
require that:‖, ―Mandatory practices‖: and ―Prohibited practices‖:

We think it is very important to keep the functionality of the IBS as guidance
document.
We ask for implementing a ―development tool‖. That means a tool which enables to
introduce new areas and standards in the IBS. This new areas or standards should
be understood as objective for further development in the whole IFOAM community.
Especially today such instruments are needed. The whole organic community needs
new impulses for future development and the IBS should assist them.

We see that consequently the IFOAM Principles were translated in the IBS by
introducing each capture with a ―Principles applied‖. But the formulations we find in
the text mostly need to be formulated much stronger and clearer. For example ―
Organic agriculture is based on the sustainable use of resources.‖ or ― Organic crop
production
aims to attain ecological balance‖ or ―Care, precaution and responsibility are the key
concerns in management, development and technology choice in organic
processing‖ or ―Technologies in organic processing ensure that the finished product
is healthy, safe and produced in an ecologically sound manner‖.
If you take away the word organic you end up with wording which you easily will find
in company aims and guidelines of 90% of operators in the food sector. The wording
must be stronger and must clearly demonstrate were the key differences are.

Hagai, Israel:
As a proud member of IFOAM, and as IFOAM accredited certified, Agrior's general
approach apposes the whole newly proposed revision of IFOAM's OGS. Throughout
the years, IFOAM as NGO, and as a democratic representative of the global organic
movement have strived for, and achieved the role of leading the global "Organic"
agenda. A most significant tool to that end was the OGS.

The introduction to IFOAM Norms (2005) states: "In the rapidly growing environment
of marketing and trade of products, claiming to be "organic", IFOAM provides a
market guarantee of integrity of organic claims". In our view, the newly proposed IBS
cannot be used as an efficient tool for this aim.
The new IBS does not state minimal required baselines for organic production in a
whole range of issues (such as length of conversion periods). How can
"distinguishing organic from non organic" be possible without defined base lines?

To our view, all stakeholders within the organic production and trade arena- must be
deeply concerned with any possibility of lowering thresholds and/or making definition
of what is and what is not organic- less clear. We fear that by "opening" the
standards, the IFOAM paves its own path for the loss of its relevance, authority and
credibility in the eyes of legislators, and consumers. We fear that loss of public trust
will be the end to IFOAM.

BBV, Swizerland:
We discussed the procedure of our notification to the IFOAM Benchmark for
Standards (16th of April 2007) at our general assembly from 9 May. Because several
of our members are involved into the notification of FiBL, we decided to take over the
feedback and argumentation of FiBL.
We would like to express our deep concerns with the way in which the IFOAM Basic
Standards (IBS) have been redrafted and oppose the oversimplification of the
proposed revision.
The current IBS are the result of years of extensive debating and meticulously
chosen language. They allow both for leadership and unification of the organic
movement and have been an important basis to lobby successfully for changes in the
new EU-Regulation and Codex Alimentarius Guidelines. IFOAM would be
jeopardizing its credibility if approving the new draft standards.

Objectives of the OGS Review not adequately addressed
We feel that several objectives of the OGS Review have not been adequately
addressed. The Benchmark Standards do not sufficiently ―draw a distinct line
between organic and non-organic‖ as it was requested by objective 1 of the OGS
Review (minutes of the General Assembly 2005). In some chapters they scarcely go
beyond good integrated production and animal welfare standards.
Also objective 2 of the OGS ―to maintain trust between parties involved‖ is not met,
since with such standards it would not be possible to meet consumer‘s expectations
for a clear differentiation between organic and non-organic production.
Objective 3 of the OGS Review ―to safeguard the integrity of organic production and
certification‖ has been completely missed by oversimplifying the central focus areas.
By this simplification the agreed consensus in the standards development over many
years is neglected.

Defining objectives and principles
Several principles in the draft are yet phrased very general and need to be
formulated stronger and clearer, e.g.: ―Organic agriculture is based on the
sustainable use of resources‖ or ―Organic crop production aims to attain ecological
balance‖ or ―Care, precaution and responsibility are the key concerns in
management, development and technology choice in organic processing‖. The
wording must clearly demonstrate the key differences to non-organic agriculture.
Recommendations and draft standards are important for future developments
Another problem is that the draft is inconsistent, e.g. in the field of processing (7.2.2)
it is even stricter than most private standards and can hardly be met in countries with
an early stage of development of organic agriculture. Since it is important to indicate
areas, where further development is necessary such as regarding processing, BbV
recommends to maintain the tools of recommendations and draft standards.

BbV believes that it is very important to keep the functionality of the Basic Standards
as guidance document. The actual IBS structure with ―aims‖, ―recommendations‖ and
―minimum standards‖ perfectly allow ―guidance‖ on the one side and ―reflection‖ of
the current practices on the other side. This allows a balanced approach between
facilitating market access and protecting integrity as requested by the General
Assembly. Over many years, the ―draft standards‖ enabled the accredited certifiers
as well as the member organisations to adapt their standards on a middle-term basis.
The proposed structure for ―Benchmark standards‖ do not allow for a concept of
development. BbV asks therefore to maintain and further develop the existing
development tools. New areas or standards, e.g. in the field of processing, should be
understood as objective for further development. The organic community needs new
impulses for future development and the IBS should assist this process.
Maintain the requirement level and further develop the tool of regional variation

BbV recommends revision of the IFOAM Basic Standards on the level of the current
version since it reflects an international agreement developed over more than 30
years. Improvement of accessibility can be achieved by allowing regional variations
on the basis of clear criteria. The basis should be a transparent procedure, where the
applicants show that they fulfil the common basic principles and criteria and report to
the Standards Committee. This approach could also be guidance for the EU which
has chosen a similar approach however jeopardized its effectiveness by lack of
transparency.

Conclusive remarks
A further improvement of specific principles and objectives in the different thematic
chapters based on the four overarching IFOAM principles would be welcomed. They
need to be phrased stronger and clearer, indicating key-differences to non-organic
agriculture.
If IFOAM would decide to maintain the new structure, it would be absolutely
necessary to become more precise in language, to define for selected areas the
absolute minimum and to provide minimum time-frames or other data (e.g. for the
conversion period), as it was the case in the current IBS. Furthermore it is necessary
to keep the annexes and to maintain the level of the current standards.
Please find the detailed comments of BbV to the Draft Benchmark Standards of
IFOAM in the separate document attached. We urge the IFOAM Board and the
Standards Committee to reconsider the draft, and to elaborate a new version, which
will contribute to safeguarding the integrity of organic production and maintaining the
leading role of IFOAM in the standard setting processes. We further recommend re-
introducing the paragraphs of ―recommendations‖ which describe the visions and in a
sense are the benchmarks for future developments.

Fibl, Switzerland: We wish to thank you for the occasion given to comment on the
first draft of the IFOAM Benchmark for Standards. The draft has been studied and
discussed by the Teams of FiBL Switzerland, FiBL Germany and FiBL Austria. While
recognizing the significant work done by the Standard Committee, we wish to
express our deep concern with the way in which the IFOAM Basic Standards (IBS)
have been redrafted and strongly oppose the oversimplification of the proposed
revision.

Historical development of the IBS
The current IBS are the result of years of extensive international debating and
meticulously chosen language. They allow both for leadership and unification of the
organic movement and have been an important basis to lobby successfully for
changes in the new EU-Regulation and Codex Alimentarius Guidelines. FiBL
believes that IFOAM jeopardizes its credibility by approving the new draft standards.

Objectives of the OGS Review not adequately addressed
FiBL feels that several objectives of the OGS Review have not been adequately
addressed. The Benchmark Standards do not sufficiently ―draw a distinct line
between organic and non-organic‖ as it was requested by Objective 1 of the OGS
Review. In some chapters they scarcely go beyond good integrated production and
animal welfare standards. Also Objective 2 of the OGS ―to maintain trust between
parties involved‖ is not reached. With the proposed standard consumer‘s
expectations for a clear differentiation between organic and non-organic production
are not met. Objective 3 of the OGS Review ―to safeguard the integrity of organic
production and certification‖ has been completely missed by oversimplifying the
central focus areas. By this simplification the agreed consensus in the standards
development over many years is neglected.

Defining objectives and principles
Several principles in the draft are phrased in a very general way and need to be
formulated stronger and clearer, e.g.: ―Organic agriculture is based on the
sustainable use of resources‖ or ―Organic crop production aims to attain ecological
balance‖ or ―Care, precaution and responsibility are the key concerns in
management, development and technology choice in organic processing‖. The
wording must clearly demonstrate the key differences to non-organic agriculture.

Recommendations and draft standards are important for future developments
Since it is important to indicate areas, where further development is necessary such
as regarding processing, FiBL recommends to maintain the tools of
recommendations and draft standards. FiBL believes that it is very important to keep
the functionality of the Basic Standards as guidance document. The actual IBS
structure with ―aims‖, ―recommendations‖ and ―minimum standards‖ perfectly allow
―guidance‖ on the one side and ―reflection‖ of the current practices on the other side.
This allows a balanced approach between facilitating market access and protecting
integrity as requested by the General Assembly. Over many years, the ―draft
standards‖ enabled the accredited certifiers as well as the member organisations to
adapt their standards on a middle-term basis. The proposed structure for ―Benchmark
standards‖ do not allow for a concept of development. FiBL asks therefore to
maintain and further develop the existing development tools. New areas or
standards, e.g. in the field of processing, should be understood as objective for
further development. The organic community needs new impulses for future
development and the IBS should assist this process.

Maintain the requirement level and further develop the tool of regional variation
FiBL recommends revision of the IFOAM Basic Standards on the level of the current
version since it reflects an international agreement developed over more than 30
years. Improvement of accessibility can be achieved by allowing regional variations
on the basis of clear criteria. The basis should be a transparent procedure, where the
applicants show that they fulfil the common basic principles and criteria and report to
the Standards Committee. This approach could also be guidance for the EU which
has chosen a similar approach however jeopardized its effectiveness by lack of
transparency.

Proposals for changes in the IBS
Please find the detailed comments of FiBL to the Draft Benchmark Standards of
IFOAM attached in the separate document. We urge the IFOAM Board and the
Standards Committee to reconsider the draft, and to elaborate a new version which
will contribute to safeguarding the integrity of organic production and maintaining the
leading role of IFOAM in the standard setting processes. We further recommend re-
introducing the paragraphs of ―recommendations‖ which describe the visions and in a
sense are the benchmarks for future developments. A further improvement of specific
principles and objectives in the different thematic chapters based on the four
overarching IFOAM principles would be welcomed. They need to be phrased
stronger and clearer, indicating key-differences to non-organic agriculture. If IFOAM
would decide to maintain the new structure, it is paramount to become more precise
in language, to define for selected areas the absolute minimum and to provide
minimum time-frames or other data (e.g. for the conversion period), as it was the
case in the current IBS. FiBl also considers it necessary to keep the annexes and to
maintain the level of the current standards.

RSTWG:The comments are mainly based on the content of the East African Organic
Product Standard ( EAOPS).

Biokontroll, Hungary:
We have read the 1st Revision Draft of the IFOAM Benchmark for Standards, but we
would like to add also our general comment on the document as we are very much
concerned about the whole approach of the standards revision process within the
OGS revision.
We understand and accept the basic goal of the revision procedures that the primary
aim is to harmonize standards and to facilitate international trade of organic products
and access to IFOAM accreditation. Otherwise we do not agree with the tool that has
been chosen to reach this purpose, as now we see that IFOAM has found that if
other standard-setting organizations and governments do not want to rise to our level
then we will have to put the level lower.
For us IFOAM has always represented the real trustful organic idea – since the very
first time when the organic movement here in Hungary started to organize itself and
Biokultúra Association - that was gathering all the pioneers in organic farming - built
up its own tandards in line with the IFOAM Basic Standards using it as a reference
standard.
The movement and its set of requirements has been started and formed by such
people and in such a way that it has become a true measure of organic production,
which role we believe cannot be undertaken e.g. by governments.
We have decided to apply for IFOAM accreditation because we wished to join this
movement which is bearing a real value. It is also a question of prestige as we
wanted to demonstrate that we are a certification body that is operating in the trustful
organic sector and not only within a compulsory administrative system.
In our opinion it was a suitable approach as we have imagined a harmonization that
is reached by a uniform standard but representing real quality.
Up to now the baseline was approached from the top, but now from the bottom –
considering especially the fact that the intention is to find the minimum common level
of national regulations as well. We think this approach is lacking the basic organic
values and considerations that are important for the consumer as well.
In this way we do not see the relevance of accreditation and the MLA signed by the
ACBs that was based on the trust in each other‘s high-quality work.

LOS, Germany:
Due to time restraints I picked out some issues, which I know, are highly disputed in
the market. Looking at these issues, I think, the draft does not adequately reflect the
expertise and the care of the IFOAM members working with organic products in their
daily businesses.

I suggested, to completely rework the draft carefully using the expertise knowledge of
those within IFOAM, who have discussed the same issues over and over again in
their regional and national systems. I concentrate on "prohibited practices", since
these prescriptions are the ones, which finally determine what IFOAM considers
organic or not.

I very well appreciate the lot of work, which has gone into this draft and into the
revision process. I know, how difficult it is, to come up with texts, which really work. I
have spend very many working days for IFOAM texts myself. However, I think, that
this draft is of such strategic importance to IFOAM, that it should be wholly and very
carefully revised looking at the fact, that it contains quite a number of though
decisions, which affect the heart of the organic movement and which have not been
discussed by the membership.

I suppose, that most of the members would not agree with the draft with respect to
quite a number of these "hidden" issues. There has been little membership input: I
think, because the proposed decisions are communicated "hidden" in a lot of
normative text and not addressed with sufficient
clarity.
JR-UoM, US:
In general, I find that the proposed changes blur the lines between organic and
conventional production. At a time when IFOAM should be a world leader in raising
the bar and helping standard-setting bodies and governments implement high
standards, it is disappointing to see the IBS is headed in the opposite direction.
Specifically, I find that, if the proposed changes are implemented, the IBS will:
1. allow extremely short, but unspecified time periods for the conversion of land to
organic production;
2. allow animals to be converted to organic with no specified requirements;
3. Allow animals to be rotated between organic and conventional management with
no restrictions;
4. Allow the use of unspecified quantities of non-organic feed for "organic" livestock
and aquaculture;
5. Not prohibit the use of cloned or transgenic animals or their progeny;
6. Allow the unregulated use of allopathic antibiotics and other medical treatments,
without withholding restrictions.
7. not prohibit or regulate the presence of GMOs in organic production or processing
(like the NOP, it would prohibit the "use," but not the presence);
8. Allow the possible use of synthetic fertilizers;
9. Not contain record keeping requirements, especially to document compliance
during conversion and split production;
10. Not require the use of buffer zones to protect organic production areas from
contamination from adjoining land uses; and
11. Not define "organic production" as a proactive, ecologically sound management
system;
12. Repeatedly use vague, subjective, and unquantifiable terms such as "excessive,"
"appropriate," and "suitable";

Further, Section A, ―Function of the IBS,‖ discusses a goal of the revision as to allow
growth of the IFOAM "Family of Standards" without describing who determines which
standards fit in the "family" or what procedures are to be used for making such
determinations. Since being in the "family" will allow for functional equivalency, this
has the potential to seriously undermine the IFOAM Accreditation Program,
administered admirably by the International Organic Accreditation Services.

EEI,US: Equal Exchange Inc., a member of IFOAM, entirely endorses the comments
from Jim Riddle, which are attached.

FKISU, US:
First, I would like to commend IFOAM for recognizing the need to revisit standards
from time to time as the organic movement and nature itself evolves. What was
"sustainable" on our farm 20 years ago may no longer be so and certainly won't be
as peak oil and climate change begin to impact our farming operations in the next
decade and beyond.

That said, I must say I have some problems with certain parts of the proposed
standards and have at least one recommendation for a sort of "preamble" to the
standards.

I think that one thing we have not sufficiently emphasized in our organic standard
setting efforts is something that virtually all of the founders of the organic movement
took for granted---namely that our goal needs to be that of enhancing the capacity for
self-renewal in our agro-ecological systems. This was certainly central to the thinking
of Sir Albert Howard, J.I. Rodale, Eve Belfour, Rudolph Steiner and others. I think
that given the challenges we will be facing in the next decade or two---peak oil,
depleting ground water resources, climate change, ecological degradation---it will
become increasingly critical for us to keep this important ecological principle before
us. We have been able to get away with ignoring this fundamental principle in organic
because we have had cheap energy to compensate for depleting soil and other
natural resources with cheap energy inputs---albeit "natural" ones. The era of cheap
energy is rapidly coming to a close so it is incumbent on us to attend to the capacity
for self-newal. While I realize that "enhancing the capacity for self-renewal" is a goal
that will be extremely difficult to measure---at least in the short term---and therefore it
probably cannot be part of a certification "requirement" but I think it would be
important to keep it before us as one of our core principals by writing a "preamble"
that would be placed at the forefront of all of our certification documents. Just a
thought.

Now to my problems with the current version of the 2008 IBS which I hope you will
address before these become final.

1. I have been involved in certification systems for over 20 years and have come to
realize that not every issue can be specified in the certification standards language
and therefore the standards need to give some authority to the oversight body to
provide guidance to certifiers. In the case of IFOAM I gather this is the IOAS. So I
would strongly urge that in the final 2008 IBS some statements be added which alerts
the organic community that the IOAS will provide specific guidance with regard to
things like 1.2.3 "Water use does not excessively exploit and deplete available water"
so that the word "excessive" will have specific meaning---otherwise there will be no
effective way to enforce such a standard. There are many other places where the
standard requires such oversight. Good examples are all those places where
language like excessive, necessary, sufficient, appropriate, relevant, etc are used.
Without guidance such words become extremely subjective and therefore impossible
to regulate any intended outcome.

2. There are places where the 2008 IBS recommendations are going in the opposite
direction that organic consumers are demanding and would, if left in their current
form, open the door to the kinds of abuses that would drive many consumers out of
the organic market. It is increasingly clear that today's consumers not only want a
product that meets certain environmental standards, they also want to be sure that
other concerns are met. For example, as the current draft reads, 5.2.2 "The use of
non-organic feed is strictly limited to necessity (there is that word "necessary" again)
based on regional production practices." This opens a door that could allow some
producers to make a case for almost unlimited amounts of non organic feed because
organic was not available---especially would be abused by large corporate animal
operations---and would cause a huge outcry from consumers.

These are the sorts of issues that IFOAM needs to thoroughly review in this
document and make sure that such language is tightened and authority is given for
appropriate oversight or the standard will lend itself to the kind of abuse that could
destroy the organic industry. Today's consumers want more stringent standards, not
more lax ones. The cover of Time magazine a few months ago ("Forget organic, Eat
Local") should serve us as a warning, that if consumers can no longer trust the
organic label to provide them with what they want, they will abandon it. Please
tighten up this standard to meet consumer expectations.

SOFA, Sweden:
Swedish Organic Farmers Association generally approves on the approach to make
the IBS a standards for standards, enhance the accessibility to the OGS and also the
ambition to become a bridge between the different legislative systems (EU, NOP, etc)
and in that way facilitate trade and development of the organic sector.

We acknowledge the difficult mission for the Standards Committee, but we find there
is still a long way to go before we have a new IBS that fulfills its various aims.

We find the draft lacking in consistency in the approach in different chapters, for
example in level of details. In some chapters we think the removal of details has gone
too far and left the chapter without much real content. Chapter 5, animal husbandry is
an example of this.
This lack of stringency is also reflected in the language and use of terms.
More detailed comments are limited to the draft chapters 3, 4 and 5 - the areas where
our organisation has its main activities.

IBOAA, Israel:
We accept the document and believe that it reflects the development of the
International movement. More than that, we find new IBS keeping the organic spirit
while enable each local certification body to develop its suitable organic approach, in
details. We also agree that the standard should reflect the consumers' point of view,
and avoid situations of misleading.
Besides, we would like to add 2 points to the discussion. The first is
"Food Safety regulations. We believe that the standards must require demands to
keep and monitor food safety (like BRC/IFS) relating to physical, chemical or food
microbiological aspects.
The second point is, "Referring to local unique conditions". We think that the standard
have to fit the unique climate / topographic/ geographic areas and must enable
special inputs and qualities to the a.m areas.

OMRI, US:
Prohibited Practices and Substances: The proposal changes the current system of
General Principles, Objectives, Recommendations, and Standards and replaces
them with Principles Applied, Standards, Mandatory Practices, and Prohibited
Practices. These categories could be valid if properly applied, but the current draft
has a number of problems. The omission of recommendations loses the intent of
some of the principles. Also, recommendations have been promoted to standards in
the past and have been a useful tool for IFOAM in the past. IFOAM stands to lose its
leadership in standard setting by the omission of recommendations.
Specific requirements in organic standards set by standards-setting bodies must not
fall outside of the principles and must meet the objectives. The IBS fails to
accomplish this in many cases, only a few of which I will identify in the interest of
staying focused and keeping the comment brief. In the introduction, the difference
between the ―Requirements for Organic Standards‖ and the ―Mandatory and
Prohibited Practices‖ are explained. Throughout the text, there are contradictions
between these two sections.
The explanation for ―Mandatory and Prohibited Practices‖ states:
The role of the IBS includes setting a baseline for differentiating organic systems
from those that are not organic. In order to do this, it is necessary for the IBS to state
some practices that are always necessary in organic production and processing, and
others that are prohibited. Therefore, some Sections include relevant mandatory and
prohibited practices.

For one thing, this explains a ‗baseline‘ and not a ‗benchmark.‘ By itself, the
distinction has merit. However, of greater concern are those sections where there are
no mandatory or prohibited practices. In such cases, one could infer logically that
there is no difference between organic systems and those systems that are not
organic. By not distinguishing between organic and non-organic systems, the
proposed IBS threatens the very identity of organic agriculture.
There are also numerous internal inconsistencies, where mandatory or prohibited
practices appear to be specified under ―Requirements for Organic Standards,‖ but
there is no corresponding mandatory or prohibited practice to give the standard
setting body guidance as to what is acceptable. In some cases, even where there are
mandatory or prohibited practices specified, they are not sufficiently clear or
connected to the requirements to ensure that a standard must meet a minimal
baseline.

While there is a claim that the proposed criteria are based on the Principles of
Organic Agriculture, and in particular the precautionary principle, that claim is not
substantiated and begs the question. Instead of saying that the criteria must meet the
Principles of Organic Agriculture, the criteria are supposed to explain how one can
determine whether a substance meets the Principles of Organic Agriculture. While
the current criteria could be improved, they do a much better job of fulfilling the
Principles of Organic Agriculture than the proposed revision. In particular, the current
criteria have a statement of the Precautionary Principle, which was removed without
any justification or explanation.
IFOAM‘s Principle of Care states that ‗decisions should reflect the values and needs
of all who might be affected, through transparent and participatory processes.‘ The
criteria for the evaluation of substances can be improved by ensuring the
transparency of the evaluation process by stating what information needs to be
considered and by making sure that all the affected parties are able to participate.
The need for standard setting bodies to be transparent, competent, and
representative of all stakeholders is a fundamental problem throughout the proposed
Benchmark, but the problem seems particularly acute with the criteria used to
evaluate substances for use in organic production and processing.

The current IBS addresses these essential parts of the precautionary principle in a
way that the proposal does not. The current criteria are transparent and contain both
‗hard‘ and ‗soft‘ metrics for evaluating inputs. The process involves both IFOAM
internal bodies as well as final approval by the IFOAM membership. The proposed
criteria are nebulous and vague, containing only ‗soft‘ criteria. It is not clear who will
be applying these criteria or how IFOAM will evaluate standard-setting bodies for
competence and accountability to stakeholders.

The current criteria have a number of objective requirements that have been
removed in the proposal. Instead, the proposed criteria appear to be much the same
as the ones that the membership voted to replace in 2005 because they were
insufficient and not based on the Principles of Organic Agriculture. Merely saying
that the criteria are based on the precautionary principle does not make them so.
The Principles of Health, Ecology and Fairness are also better addressed in the
criteria found in the current standards.

In the absence of the Appendices, the proposed criteria make it impossible to
determine objectively if many substances comply with the IFOAM Basic Standards
and which ones do not. In such a situation, one can imply that many substance used
in agriculture could potentially be allowed under the IBS.

OMRI Suggested Revisions While OMRI cannot support the proposed IBS, the
following revisions are crucial for the document to be implemented consistent with the
spirit of the motion as amended and the Principles of Organic Agriculture as passed
by the General Assembly in Adelaide. The Criteria
for the evaluation of substances used in organic production and handling was also
passed in
Adelaide. OMRI requests that the IFOAM Benchmark for Standards maintain
positive,
indicative lists for the purpose of establishing the difference between organic and
conventional systems. Without such lists, there will be no tangible difference
between organic andconventional agriculture. IFOAM should also establish a positive
list of livestock feed ingredients and medical treatments, but OMRI recognizes that no
such list exists in the current IBS.

General Assembly Motion
OMRI protests the unconstitutional revision of the Motion from the 2005 General
Assembly as amended by the motion of the Soil Association and the Organic Crop
Improvement Association.
The Standards Committee should prepare a draft that is based on the motion that
was actually
approved by the membership at the 2005 Adelaide General Assembly rather than the
motion that was revised by the E-Board without authorization by the membership.


Conclusion OMRI appreciates your consideration and respectfully requests that the
draft revision of the IBS be withdrawn and resubmitted, using the motion as actually
passed by the GA in Adelaide as guidance. OMRI supports the efforts made at
comparing the proposed revision with the current IBS and agrees that the current IBS
not the proposed revision is a more appropriate starting place for the next revision.

BB, US:
While the proposed IFOAM Benchmark for Standards assert that they are based on
the Principles of Organic Agriculture, this claim is not supported by the document and
begs the question. Instead of saying that the standards must meet the Principles of
Organic Agriculture, the IBS is supposed to explain how one can determine whether
a standard meets the Principles of Organic Agriculture. The process of evaluating
standards to determine if they qualify needs to be explained much more clearly, and
be included in this document for discussion. The standards need to do much more to
distinguish between organic and non-organic systems. The revision presented makes
it appear as if there is very little difference between the two systems.

The requirements for the standards need to stand on their own. I would recommend
that the Standards Committee use a consistent style throughout the IBS so that it is
clear who is required to do what, and the action that must be taken in order to clear
the baseline or benchmark.
‗Principles Applied‘ are declarative statements of a single sentence where organic
agriculture is the subject. Where possible, it is helpful to quote from the IFOAM
Principles of Organic Agriculture. For example, ―Organic agriculture rejects genetic
engineering as an unpredictable technology.‖
Objectives are normative or prescriptive statements of the intended accomplishments
of organic farmers, handlers, processors, and other actors in the organic community.
For example, ―Organic Agriculture should attain ecological balance through the
design of farming systems, establishment of interconnected habitats and
maintenance of biodiversity.‖ These appear to take the place of ‗Recommendations.‘
Requirements for Organic Standards are directive statements that require action from
the standard-setting body.
In order to succeed as benchmarks and to evaluate whether a given standard is an
organic standard or to decide it is a standard for some kind of ‗greenwashing‘ the
requirements need to say more than the standard-setting body will set standards.
The requirements should give guidance as to what those standards should include in
order to be organic standards.
For example, Standards must require that: Organic practices take measures to avoid
contamination by prohibited substances.
Mandatory and Prohibited Practices are directive statements that usually address an
organic operator. Mandatory Practices Prohibited Practices are directive statements
that forbid specific actions, also usually by an organic operator.
The statement should say who is expected to do [or not do] what and should be a
complete sentence that has sufficient information for the subject to conduct the
appropriate action.
An example of a Mandatory Practice is: ―The operator shall take measures to prevent
the contamination of organic crops, livestock, and food by substances that do not
appear in Section C.‖
An example of a Prohibited Practice is: ―The operator shall not commingle organic
and non-organic products.‖

Attached is a marked-up version of the IBS with some suggestions. I was not able to
go carefully through the entire standards and carefully edit it according to style. Even
if I had taken the time, I am not sure that such an exercise would be appropriate. The
comments are intended to be constructive guidelines, even if the tone is sharp and
abrupt. My apologies in advance if I offend anyone—again the comments in the
attached document are my own and do not reflect the opinion of OMRI, members of
the Principles of Organic Agriculture Task Force, or anyone other than myself. Please
contact me if you have any questions.

JONA, Japan:
JONA and other ACBs‘ organizations have been accredited by complying with IBS
    in the past. IOAS is now executing two kind of accreditation
 1) One is IFOAM Accreditation with CB‘s standards based on IFOAM Basic
   Standards 2005 and Criteria for CB. If the draft of IFOAM Benchmark Standards is
   implemented and replaces IBS 2005, there would be no basic ground in common
   to compare each CB‘s standards.
    The reasons for this is that the Benchmark standards is vague and leaves much
    room ,and therefore each CB could make its own standards differently from the
    IBS 2005. Especially, lack of approved materials and vague definition of
    conversion period are critical. If those difference were not clarified, there would be
    no common understanding among ACBs and other CBs.
   Probably IOAS in cooperation with currently accredited CB should make
   Standards
   for IFOAM Accreditation.
2) Another Accreditation of IOAS is based on ISO65.
   ISO65 accredited CBs can co-exist regardless its own standards which must be
   based on the revised IFOAM Benchmark Standards or Government‘s regulations.
   Credibility of certified organic products has two aspects.
   One is related to credibility of inspection and certification and the other is related
   to
   its standards.
   Standards of any CB can be written and recognized by others, but credibility of
   certification is not easy to become credible without auditing by a third party.
   Participatory certification or declaration by an operator can only be trusted by its
   own society or group of people. Those certification is not suitable to open
   market.
   Even though accreditation by ISO65 is not perfect and it needs to modify to meet
   to
   local or regional cultural back ground, IFOAM in cooperation with IOAS would
   better pursue to this direction to promote and encourage organic agriculture in
   developing countries.

NASAA, Australia:
Firstly we do not recognize (literally) the motion from the GA that we debated and
voted on in Adelaide and that purports to provide the framework for this revision. It
should also be said in fairness that we have historically opposed the sentiments of
the revision as it was broadly construed by its supporters for reasons that we have
not believed it necessary for IFOAM in particular to make this dive for the bottom of
the fishpond so to speak when we have had such a historically high level of
leadership and authority in the standards setting arena.

We continue to see this step as one , that without attention to the draft, could easily
see IFOAMs organic signature become illegible!

We would begin our brief discussion of the appended and annotated draft by saying
that despite the intention of the document under the new revised framework or
similar, there remains strong justification to continue with the title of Basic Standards
and that the maintenance of such a title may help maintain a level of operational
relevance for the document in the standards world!

Our chief concern lies with the absence of annexes and reference to same in the
body of the revision. We cannot see how organic can be differentiated from
conventional if certification bodies are not provided with basic input parameters in the
form of annexes. In relation to this, the absence of mandatory or prohibited practices
in most sections compounds the lack of definition when it comes to organic vs
conventional practices, and as such we have endeavored to insert instructive
language in these sections,

We have removed several highly subjective standards requirements which we
believe do little to enlighten the reader or the operator. Our reading of the text and
language within the body of the document is very favorable in most cases and the SC
should be congratulated for the breadth and precision of their work, subject to the
limitations posed by the (revised) GA mandate.
However, we believe there is, if one takes the broad view, a diminished emphasis
placed on the quality and integrity of the finished product vs the sustainable
environmental production process. This deficiency is further highlighted by the
adoption of an outcome oriented approach which does not appear to be so well
reflected in the ―objectives‖ As a consequence, we have inserted language that
draws greater attention to the productivity and to the organic integrity of the products
in the text.

There are a number of other self explanatory amendments we have made without
comment, but we have serious doubts that the organic sector who have developed
the systems that we have today will benefit at all from this revision, and indeed , as
stated earlier , fear that this document will weaken the IFOAM position irreparably.
However, with the inclusion of a series of annexes and more attention to mandating
basic practices, the restructure may maintain some of the valuable elements of the
IFOAM BS and provide ongoing relevance for those that chose to be accredited to it.

In conclusion, we would say that we cannot support the draft as it stands and would
urge the IFOAM authorities to permit the SC to restructure the revision documents in
ways that better reflect the GA motion and the sentiments of many of those present in
Adelaide and resuscitate the annexes from the existing standards as a part of this
process.

WSDA, US.
The goals of the IFOAM Organic Guarantee System are to unite the organic world
through a common system of standards, verification, and market identity. In order to
unite the organic world IFOAM needs to recognize the organic regulatory systems
that are already accepted in the marketplace. The IFOAM Benchmark for Standards
should 1) provide a clear distinction between organic and conventional agriculture
and 2) be aligned with the major existing organic standards around the world
including the European Union‘s organic standards and the US National Organic
Standard. Unfortunately, the proposed IBS fails in both of these areas.
The proposed IBS is too vague in many areas and fails to make a clear distinction
between organic and conventional agriculture. The lack of defined terms and
measurable criteria leave the IBS much too vague. Examples of this include:
     Lack of required conversion time
     No prohibition on synthetic NPK fertilizers
     No prohibition on organochlorine, carbamate and organophosphate pesticides.
     Allowance of antibiotics in livestock production.
     No specificity on the amount of organic feed required.

The proposed IBS is not aligned with existing organic standards. Specifically the
proposed IBS would eliminate the US organic farming community from participating
in the IFOAM Organic Guarantee System by its prohibition on the use of sodium
nitrate.
The Washington State Department of Agriculture (WSDA) is IFOAM accredited for its
European organic certification program. Due to the current regulatory structure
IFOAM standards are not compliant with the US National Organic Standards.
Therefore, the majority of organic growers in Washington State are not in the IFOAM
accredited program. WSDA would like to have all of its programs (NOP, JAS, and
EU) IFOAM compliant. Due to U.S. National Organic Standards and IFOAM Norms it
is not currently feasible to create an IFOAM accredited NOP program. How can
IFOAM unite the organic world if the largest organic marketplace is unable to
participate? Why would U.S. organic farmers want to participate in the IFOAM
Organic Guarantee System if they are automatically disqualified by their adherence
to U.S. organic standards?
The IFOAM Benchmark for Standards should include specific criteria that distinctly
define the difference between organic and conventional systems and are inclusive of
the existing organic standards around the world. The proposed IBS is too vague in
many areas and could lead to the development of standards that are antithetical to
organic principles including the use of synthetic NPK and toxic pesticide inputs. The
IBS should be redesigned to include specific criteria, measurable standards, and
allow all major organic standards to qualify under the IBS.

OIA, Argentina:
After reading the 1st Draft for revision of the IFOAM Benchmark for Standards it
seems to be clear that in various points the wording is more of Guidelines than a real
Standard.

This lack of a clear intended position for the document is reflected in points were al
reference is that the ―standard setting body‖. This could mean that anything accepted
by any Standard Setting Body will or could be considered equivalent.

On the other hand it seems to be a big difference in between Standards for
Benchmark than Basic Standards and Guidelines.

The idea for Harmonization is welcome and very good indeed, but having a
document that lacks of definitions and clarity will become it unacceptable for every
Standards Setting Bodies or Governments that find it weaker or not clearly defined.

If the aims of the OGS is Harmonization, IFOAM could always accept other weaker
Standards by specific exceptions, but how we could know that the others will apply
the same open criteria in order set bridges.

Lowering the level it seems not to be the best way for any potential harmonization.

IFOAM always was seen as a model to be follow, even IFOAM claims about his
leading position within the Organic Movement, the sound effort for becoming the
leader in harmonization to seems to be address in a way that could mislead the
consumers about what means to be organically certified or not.

In order to maintain the leadership in Organic Certified products and it meaning for
the consumers Harmonization should be seen as a part of the permanent
improvement cycle, not by lowering the IFOAM Standards as to a level that all
standards could match it or even surpasses it.

In such a way the IBS will mean almost nothing in the International Arena.

Of course this will completely diminish the IFOAM Accreditation value.

There are various points free to the Setting body decision, if the setting body take
weak position IFOAM will respect and follow it. This is a lowering of the IBS not
acceptable.
Beside other points that could be consider as lacking of clarity, the Standards seems
to propose a clear reduction in requisites in relation with the previous 2005 IBS
version in order to be so general that could be accepted for every body.

This vague interpretations of Basic Organic Standards could not represent the real
organic meaning for producers, processors, consumers and any other involved part
or stakeholder,

AnnieK, US: As a former World Board member, I have an ongoing investment in the
success of IFOAM. Regarding the new draft of the IFOAM Basic Standards, it is my
opinion that – if implemented -- these proposed changes will not achieve the desired
impact. Further, this version of the IBS could severely undermine the integrity of
organic, rendering it virtually indistinguishable from conventional.

I urge IFOAM to abandon this approach.

The fundamental problem as I understand it, is that IFOAM is attempting to use
standards as a tool to create accessibility. These are incompatible concepts and it
will not work.

I deeply appreciate IFOAM‘s intention to create greater accessibility and to grow
organic worldwide. This is very challenging, and I do not envy the job. However, to
approach accessibility through reducing standards to the lowest common
denominator is a weak, unworkable approach. It does not serve IFOAM or the
organic world we envision.

These proposed standards contain far too many vague and easily misinterpreted (or
deliberately manipulated) points. To name just a few:

1. undefined conversion periods;
2. broad and unspecific allowance for animal mutilations;
3. a window for the introduction of transgenic animals;
4. no record keeping requirements;
5. vague terminology throughout the document, such as ―suitable‖ or ―appropriate‖

Any one of these can render organic unrecognizable. And there are many more
examples contained in the proposed document.

If standards are used to create accessibility, then the proposed draft is about as good
as it will ever get. Using this approach, it will be virtually impossible to close the gaps
created by this set of standards. And IFOAM will set itself up to continually lower the
standards, as producers and processors in the future claim they can not meet the
requirements, and complain that IFOAM is being exclusive. . .there is your downward
spiral.

There are certainly other ways to increase accessibility, while at the same time
growing organic. For example, IFOAM could take a stronger role in helping organic
producers and processors meet good organic standards and practices; help them to
learn how to change their THINKING – which is where organic begins (and ends, for
that matter). IFOAM needs to explore alternative ideas for creating accessibility.
This a time when organic fraud is becoming rampant and government programs are
unable to stop it. It is a time when global warming and the depletion of fossil fuels will
begin to have an enormous impact on organic -- and how we trade organic products.
In these times, the organic world will increasingly look to IFOAM for strong
leadership; and IFOAM should be leading the way. Joining the race to the ―organic
standards bottom‖ will not fulfill that need; nor will it, in the long run, satisfy the
mandate set before the World Board by the General Assembly.

Again, I urge you to abandon this approach and seek alternatives.

OCA, US: As a longtime member of IFOAM, the Organic Consumers Association
recognizes that the proposed revisions of the IFOAM ―Benchmarks of Standards‖
were clearly drafted with the four principles of organic farming—health, ecology,
fairness, and care—in mind. Unfortunately, in its attempt to foster equivalence, the
new draft IBS is likely to encourage wide disparities in organic standards.

At a time when the rapid entry of powerful corporate interests into the organic market
is forcing a race to the bottom, this shift from ―Basic Standards‖ to ―Benchmarks‖ is
irresponsible and could ultimately obscure the distinction between organic and
conventional products and farming techniques. I nstead of trying to find the lowest
common denominator, IFOAM should actively promote the best practices of the
highest organic standards.

Even if IFOAM chooses to set a floor rather than a ceiling, the IBS should meet the
legitimate expectations of organic consumers who rightly believe that organic
production is a proactive, ecologically sound management system.

To avoid creating a multilevel hierarchy of organic standards that could deflate
consumer confidence in the concept, the IBS should drop unquantifiable terms and
set measurable benchmarks for both processes and outcomes.

For example, the section on crop conversion speaks in terms of a ―length‖ that is
―sufficient‖ to achieve an outcome. This would be okay if the outcome were
measurable, but the draft IBS contains no requirement to ascertain the extent to
which soil fertility was ―improved‖ and contaminants were ―reduc ed.‖

The section on animal production is even more vague with conversion periods
described as ―appropriate‖ with no reference to outcomes.

Organic farming has the potential to restore balance to the ecosystems whose health
the planet relies on. The Organic Consumers Association is committed to shifting as
much agricultural production to organic as soon as possible, but we think that the
best way to do this is with the highest organic standards. We trust that IFOAM shares
this ideal and will remain a leader in promoting the best practices of the highest
organic standards.

IOIA, US: This is a radical standard. It will open up organic agriculture in a way that
was never foreseen by earlier organic standards setters and will have the possible
consequence of economics taking precedence over the environment. It has been
written on the assumption that Certification Bodies will be sufficiently high minded
with regard to organic principles to supply thresholds and minimum requirements that
are missing in the IFOAM Benchmark for Standards. The reality, as more and more
CBs are run as a business rather than a service, is likely to be the opposite and
IFOAM is setting the scene for a race to the bottom.
The standard contains phrases such as "relevant", "appropriate", "excessive",
"sufficient" which will make conformity assessment both difficult and inconsistent.
Terms such as "early states of development" are undefined and will require a
subjective assessment. In many places the standard is lacking sufficient detail to be
useful. The IOAS and any other accreditation body conducting conformity
assessment against this standard will have to develop elaborate interpretative or
guidance documents. As IFOAM has agreed in principle to permit other ABs to
conduct IFOAM accreditation, then there are likely to be several such interpretative
documents which will not necessarily be in agreement with each other. Due to the
wide ranging interpretations that these standards will permit, it is unlikely that
certification bodies will recognize each using this as a basis. This point was clearly
made at the recent IFOAM accredited certifiers' (ACB) meeting in Bonn.
It has been stated that the Benchmark for Standards must be applied in a way that
meets the objectives of Principles of Organic Agriculture.
As well as being highly subjective, it is probably impossible to do this on any practical
level - this leaves even more room for interpretation and as it has been mooted that
the principles will not even be in the same document as the Benchmark, it is not clear
that the Principles will even be well known. The IOAS maintain that intentional or not,
the Principles will remain a largely theoretical document and the standards will be all
that matters. It is certainly not possible to accredit against the Principles, nor do the
IOAS believe that they were written with that in mind.
In addition to the points made above, the IOAS would also like to make the following
comments:
     Although largely removing detail from the standard, the level of detail in the
      various chapters is inconsistent and in the case of the aquaculture section,
      contains restrictions not seen in the general livestock sections e.g. setting of
      length of the conversion period. Examples are noted in the detailed commentary
      which follows.
     There are several instances where new content has been added. The IOAS
      had understood that one aim of this standard was not to add new content. In
      some cases the new content is highly restrictive compared to previous versions
      of the norms and may well provide a significant barrier to accessibility -
      examples are noted in the detailed commentary.
     There are other instances where the standard has been so altered that
      commonly held consumer expectations of organic products will not be met.
      These are also noted in the commentary.
     Previously the IFOAM Basic Standard has served as a reference point for
      organic standards setters throughout the world; has protectedorganic production
      from influences with vested interests; and has served as a benchmark to ensure
      regulatory standards remained true to the heart of the organic movement. Now
      most, if not all, regulatory standards will contain more detail and higher
      thresholds than the IFOAM Benchmark for Standards, so this level of protection
      will disappear. Governments and others will be able to justify practices which
      have never before been acceptable in organic agriculture on the basis that it is
      permitted by the IFOAM Benchmark for Standards. Organic agriculture may well
      be more widespread as a result, but will it be principled?
The IOAS requests that IFOAM reconsider and abandon this benchmark standard. It
may well have a place in the Family of Standards, but at the moment it is the only
IFOAM member of that family and on its own, is not enough to protect organic
integrity throughout the world orconform with the expectation of what makes an
"organic" product.

The IFOAM Benchmark for Standards contains:
    At least 45 standards where IOAS would need to write additional guidance or
     interpretation in order to conduct accreditation as the standard was lacking
     sufficient detail to be applicable. This would become, in effect, a "hidden"
     standard applicable only to accredited certification bodies.
    10 standards which most likley do not meet basic consumer expectations for an
     organic product
    13 standards where new content has been added which substantially alters the
     current norms and which in some cases will almost certainly restrict accessibility
    The standard will:
    permit practices which are not commonly permitted in organic agriculture e.g.
     use of chemical fertilisation materials �� permit addition of vitamins and minerals
     and such like to organic processed food with little restriction permit unspecified
     amounts of non organic feed in organic livestock production and aquaculture
    remove emphasis on positive organic management
    permit very short conversion periods for both crop and livestock production with
     the exception of aquaculture
    not provide adequate guidance for materials which may be used as inputs in
     organic agriculture. The proposed criteria for evaluation of substances used in
     organic production and processing is unworkable in its present form.

RAE, Peru: We congratulate this great effort. The only thing we would enjoy more is
the possibility to have it in Spanish, so we can distribute it within our members and, of
course, bring you more inputs.

RAFI, US: In general, we find that the proposed changes blur the lines between
organic and conventional production. At a time when IFOAM should be a world
leader in raising the bar and helping standard-setting bodies and governments
implement high standards, it is disappointing to see the IBS is headed in the opposite
direction. It will force much more; interpretations back into on the part of accreditors,
and open the system up to greater inconsistencies of interpretations and potentially
add additional confusion to reciprocity and most importantly consumer backlash.
While we appreciate the intent of this revision but this goes to far.

Specifically, we find that, if the proposed changes are implemented, the IBS will:
1. allow extremely short, but unspecified time periods for the conversion of land to
organic production;
2. allow animals to be converted to organic with no specified requirements;
3. allow animals to be rotated between organic and conventional management with
no restrictions;
4. allow the use of unspecified quantities of non-organic feed for "organic" livestock
and aquaculture;
5. not prohibit the use of cloned or transgenic animals or their progeny;
6. allow the unregulated use of allopathic antibiotics and other medical treatments,
without withholding restrictions.
7. not prohibit or regulate the presence of GMOs in organic production or processing
(like the NOP, it would prohibit the "use," but not the presence);
8. allow the possible use of synthetic fertilizers;
9. further erode and undermine meaningful implementation of chapter 8
10. not contain record keeping requirements, especially to document compliance
during conversion and split production;
11. not require the use of buffer zones to protect organic production areas from
contamination from adjoining land uses; and
12. not define "organic production" as a proactive, ecologically sound management
system;
13. repeatedly use vague, subjective, and unquantifiable terms such as "excessive,"
"appropriate," and "suitable";

BETP, Philippine:
1.On the structure of the chapters supporting the IBS, there are indeed lack of
provisions describing elements under the prohibited and mandatory practices
specified under some chapters like under collection of wild products; what specific
tests can be conducted to ensure collection from sources are indeed organic? So
goes for other collection sources?
2. Most of all to adhere to consistency on stringent standards for organic products,
how about putting section for water quality in cleaning and sanitizing organic
products, what systems and tests must be used?
3. Kindly mentioned the specific negative lists of substances that should be included
under the additives section like the Codex Alimentarius guidelines.

ARGENCERT; Argentina.
ARGENCERT agrees in general with the new format given to the IFOAM standards
for standards for the organic production. We are aware that these are not either
production or certification standards, but a set of mandatory conditions that must be
elaborated by each ACB in order to write their own production and certification
standard.

With regard to the process through which the present Draft of the so called
Benchmark Standards was reached, it is to be noted that us ACBs received from
IFOAM several requests for comments to all the members. Nevertheless, ACBs
seem to have not read and understood the changes. We know that very few
comments were received by IFOAM; the result is that now the proposed changes are
harshly criticized. No doubt we are all too busy trying to solve the day to day
problems and that we all prioritize ―urgent‖ before ―important‖.

We sincerely believed that the whole sector wanted to harmonize both the standards
and possibly to have a single accreditation system, but then us certifiers resist other
efforts to harmonize the system, such as the IROCBs The latter try to be a tool in
establishing equivalence trying to harmonize to offer any control authority or new
government regulator a tool to save time and effort, not trying to reinvent the wheel
every the time.

In the different chapters general concepts pertaining to the whole organic production
are often repeated. Such as, e.g., in chapter 7, point 7.2.7, prohibited practices: ―The
use of substances to correct improper processing‖. The use of substances to correct
mistakes in production or processing are not allowed anywhere in organic production;
there is no reason to present it here. Perhaps it should have been included in
Chapter 1 or somewhere else where all those requirements that apply to the whole
document are collected.
Expressions such as ―restricted‖, ―whenever possible‖, ―limited‖, ―routine use‖, etc.
should be explained. For example. if synthetic products are to be permitted in
exceptional cases, their use have to be limited by specific conditions, such as they
are specified for textiles in the last sentences of Section C point c).

NODPA, US:
As President of the Northeast Organic Dairy Producers Alliance (NODPA) and Chair
of the NODPA Policy Committee and organic dairy farmers, we wish to take this
opportunity to express our disappointment and disagreement with many of the
proposed revisions to the IFOAM "Benchmark for Standards.‖
NODPA is the largest organic dairy farmer organization in the country and has a
membership of six hundred and thirty six organic dairy farmers. NODPA‘s mission is
to ―enable organic dairy family farmers, situated across an extensive area, to
have informed discussion about matters critical to the well being of the organic
dairy industry as a whole.‖ NODPA is not aligned with any one processor or
cooperative and is therefore able to represent the views of many different farmers
both in the northeast and across the country by working with its sister organizations,
MODPA and WODPA.

High standards that truly differentiate organic agriculture from conventional
agriculture are a must in order for certified organic production to have real meaning
and import. Many of these proposed revisions and vague wordings would blur /
remove the distinctions necessary for organic production to maintain its integrity.

NODPA endorses the comments and specific suggestions submitted by Jim Riddle.
In addition, we would like to add some points.

IEDS, Bangladesh. The first draft of the new IFOAM Benchmark for Standards
seemed to be okay.

NOFA, US: Please excuse my lateness. I live in a very rural area and my internet
service is via dial-up. Yesterday it did not want to work at all. Hopefully, this
message will go through today. While I am on the subject of obstacles, I would like to
add that for an organization like NOFA that depends on the work of volunteer farmers
like myself, your comment period, April through June, is truly a difficult time. In the
Northeast, this is when we are planting all of our crops. If we do not get everything in
the ground by early June, it will be too late for them to mature before the frosts of fall.
I imagine that for small, largely volunteer organizations in other parts of the world, the
obstacles to commenting would be even greater.

NOFA is a loose federation of organic farming and gardening associations with seven
state chapters in the northeast states of the United States. Each chapter is
autonomous with some coordination and guidance from the Interstate Council. Since
1971, NOFA has helped spread hands-on knowledge of organic food production and
land care and supported the development of economically viable, local, family-scale
organic farms.

Based on NOFA‘s 35 years of history with organic agriculture, we question the
timeliness of switching from IFOAM‘s Basic Standards to Benchmarks at this
juncture. Why make this kind of shift at this time? Had IFOAM established
benchmarks back in the 1970‘s when groups like NOFA were writing our standards
initially, the current draft document would have been very helpful as a guide. At that
time, the market for organic products was small, the people involved in standards
writing were the passionate true adherents, and governments had not yet even
considered the possibility of organic legislation or the establishment of bureaucratic
controls. The story is very different in 2007. Even in remote corners of the world,
people who are more attracted by the potential profits from organic products than by
the basic principles of organic agriculture are involved in the writing of organic
standards.

Since the first draft of the United States National Organic Program (NOP) in 1989, a
wide array of stakeholders has joined in the fray over organic integrity. At one
extreme are the chemically sensitive consumers who beg for food that is totally pure
and free of any chemical residues. Then there are the small-scale organic farmers,
the pioneers of organic agriculture in the US, who want to continue to make a living
as farmers in a cheap food economy. More recently, there are larger scale farmers,
attracted by the expanding organic market, who can compete with smaller margins
and higher volumes. Increasingly, there are food processors who claim the necessity
of ingredients and additives that are ―essential‖ to the production of their particular
product. And in the background are the USDA bureaucrats who opposed having an
organic program in their agency, but have had to adapt to running it without any
special training, background or propensity for organic agriculture. Political pressures
overshadow organic principles when the NOP makes decisions on the content of its
regulations. When all the stakeholders on the US organic scene work together, they
can affect NOP decisions. When there is division among stakeholders, the NOP
listens to those with the strongest political connections and the most economic
power.

The IFOAM Basic Standards have served as a model for standards around the world.
That is why it has been so important to maintain a transparent and democratic
process for creating the IFOAM standards. Tiresome as the old process of revisions
may have been, it allowed many different voices from different points of view and
social backgrounds, stages of organic development and sophistication, etc., to have
the opportunity to comment to IFOAM and to have their views heard. The detail of
these standards is terribly significant. The current process is much less transparent.

The proposed draft IFOAM Benchmark for Standards is open to all kinds of
interpretations and will serve as an invitation to the kind of tug of war we have
witnessed recently in the US over synthetic ingredients in organic processed foods.
These benchmarks will not facilitate equivalency, but allow for increased divergency
among standards, depending on the concatenation of forces in different localities. As
an example, the Benchmark for Standards says in section 5. 2. 2. that ―the use of
non-organic feed is strictly limited to necessity based on regional production
practices.‖ A large livestock company in the state of Georgia convinced their state
Senator that since Georgia produced almost no organic feed, the US law should
allow farmers to substitute as much non-organic feed as they wanted and still label
their meat organic. It took a huge political effort to turn back that amendment to the
organic law. In a country with a less well-organized organic public sector, the
livestock company would have had its way.

Section 7. 2. 2. would allow non-organic ingredients according to the ―need for
particular nutritional or essential technological needs.‖ This is much too loose a
statement. In the US, manufacturers of organic yogurt insist that pectin and
powdered milk are essential ingredients, yet there is much higher quality organic
yogurt that contains neither additive. Other manufacturers claim that various
additives are necessary for this or that product resulting in the proliferation of foods
on the market that are much more highly processed than organic food ever needs to
be. A company that markets organic macaroni and cheese argued in favor of allowing
non-organic annatto saying: ‖orange colored macaroni and cheese is an important
element of our offering. Without annatto, our macaroni-and-cheese products would
be white.‖ Clearly this company‘s view of essential technological needs is different
from mine. Does the world really need the organic ―Twinkie?‖ The NOP denial of
National Organic Standards Board control over ―food contact substances‖ may soon
bring us organic coke and pepsi.

NOFA has spent a significant portion of its resources and energies in lobbying to
maintain the integrity of the US NOP. High on NOFA‘s list of concerns is the total
failure of the NOP to address the social agenda of organic agriculture. The NOP
governs the use of the term ―organic‖ in the US marketplace, while insisting that
anything to do with social justice in organic agriculture is ―not within its purview.‖
Under the NOP, no farm will ever lose certification for failure to pay farm workers
decent wages and no company will ever lose certification for forcing unfair contracts
on farmers or for paying them less than the cost of production of their products. In
NOFA‘s discussions of organic standards we have often cited IFOAM‘s Principle of
Fairness and Chapter 8 (Chapter 9 in the Benchmark draft) as support for our
contention that organic agriculture means more than a marketing label. We would like
to see the IFOAM social standards become stronger and more specific, not weaker
as in this Benchmark draft. NOFA will be very disappointed if IFOAM fails to make a
strong case for the organic social agenda. The US government does not recognize
most of the ILO labor agreements and US labor law specifically excludes farm
workers from the right to organize. How can the US NOP meet equivalency with
organic standards that adhere to an IFOAM model that is based on the Principle of
Fairness?

Additional comments:
1. Organic Ecosystems: a mandatory practice might be – closely observe your
   ecosystem.
2. The ban on GMOs is not a total firewall against their use in organic food
   production.

BOELW, Germany: At the moment the revision of the EU Regulation for Organic Agriculture
– our compulsory framework for organic work – and the question of GMO-laws in Germany
take our first attention. So I hope that you still can take into account the remarks given with
this letter. We will thank for the opportunity to comment the draft. Our comments are
discussed with our member AoeL that itself wrote a similar comment.

In Germany we use an adage with the meaning that nothing is as changeless as change.
Therefore we appreciate a further development of IFOAM Norms and we will thank you and
your team for developing the actual proposal. Nevertheless it is essential to preserve
approved basics.

The IFOAM basic standards are characterised by three main principles:
   - they are developed by organic farmers, processors and traders themselves and
   - they are acknowledged by the organic movement but also by authorities worldwide as
      the basic definition of organic agriculture
   - they are the minimum standard within the OGS.
As the framework for organic agriculture worldwide and the minimum standard within OGS, it
is necessary, that the basic standards represent clear rules. Instead of that, the revision draft
seems to be no more the worldwide consensus of organic farmers clearly defining organic
agriculture and what is allowed to be done and what not. In fact possibilities of flexible
adoptions were planned and let it seem doubtable, if in a few years the strong standard still
exists and represents the clear framework for lawmakers, authorities, advisers and certifiers.
Hence we are anxious that the organic movement will be weaken when the change came
true in the intended way.

In the actual structure there is no concept in place to transform recommendations in
minimum standards. In older times therefore the tool of ―draft standards‖ was used to enable
the accredited certifiers to adopt their systems to justifications or new areas in the IBS.

Now we are facing a new structure which does not include recommendations or draft
standards at all. Now we find ―principles applied‖, ―objective is‖, ―the standards must require
that‖, ―mandatory practices‖ and ―prohibited practices‖.

We think it is very important to keep the functionality of the IBS as guidance document. We
ask for implementing a ―development tool‖. That means a tool which enables to introduce
new areas and standards in the IBS. This new areas or standards should be understood as
objectives for further development in the whole IFOAM community. Especially today such
instruments are needed. The whole organic community needs new impulses for future
development and the IBS should assist them.

We see that consequently the IFOAM Principles were translated in the IBS by introducing
each capture with ―principles applied‖. But the formulations we find in the text mostly have to
be formulated much stronger and clearer. For example ―organic agriculture is based on the
sustainable use of resources‖ or ― organic crop production aims to attain ecological balance‖
or ―care, precaution and responsibility are the key concerns in management, development
and technology choice in organic processing‖ or ―technologies in organic processing ensure
that the finished product is healthy, safe and produced in an ecologically sound manner‖. If
you use these sentences without the word ―organic‖ you end up with a wording you easily will
find in company aims and guidelines of most of the operators in the food sector. The wording
must be stronger and must clearly demonstrate were the key differences are.

On the other hand we see it positive to find a new way of dealing with the technical annexes.
Especially the substance lists need more flexible handling in dynamic growing markets. Also
the different cultural backgrounds and the very different stages of development in organic
farming and processing are asking for more flexibility in the area of substance lists.

We propose to introduce a similar tool as Codex Alimentarius has developed. The codex
guidelines include so called ―indicative lists‖. This means lists which are demonstrating a
world wide consensus on substances used for organic production. But indicative lists are not
closed lists. The Codex allows each country to add substances, if they have evaluated this
substances in accordance to the given criteria‘s. This approach could easily be adapted to
the given IBS by using the actual substance list as the ―indicative list‖. Further on a standard
has to be set which enables companies and labeling organization to evaluate further
substances for their own lists by using the given IBS criteria‘s. The positive evolutions should
be reported to the SC.
The IBS has strong and clear evaluation criteria in place! In the new draft the presented
criteria are a step backwards. In the new concept the evaluation criteria has a much higher
importance for the whole standard system! Therefore we ask for a further development of
evaluation criteria and not for less clear and weakened once. Clear criteria and an open,
transparent process are necessary for a permitted substance list to be valid.

GROLINK, Sweden
Generally we find it a good approach to make the IBS a standard for standard or a
benchmark as it is now renamed to. This is a cumbersome and challenging task for
the SC, which has done a good job, but there are still a lot of work to do. This draft
has several features of a benchmark standard but there are also areas where there
still are details from the current IBS and there are also some areas where the full
content get lost, there is too little to get understandable. I some places the IBS is
made much stricter, e.g. seeds, processing and labelling which we strongly question,
if the function of the proposed text will be for benchmarking..
Our comment is split in two parts; general comments directly following here and more
detailed comments written into the standard text itself.

The chapters
It is clear when reading the draft that there are different authors for different chapters.
The approach differs in the level of detail, sophistication of language, terms used and
difference in content to the current IBS. There are many comments about that in the
standards text itself. This has to be worked through better to get an even appearance
of the new IBS.

Principle applied
The principles are difficult to formulate, the IFOAM Principles are probably too
abstract and condensed to use. The General principles in the current IBS are uneven
and sometimes to weak. There have been efforts to write new or reformulate old text
to the ―principles applied‖ but some gets much to narrow and lean to really be
principles and seems to be more of recommendations.

Prohibited practises
The prohibited practises are often detailed standards recycled from the current IBS,
in some places they are wider and more covering. When details are mentioned, like
in 4.3.7 where sodium nitrate is prohibited it seems for the not totally initiated reader
like all other nitrates are allowed, or maybe all fertilisers are allowed. When the
standards are pretty general and then comes one detail as a prohibited practise it is
easy to get gaps in the standard.

Use ISO language
ISO directives part 2, annex H which is handling the language used in standards
recommends the use of the terms ―shall‖, ―should‖, ―may‖, ―need not‖, ―can‖ and
―cannot‖.

Simple language
Make the language simple, again it is uneven through the text, sometimes it is very
complicated. Try to get into a language more similar to plain English in the Soil
Association standard, check also the OECD style guide.

Conversion time
In the proposal the length of the conversion period is taken away , that is an
interesting approach, but it would be good for political reasons to keep the 12 months
or one production cycle.

Level of detail
Many details are taken away, that is good in many cases but it has to be done in the
same manner in the whole text, so far it varies quite a lot. There is also a difference
between the chapters, the animal husbandry standards gets to lean to really work
out, while for example plant production or processing probably will function, even if
processing is so strict that it will get difficult to use.

Another example is that wing clipping of bees is a prohibited practise while mutilation
of animals is very generally described.

Stricter standards
For seeds the proposal probably states that no chemically treated seeds are allowed,
the text is not clear. There are many places were still not untreated seeds are
available and there is no possibility for a producer, and especially a small scale
producer to be able to get hold of untreated seeds. We think it is better to make a
step wise approach so that this kind of organic production can be accepted even if
treated seeds have been used. Without any organic farmers there will be less force
and request for untreated seeds. There are also areas in the world were chemical
treatment is required by the legislation. We know that the SC is well aware of that this
is the case, but have still proposed this standard. What is the intention of the SC?

The processing and labeling standard has been made much stricter, labeling of origin
of ingredients, very strict formulations on conventional ingredients and in several
more areas. Is there a really a request to make the processing and labelling
standards so strict? Will the IBS then function as a benchmark at all?
Table of Contents

I. THE PRINCIPLES OF ORGANIC AGRICULTURE ................................................. 1
II. IFOAM FOR STANDARDS (IBS) ........................................................................... 2
Section A - Introduction .............................................................................................. 2
Section B - Definitions, Principles Applied, Objectives and Requirements ................. 9
Definitions ................................................................................................................... 9
1. Organic Ecosystems.......................................................................................... 16
1.1. Ecosystem Management and Biodiversity ..................................................... 16
1.2. Resource Management .................................................................................. 21
1.3. Collection of Wild Products ............................................................................ 23
2. Genetically Modified Organisms ........................................................................ 25
3. General Requirements for Plant Production and Animal Husbandry ................. 29
3.1. Conversion Requirements ............................................................................. 29
3.2. Conversion of Plant Production Systems ....................................................... 32
3.3. Conversion of Animal Production Systems .................................................... 35
3.4. Conversion of Organic Aquaculture ............................................................... 38
3.5. Split Production and Parallel Production ........................................................ 40
3.6. Maintenance of Organic Management ........................................................... 42
3.7. Avoiding Contamination ................................................................................. 43
4. Crop Production ................................................................................................ 46
4.1. Seed and Propagation Material ..................................................................... 46
4.2. Soil Conservation and Crop Rotation ............................................................. 50
4.3. Fertilization .................................................................................................... 53
4.4. Pest-, Disease-, Weed-, and Growth Management........................................ 64
4.5. Aquatic Plants ................................................................................................ 67
5. Animal Husbandry ............................................................................................. 68
5.1. Animal Health and Welfare ............................................................................ 69
5.2. Feed............................................................................................................... 75
5.3. Transportation and Slaughter ........................................................................ 81
5.4. Breeds and Breeding ..................................................................................... 82
5.5. Bee Keeping .................................................................................................. 84
6. Aquaculture Production ..................................................................................... 88
6.1. Aquatic Ecosystems....................................................................................... 88
6.2. Sources, Breeds and Breeding of Aquatic Animals........................................ 90
6.3. Aquatic Animal Nutrition ................................................................................. 91
6.4. Aquatic Animal Health and Welfare ............................................................... 93
6.5. Aquatic Animal Transport and Slaughter ....................................................... 94
7. Processing and Handling................................................................................... 95
7.1. General .......................................................................................................... 95
7.2. Ingredients ..................................................................................................... 98
7.3. Processing Methods .................................................................................... 101
7.4. Packaging and Containers ........................................................................... 103
7.5. Cleaning, Disinfecting, and Sanitizing Food and Food Processing Facilities 105
7.6. Pest and Disease Control ............................................................................ 106
7.7. Textile Fiber Processing .............................................................................. 108
8. Labelling .......................................................................................................... 110
9. Social Justice .................................................................................................. 113
Section C - Criteria for the Evaluation of Substances Used in Organic Production and
Processing .............................................................................................................. 114
I. THE PRINCIPLES OF ORGANIC AGRICULTURE

The Principles are not subject to consultation. For further information see IFOAM
website at: http://www.ifoam.org/about_ifoam/principles/index.html




                                                                             1
II. IFOAM BENCHMARK FOR STANDARDS (IBS)

Section A - Introduction

Role of the IFOAM Benchmark for Standards

The IFOAM Benchmark for Standards (IBS) provides a crucial link from the Principles
of Organic Agriculture to those standards that are applied directly to organic
production and processing. The IBS functions as guidance for developing and
evaluating these other standards, and for distinguishing organic from not-organic
systems. Therefore it is a baseline for determining which standards and practices can
be called ―organic‖.

A farm or processing plant could never be certified to this document. The document is
intended for use as a tool for setting more detailed organic standards according to the
Principles of Organic Agriculture. In order to link principles and standards, the IBS
establishes outcomes (called ―objectives in the document) that organic standards should
achieve in order to meet the principles. The IFOAM Benchmarkfor Standards also sets
requirements for what organic standards must address in order to achieve the outcomes
(objectives). The requirements do not usually prescribe ―how‖ to achieve the objective, but
leave that to organic standards. They are written in language that applies to organic
standards, not directly to the farm or processing operation. However, in order to clearly
distinguish organic from conventional systems and practices, the IBS do sometimes
specify production and processing practices that organic standards must require (called
―mandatory practices‖ in the document), and also practices that organic standards must
prohibit (called ―prohibited practices‖ in the document).
SA, UK: MUST replaces SHOULD

BB US: [organic standards according to the Principles of Organic Agriculture] Begs
the question. Show it, don‘t say it.

NASAA, Australia: A farm or processing plant could never be certified [directly]to
this document.

Fibl/BBV, Switzerland: The terms objectives and outcomes are used in a different
way, usually there is a differentiation between objectives and outcomes.


This approach in the IBS provides flexibility for organic standards to vary according to
the context in which that standard is applied to farming and processing (e.g. ecology,
stage of organic development, product specialization).

Hierarchy of Requirements for Organic Production and Processing
BB, US:
The metaphor of a pyramid is inappropriate and is counter to the Principles of
Organic Agriculture. It implies that the standards are set by ‗top-down‘ process and
the standards, not the principles are at the foundation. Instead, I propose the more
biological metaphor of a tree. To quote from the IFOAM Principles of Organic
Agriculture, ―The Principles of Organic Agriculture are the roots from which organic
agriculture grows and develops.‖ If the four principles form the solid roots of the
standards, then it follows that the IBS forms a solid trunk. The various standards that


                                                                                  2
comply with the basic standards are the branches. The twigs, leaves, fruits, and
seeds are the outcomes and objectives of organic agriculture.




                                        Principles of                   IFOAM
                                     Organic Agriculture


                              Outcomes (Objectives) for                             IBS
                          Organic Production and processing


                                       Requirements                                             IBS
                                   for Organic Standards

                                                                                                         Organic Standards1
                     Standards for Production and Processing

 1
 must include the mandatory and prohibited practices in the IBS, address all requirements and meet the IBS objectives




Function of the IBS

The IFOAM Benchmark for Standards functions as a guidance for organic standards
setting, as a tool for determining equivalence of standards, and as one of the two
norms that must be met in the IFOAM Accreditation Program.
FAO: [as a guidance for organic standard-setting,] replaces [as a guidance for
organic standards setting,]
Same as hereinafter

ANSI: Add - IFOAM Accreditation Program requirements for product certification
bodies complies with the criteria to be defined by the ITF group.

Guidance for Organic Standards Setting

The IBS is the framework of all other organic standards settingStandards that meet
the IBS can be considered and labeled as ―organic standards‖ because they are
consistent with the Principles of Organic Agriculture, address what is required by the
IBS, and comply with certain mandatory and prohibited practices that the IBS specify.
BB, US: [framework of all other organic standards setting]. How do you propose to
make it so? This is not explained.

Tool for Equivalence of Standards
IFOAM develops and maintains a Family of Standards. This Family consists of
private and governmentorganic standards recognized by IFOAM as meeting the
principles, objectives and requirements of the IFOAM for Standards
KRAV, Sweden include: which are minimum requirements.

BB, US:
How does IFOAM develop these [the family] ? Are these like the West African
standards?)

                                                                                                                              3
Family of Standards: This is another bad metaphor.
How does IFOAM ‗develop and maintain‘ government standards if IFOAM is a Non-
Governmental Organization.)
Recognized private and government-organic standards: Such as? What standards
are these?)

RAFI, US: ―Function of the IBS,‖ discusses a goal of the revision as to allow growth
of the IFOAM "Family of Standards" without describing who determines which
standards fit in the "family" or what procedures are to be used for making such
determinations. Since being in the "family" will allow for functional equivalency, this
has the potential to seriously undermine the IFOAM Accreditation Program.

Together, IBS and the Family of Standards form a tool for determining the
equivalenceof organic standards. IFOAM considers standards (with the same scope)
in the Family of Standards as equivalent
BB, US:
    – ‗Equivalence‘ Should be compliance / conformity and not equivalency. By
       whom and what process are equivalency determinations made?
    – Equivalent is not appropriate.

Development of the Family of Standards is governed by IFOAM policy and
procedure.
JR-UoM, US: Who determines which standards are allowed in the ―Family of
Standards‖? What are the written criteria and procedures for these determinations?
How does this relate to the IOAS review of standards for accreditation purposes?
How does this process strengthen, rather than diminish or undermine, IFOAM
Accreditation?
KRAV, Sweden: One objective of the development of ―Family of standards‖ is to
make trade of organic products easier between organic production under different
standards.

BB, US: [policy and procedure]. Which ones??

ICS, US: Clarification is needed as to what kinds of standards are eligible for
consideration in the first place. For example, can an individual certification body
have its own private standard considered?

For a standard to be considered as part of the Family there should be absolutely no
exceptions to requiring complete compliance with the new IBS. It has come to our
attention that current policies related to the OGS do not assure this. It would be
unacceptable to us if exceptions are allowed, especially because of but not limited to
the reasons we state below.

Policies for making any related decisions to regarding the congruence between any
standard and the IBS must be revised to be relevant to the new IBS – using any
policies that were crafted based on the old IFOAM Basic Standards are not
necessarily valid and must be duly reviewed and revised accordingly.

It is absolutely critical that the process of recognizing any standard to be part of the
Family of Standards to be transparent and subject to a system of checks and
balances. Said system must be approved by the GA and mechanisms in place to
ensure ongoing monitoring by the GA.

                                                                                      4
We hereby request that IFOAM provide us with a complete set of policies that will be
used to assess any given standard against the new IBS and how said standard will
be admitted into the Family of Standards. (Naming and directing us to said policies
on the IFOAM website would suffice.)

Our concerns are especially critical when one considers that IFOAM accreditation
may be opened up to other accreditation bodies than the IOAS. If exceptions are
allowed to the IBS and admittance to the Family granted based on some accreditor‘s
determination, and different accreditors take different approaches and/or make
inconsistent determinations, the ―safety net‖ of checks and balances ends up having
unacceptable holes. In essence the Organic Guarantee System will end up not being
a guarantee at all. We need assurance that there is a guarantee, otherwise our
IFOAM accreditation and our IFOAM membership will become relatively meaningless
and we may likely withdraw.

Without satisfactory address of the aforementioned concerns, we shall oppose the
new IBS revision to the fullest extent.

Component of IFOAM Accreditation
The IBS also function in the IFOAM Accreditation Program. This Program is a formal
means of verifying that the standards and accreditation requirements impremented
by an organic certification body meet the IBS requirements for organic standards and
also IFOAM‗s requirements related to the conformance of certification, which is
addressed in another document, the IFOAM Accreditation Criteria.
Changes according to ANSI.


Structure of the IFOAM Basic Standards

IBS Chapters
The IBS consists of 9 Chapters, which focus on certain topics in organic production
and processing. Sections within each Chapter further develop the topic of the
Chapter. Each of these sections is organized in a uniform structure, and contains the
following subsections:

Principles Applied
The Principles of Organic Agriculture relevant to the topic of the Section are stated. In
some cases the language is taken directly from IFOAM‘s Principles of Organic
Agriculture and in other cases the spirit and language of the Principles is adapted to
the topic.
BB, US:
in other cases the spirit and language of the Principles is adapted to the topic. And in
some cases the principles are ignored or the question is begged.
 „Principles Applied‟ are declarative statements of a single sentence where organic
agriculture is the subject.. Wenpeng: Please check this is not understandable.


Objectives




                                                                                   5
This subsection states the outcomes that must be achieved by organic farming and
processing with respect to the topic in order to be consistent with the IFOAM
Principles.
SA, UK: There seems to be a lack of clarity about the relationship between
objectives and requirements. This is a critical area. If the objectives MUST be
fulfilled (as stated here), then the requirements have to comply with and deliver all
aspects of the relevant objective. This is not the case at the moment: there are
glaring gaps and inconsistencies. If the objectives only SHOULD be fulfilled (as
stated in the introduction), then the objectives are of marginal importance for the
purpose of setting standards. If so, then the requirements on their own are woefully
inadequate. In either case, the document is fatally compromised.

BB, US: Objectives are normative or prescriptive statements of the intended
accomplishments of organic farmers, handlers, processors, and other actors in the
organic community.

Requirements for Organic Standards
This subsection presents those topics and requirements that organic standards must
address in order to fulfill the objectives. Specific requirements in organic standards
set by standards-setting bodies must not fall outside of the principles and must meet
the objectives.
BB, US: Requirements are directive statements that require action from the
standard-setting body.

Mandatory and Prohibited Practices
The role of the IBS includes setting a baseline for differentiating organic systems
from those that are not organic. In order to do this, it is necessary for the IBS to state
some practices that are always necessary in organic production and processing, and
others that are prohibited. Therefore, some Sections include relevant mandatory and
prohibited practices.
BB, US:
– ‗baseline‘ is highlighted ‗Minimal approach‘ This is NOT a benchmark.
– ‗In order to do this, it is necessary for the IBS to state some practices that are
   always necessary in organic production and processing, and others that are
   prohibited. Therefore, some Sections include relevant mandatory and prohibited
   practices.‘ is highlighted. This means that here nothing is required or prohibited,
   then the baseline is the same as conventional.
– Mandatory and Prohibited Practices are directive statematentes that usually
   address an organic operator. Mandatory Practices Prohibited Practices are
   directive statements that forbid specific actions, also usually by an organic.

IBS Criteria for Substances Used in Organic Production and Processing
BB US: Delete: „IBS Criteria for‟

The Principles of Organic Agriculture are designed to lead organic production and
processing toward minimal and prudent use of all substances. Therefore, organic
standards restrict the use of substances in organic production and processing. In
order to fulfill its role as a guidance and benchmark document, the IBS addresses
use of substances in general terms throughout the Chapters, and sometimes very
specifically in these Chapters by prohibiting certain substances. A comprehensive set
of Criteria for determining allowed and prohibited substances is provided in Section
C.

                                                                                     6
BB, US: What is in the proposed revision is not comprehensive. Either make them
comprehensive or remove the word.

SA, UK: It cannot be both guidance and benchmark.

OMRI, US/BB, US: Replace previous paragraph with: Organic production and
processing systems are based on the use of natural, biological, renewable, and
regenerative resources. The Principle of Health states that organic agriculture should
avoid the use of fertilizers, pesticides, animal drugs, and food additives that may
have adverse health effects. Therefore, most of these substances are prohibited in
organic agriculture. What few exceptions are made are based on the precautionary
principle. Organic agriculture also prevents significant risks by adopting appropriate
technologies. Criteria and Indicative Lists to be used to determine what substances
are allowed in organic production and processing are contained in Section C. These
lists are subject IFOAM‘s Policy 60 contained in the IFOAM Norms. Wenpeng:
Please check: Did both make this comment?

Organic standards setting bodies must use these Criteria to determine which
substances are allowed in their standard and they may also use the Criteria to
prohibit certain substances. Lists of substances in organic standards regulated within
the IFOAM Accreditation Program must meet the Criteria.
BB, US: Who determines whether standard setting bodies are competent? What is
the process they must use in order to evaluate and decide what is allowed and
prohibited? Where is it explained?

FAO, Italy: [as a guidance for organic standard-setting,] replaces [as a guidance for
organic standards setting,] Does this really belong here?

IFOAM maintains an indicative list of substances allowed for use in organic
production and processing. This list is subject to change via a transparent processes
administered by IFOAM. The list functions in IFOAM Accreditation and as a reference
for organic standards setting. Standards setting bodies may accept the listed
substances for their own standards without further evaluating them according to the
Criteria. A current list is available on the IFOAM website.
SA, UK: So why not include it here as a rightful part of the standard and be done with
it? Either this list is the definitive interpretation by the international organic authority,
or it is nothing and a question mark hangs over IFOAM as being that authority – see
Section C for further comments.

GCSAR, Syria: ‗via a transparent processes‘ should be" Via transparent processes
or Via a transparent process

BB, US:
 [This list is subject to change via a transparent processes administered by
  IFOAM] Where is this explained?
 [A current list is available on the IFOAM website‘ is highlighted]. What is the URL?
  I can‘t find it.

FAO, Italy: replace [as a guidance for organic standards setting,] with [as a guidance
for organic standard-setting,] Does this really belong here?

Development of the IFOAM for Standards

                                                                                       7
The IFOAM for Standards is developed in accordance with IFOAM policies and in
compliance with the ISEAL Code of Good Practice for Standards Setting.
BFA & ACO, Australia: Our other request is to see a guidance standard for
Cosmetics to be established asap. BFA and ACO utilize the food standard itself
which is highly restrictive but we have had clear feedback from our industry members
and the Cosmetics SubCommittee that they wish to keep this way, with limited
additional allowances of products. We note a developing plethora of certifier
standards for cosmetics in the world in the absence of a guidance document from
IFOAM.

FAO, Italy: [as a guidance for organic standard-setting,] replaces [as a guidance for
organic standards setting,] Does this really belong here?




                                                                                 8
Section B - Definitions, Principles Applied, Objectives and Requirements

Definitions

OFRC, China: For the definitions, it adds some new ones and deletes some existed
ones, such as buffer zone. I don't know if it means the deleted ones are those not
important now or known to every body so no need to explain.

Accreditation Criteria: Specify what is required from the certifier (what has to be in
place) and what the certifier has to require from the operator to enable third party
certification.
OPPAZ, Zambia: Specify wWhat-----

FAO, Italy: Requirements for the certifier and the operator to obtain third party
certification .

Additive: See Ingredient.
Fibl/BBV, Switzerland: ―Additive‖ is clearly defined in Codex.

Biodiversity: The variety of life forms and ecosystem types on Earth. Includes
genetic diversity (i.e. diversity within species), species diversity (i.e. the number and
variety of species) and ecosystem diversity (total number of ecosystem types).

Breeding: Selection of plants or animals to reproduce and / or to further develop
desired characteristics in succeeding generations.

Certification: The procedure by which a third party gives written assurance that a
clearly identified process has been methodically assessed, such that adequate
confidence is provided that specified products conform to specified requirements.
FAO, Italy: The procedure by which a third party gives written assurance that a
clearly identified process has been methodically assessed, such that adequate
confidence is provided that specified products conform to specified requirements.

ANSI, US: Replace with - See ISO/1EC 17000 - 5.5

Certification Body: The body that conducts certification, as distinct from standard-
setting and inspection.
FAO, Italy: What is the rationale for adopting a different definition than that of the
CODEX? This may lead to interpretation difficulties.

ANSI, US: Replace with - See ISO/IEC 17000 2.5


Contamination: Pollution of organic product or land; or contact with any material that
would render the product unsuitable for organic certification.
FAO, Italy: This definition is tautologic. It would be preferable to explain more in
detail what is considered ―pollution‖ of organic product or land (for example, contact
with harmful substances due to human activity).

FIBL/BBV, Switzerland: FiBL does not support this definition. A contamination,
which is not intentional, must not always lead to decertification. Causes must be
verified and actions taken against future contamination (HACCP).

                                                                                    9
Conventional: Conventional means any material, production or processing practice
that is not certified organic or organic ―in-conversion‖.
OPPAZ, Zambia: Conventional means any material (in exclusion of genetically
modified organisms), production or processing practice that is not certified organic or
organic ―in-conversion‖. This definition may also imply that genetically modified
materials are Conventional. To disqualify them it may be prudent to insert in (in
exclusion of genetically modified organisms)
JONA, Japan: IFOAM is promoting organic agriculture world-wide and this draft is
the framework for organic standards setting. Organic agriculture in this draft is aiming
not only for certified organic but also non-certified organic. Therefore, Conversion
Period in the Section B Definition must be corrected. ―the time between the start of
organic management and certification harvesting time of crops ----- as organic.‖
Certification must be deleted. This is the wrong place – It needs to go to the relevant
section in the Conversion chapter.

Conversion: The transition from non organic to organic farming.
FAO, Italy: The transition from non-organic to organic farming.

Conversion Period: The time between the start of the organic management and the
certification of crops and/or animal husbandry as organic.
FAO; Italy: The time between the start of the organic management and when the
certification of crops and/or animal husbandry as organic becomes possible.

Crop Rotation: The practice of alternating the species or families of annual and/or
biennial crops grown on a specific field in a planned pattern or sequence so as to
break weed, pest and disease cycles and to maintain or improve soil fertility and
organic matter content.

Direct Source Organism: The specific plant, animal, or microbe that produces a
given input or ingredient, or that gives rise to a secondary or indirect organism that
produces an input or ingredient.

Disinfect: To reduce, by physical or chemical means, the number of potentially
harmful microorganisms in the environment, to a level that does not compromise food
safety or suitability.

Farm Holding: The total area of land under control of one farmer or collective of
farmers, and including all the farming activities or enterprises. The farm holding may
be divided into farm units.

Farm Unit: A sub set of a farm holding.

Good Organic Manufacturing Practice: The part of the quality assurance which
ensures that organic products are consistently produced and controlled to the quality
standards appropriate to their intended use.
FAO, Italy: This definition is not clear and the term is only used once in the
document. It may be advisable to delete the definition and clarify the point directly at
7.1.1.

Genetic Engineering: Genetic engineering is a set of techniques from molecular
biology (such as recombinant DNA) by which the genetic material of plants, animals,

                                                                                 10
microorganisms, cells and other biological units may be altered in ways or with
results that could not be obtained by methods of natural mating and reproduction or
natural recombination. Techniques of genetic modification include, but are not limited
to: recombinant DNA, cell fusion, micro and macro injection, encapsulation, gene
deletion and doubling. Geneticallyengineered organisms do not include organisms
resulting from techniques such as conjugation, transduction and natural hybridization.
JR-UoM, US add: and somatic cell nuclear transfer (animal cloning)

FAO, Italy: The definition of the CODEX seems clearer than the one suggested:
“techniques in which the genetic material has been altered in a way that does not
occur naturally by mating and/or natural recombination.”

Fibl/BBV, Switzerland: Note: Cell fusion or protoplast-fusion is allowed, when
crossbreeding is possible with natural methods

Genetically Modified Organism (GMO): A plant, animal, or microbe that is
transformed by genetic engineering.

BB, US: GMO derivative: A product obtained directly or one step removed from a
GMO.

Fibl/BBV, Switzerland: To be verified.

Green Manure: A crop that is incorporated into the soil for the purpose of soil
improvement. May include spontaneous crops, plants or weeds.
GCSAR, Syria: It may include spontaneous crops, plants or weeds.

Fibl/BBV, Switzerland: /BBV: The definition is too narrow Better: A crop that is
grown and incorporated into the soil for the purpose of soil improvement and/or
prevention of erosion, prevention of nutrient-leakage, mobilization and accumulation
of plant-nutrients, balancing soil organic matter. May include spontaneous crops,
plants or weeds.

Habitat: The area over which a plant or animal species naturally exists; the area
where a species occurs. Also used to indicate types of habitat, e.g. seashore,
riverbank, woodland, grassland.

Homeopathic Treatment: Treatment of disease based on administration of
remedies prepared through successive dilutions of a substance that in larger
amounts produces symptoms in healthy subjects similar to those of the disease itself.

Hydroponics: Crop production systems in inert media or water using dissociated
nutrients as prime source of nutrient supply.

Ingredient: Any substance, including an additive, used in the manufacture or
preparation of a product and present in the final product although possibly in a
modified form.

Ionizing Radiation: High energy emissions from radio-nucleotides, capable of
altering a food‘s molecular structure for the purpose of controlling microbial
contaminants, pathogens, parasites and pests in food, preserving food or inhibiting
physiological processes such as sprouting or ripening.

                                                                               11
Label: Any written, printed or graphic representation that is present on a product,
accompanies the product, or is displayed near the product.

RLF; South Africa: Add Natural: Not artificial, not cultivated (while recognising that
people have modifed landscape and ecosystems over many thousands of years,
resilient ecosystems tend towards a climax state, where stable plant communities
develop which are well-adapted to soil, climate and slope. Any such stable
ecosystem can be said to be natural)
Nature is the creative and regulative power operating in the physical world.

Operator: An individual or business enterprise, responsible for ensuring that
production meets, and continues to meet, the requirements on which the certification
is based.
JOAN, Japan - Delete: ―on which the certification is based ―

Operation: An individual or business enterprise producing, processing or handling
agricultural products.

Organic: ―Organic‖ refers to the farming system and products described in the
IFOAM Basic Standards and not to ―organic chemistry‖.
RLF, South Africa - Change to ―Organic‖ is derived from a dynamic farm organism
(organised living system), and refers to the farming system and products described in
the IFOAM Basic Standards and not to ―organic chemistry‖.

FAO, Italy: Organic: Change to: A claim that refers to the farming system and
products described in the IFOAM Basic Standards and not to ―organic chemistry‖.

Organic Product: A product which has been produced, processed, and/or handled
in compliance with organic standards.
OTA, US:_ Delete ―and/or‖ so it doesn't imply that a product can be processed or
handled but not produced in compliance with organic standards. ―A product which
has been produced, processed and handled, as applicable, in accordance...‖ would
work.
That said, we note that in the U.S. National Organic Program, "processing" is one
possible component of "handling," which also includes selling, packaging, or
storing.JR-UoM, US: - Change to A production system that is managed to respond
to site-specific conditions by integrating cultural, biological, and mechanical practices
that foster cycling of resources, promote ecological balance, and conserve
biodiversity.

BB, US: Two definitions of ‗Organic‘ and ‗Organic Products‘ are highlighted. Circular,
not helpful. Membership will vote on a definition at the GA.

JONA, Japan: in the definition of Organic Product, it is mentioned ―a product ----- in
compliance with organic standards‖. This definition is good. It excludes ―certification‖.

Organic Quality: Product produced according to standards in compliance or
equivalent to the IFOAM for Standards.
FAO, Italy: Characteristic of a product produced according to standards in
compliance or equivalent to the IFOAM Benchmark for Standards.


                                                                                  12
Parallel Production: Any production where the same operation is growing, breeding,
handling or processing the same products in both a certified organic system and a
non-certified or non-organic system. A situation with ―organic‖ and ―in conversion‖
production of the same product is also parallel production.
GCSAR; Syria - Change 1st sentence to: Any production where the same operation
is applied: growing, breeding, handling or processing for the same products in both a
certified organic system and a non-certified or non-organic system.

JOAN, Japan: In the definition of parallel production, it must be corrected to ― in both
a certified organic system and a non-certified conversion or non organic system.

ICS, US: Parallel Production – Change 1st sentence to: Any production where the
same operation is growing, breeding, handling or processing visually
indistinguishable products in both a certified organic system and a non-certified or
non-organic system.

OIA, Argentina: Parallel production was clearly defined in terms of requirements in
the IBS from 2005. Now in the actual draft it is to open.

Primary Ecosystem: Primary ecosystem or habitat: Pristine and anthropogenously
undisturbed ecosystems/habitats.
RLF, South Africa: Primary Ecosystem: Primary ecosystem or habitat: Pristine
cosystems/habitats undisturbed by people.

GCSAR, Syria: Habitat: Primary ecosystem                  or   habitat:   Pristine        and
anthropogenously undisturbed ecosystems/habitats.

FAO, Italy: Primary Ecosystem: Pristine and anthropogenously undisturbed
ecosystems/habitats.

Processing: The operation of slaughtering, preparation, preserving and packaging of
agricultural products and also modifications made to the labeling concerning the
presentation of the organic production method.
RLF, South Africa: Processing: The operation of slaughtering, preparing,
preserving and/or packaging of agricultural products.

Fibl/BBV, Switzerland: The definition ―Processing‖ should be defined more
generally, the term is not reserved for ―Organic‖

Processing Aid: Any substance or material, not including apparatus or utensils, and
not consumed as a food ingredient by itself, intentionally used in the processing of
raw materials, products or its ingredients, to fulfill a certain technical purpose during
treatment or processing and which may result in the non-intentional, but unavoidable
presence of residues or derivatives in the final product.
RLF, South Africa: Processing Aid: Any substance or material, not including
apparatus or utensils, and not consumed as a food ingredient by itself, intentionally
used in the processing of raw materials, products or their ingredients, to fulfill a
certain technical purpose during treatment or processing and which may result in the
unavoidable presence of residues or derivatives in the final product.

BB, US. ‗products‘ is highlighted. Prohibited substances and practices are mentioned
in the text but it is never explained what it jeans

                                                                                     13
ICS, US: Processing Aid: Any substance or material, not including apparatus or
utensils, and not consumed as a food ingredient by itself, intentionally used in the
processing of raw materials, products or its ingredients, to fulfill a certain technical
purpose during treatment or processing and which does not remain in the final
product either as itself or a derivate of it.

Fibl/BBV, Switzerland: : Imprecise definition of processing aid, not the same as in
Codex Alimentarius.

Sanitize: To adequately treat produce or food-contact surfaces by a process that is
effective in destroying or substantially reducing the numbers of vegetative cells of
microorganisms of public health concern, and other undesirable microorganisms, but
without adversely affecting the product or its safety for the consumer.

Split Production: Conventional, in conversion and/or organic production, breeding,
handling or processing in the same operation.
TLF, South Africa: Split Production: Simultaneous conventional, in conversion
and/or organic production, breeding, handling or processing in the same operation.

Synthetic: Manufactured by chemical and industrial processes. May include
products not found in nature, or simulation of products from natural sources (but not
extracted from natural raw materials).
KRAV, Sweden: in a way that results in (significant) modifications of the chemical
composition.

OTA, US:_ This is much too vague—anything cooked in a factory would be
considered synthetic according to this. Even the NOP definition is giving problems,
and nobody has yet come up with a meaningful definition of ―natural.‖ In any event, it
would be acceptable to substitute the NOP definition: ―A substance that is formulated
or manufactured by a chemical process or by a process that chemically changes a
substance extracted from naturally occurring plant, animal, or mineral sources,
except that such term shall not apply to substances created by naturally occurring
biological processes.‖ Maybe even add to the ―except that‖ clause: ―or by
transforming agricultural ingredients through normal processing methods.‖

"Synthetic" should be defined as being limited to various specific classes of
substances so that tools, machines, baskets, trucks, etc. are not included. In
handling, the prohibition of synthetics unless listed should be limited to processing
aids and ingredients as opposed to tools, cookware, tableware, packaging, etc. An
example of good regulatory language for this is ―any substance intended for use as a
component of materials used in manufacturing, packing, packaging, transporting, or
holding food if such use is not intended to have any technical effect in such food.‖

To address the cooking issue, consider in the ―except that‖ clause, "...excluding the
processing of a final product, including cooking."

For a definition of "natural," perhaps "non-manufactured" would be appropriate.

ICS, US: Synthetic: Resulting from a chemical reaction that is not biologically
induced. May include products not found in nature, or simulation of products from
natural sources (but not extracted from natural raw materials).

                                                                                  14
Fibl/BBV, Switzerland: : Definition of synthetic is incorrect and not is precise
enough.

Standards: Specify how a product should be grown and processed to be regarded
as organic.
OPPAZ, Zambia: Specify h How-----

RLF, South Africa: Standards: Specify how a product should be grown and
processed

RLF, South Africa: Sustainable: Able to continue in the long term without failing.

JONA, Japan: In the definition of Standards‖ it says simply as organic but not says
as certified organic. This is good for this IBS.

Fibl/BBV, Switzerland: : The definition ―Standards‖ should be defined more
generally, the term is not reserved for ―Organic‖

ANSI, US: Add - See ISO Guide 2 and WTO TBT agreement principles




                                                                                   15
1. Organic Ecosystems

WWF: Overall comment: compliance with applicable legislation - WWF's suggestion is to
include implementation of all legal requirements as a baseline requirement for all growers
whatever their location or size. Relevant legislation could include regulations governing
land tenure and land-use rights, labour, agricultural practices, environment. It could also
include any relevant international laws or conventions (such as the Convention on
Biodiversity).

Fibl/BBV, Switzerland: : This chapter is very general and could better reflect modern
views of ecosystem management.

1.1.   Ecosystem Management and Biodiversity


Principles applied
Organic agriculture is based on living ecological systems and cycles. Organic Agriculture
should attain ecological balance through the design of farming systems, establishment of
interconnected habitats and maintenance of biodiversity. EPOPA, Uganda: Organic
Agriculture should attain ecological balance through the design and implementation of
farming systems…
Q: Is a zero external input farming system possible?

BB, US:
– ‗should‘ is Recommendeation, not a principle.
– Move the sentence: Organic Agriculture should attain ecological balance through the
  design of farming systems, establishment of interconnected habitats and maintenance
  of biodiversity.

Fibl/BBV, Switzerland: : Recommendations in current standard should be included
again: A farm should place appropriate areas under its management in wildlife refuge
habitat. These include:
a. extensive grassland such as moorlands, reed land or dry land;
b. in general all areas which are not under rotation and are not heavily manured:
extensive pastures, meadows, extensive grasslands, extensive orchards, hedges,
hedgerows, edges between agriculture and forest land, groups of trees and/or bushes,
and forest and woodland;
c. ecologically rich fallow land or arable land;
d. ecologically diversified (extensive) field margins;
e. waterways, pools, springs, ditches, floodplains, wetlands, swamps and other water rich
reas which are not used for intensive agriculture or aquaculture production;
f. areas with ruderal flora;
g.wildlife corridors that provide linkages and connectivity to native habitat.

GROLINK: Organic agriculture is based on living ecological systems and cycles. Organic
Agriculture should attain productivity and ecological balance through the design of farming
systems, establishment of interconnected habitats and maintenance of biodiversity.

The objective is to ensure the long-term management of an organic holding. To respect,
maintain, improve and complete ecological cycles, while also encouraging biodiversity
and protecting the quality of the landscape. Organic agriculture deliberately maintains

                                                                                16
and enhances nature; enhances diversity in plants, animals, and micro-organisms.
Biodiversity increases the resilience of organic agriculture.
EPOPA: Define ‗nature‘ or use ‗natural systems‘

RLF, South Africa: „enhancing diversity‘ replaces ‗enhances diversity‘

BB, US: Inserted: „Organic Agriculture should attain ecological balance through the
design of farming systems, establishment of interconnected habitats and maintenance of
biodiversity.‟ as the second sentence.

PGPCS, Sri Lanka: [new expression]
The objective is to ensure the long-term, sustainable management of an organic
holding. To respect, maintain, improve and mature ecological cycles, while also
encouraging biodiversity and protecting the quality of the landscape. Organic agriculture
deliberately maintains and enhances nature; enhances diversity in plants, animals, and
micro-organisms. Biodiversity increases the resilience of organic agriculture by making it
more stable.

FAO, Italy:_[encouraging biodiversity] This should be rephrased: encouraging
biodiversity protection? And/or biodiversity sustainable use? Or rather say ―protecting
biodiversity‖?

GROLINK: The objective is to ensure the long-term management of an organic holding.
Also respect, maintain, improve and complete ecological services, biodiversity the quality
of the landscape. [Repetitious] Biodiversity increases the resilience of organic agriculture.


Standards must require that:
Unilever: (1) The distinction (or relation) between the two following principles is
somewhat unclear to us. Is this the distinction between on-farm and off-farm biodiversity?
1.1.1. Biodiversity is maintained, and enhanced on the farm. 1.1.4. Habitat and native
species be preserved and enhanced wherever possible.

RLF, South Africa: „Organic standards---’ replaces ‘Standards--’

BB, US: In general, these are passive and do not identify who is responsible for
what. The current IBS is much clearer as a place to start.

 1.1.1.     Biodiversity is maintained, and enhanced on the farm

KRAV, Sweden: ‗up to a certain level. ‘follows

EPOPA, Uganda: Biodiversity is maintained or enhanced on the farm
Note: Many small holder farms are already very biodiverse and it may be impossible to
enhance . At national levels a minimum may be needed as low diversity (compared to
national levels)has to be improved
WSDA, US: It may be unreasonable to require a farming system to ―enhance‖
biodiversity. Any system of farming will necessarily tend to decrease biodiversity when
compared to ―natural‖ conditions in place prior to or without the influence of man /
agriculture. A better requirement would be that biodiversity is respected and that
management of the operation provides for maintenance of biodiversity.
PGPCS, Sri Lanka: [3 new clauses]

                                                                                 17
 The farm be considered from a ‗landscape or watershed‘‖ perspective where the
  significant characteristics of proximity to the water source, drainage pathways, natural
  forest and other natural ecosystems (like the riparian zone, wetland etc) be critical to the
  design and management of the landscape.
 The biodiversity that is naturally found in that landscape be identified and conserved.
 That habitat be preserved or restored to its original status for much as it is possible by
  using species found in the closest natural forest to the farm.

Delete orginal 1.1.1

 1.1.2. Cultivation and/or husbandry actively promotes biological and agronomical
        diversity within the agricultural context.
 OPPAZ, Zambia: Agronomical diversity is a new concept in this document. It may need
 to be defined. Does it mean the multiplicity of agronomic practices (including say crop
 rotation, green manuring, etc) employed in an agricultural production system?

 EPOPA, Uganda: Cultivation and/or husbandry actively promotes biological and
 agronomical diversity within the agricultural context.
 Note: This is unclear – the word ‗agronomical‘ should be corrected to agrodiversity or
 crop diversity, or specify wild and managed on-farm diversity.

 PGPCS, Sri Lanka: [new expression] That the Cultivation and/or husbandry actively
 promotes biological and agronomical diversity within the agricultural context.

 GROLINK: Change to - Cultivation and/or husbandry supports biological and
 agronomical diversity within the agricultural context.

 1.1.3. The management system takes into account the surrounding environment
         including the natural landscape.
 EPOPA, Uganda: The management system takes into account the surrounding
 environment including the natural landscape.
 Note: Some members preferred to make the sentence end at environment and remove
 last clause.

 SACL, UK: What is SACL expected to take into account? Would need a specific
 standard to be able to inspect to this.
 SACL: taking into account can mean minimal this is not what we should aspire to.

 SA, UK: Shades ‗takes into account in yellow‘. Not sure what this means, or therefore,
 what it requires.

 PGPCS, Sri Lanka: Delete 1.1.3

 IOAS, US: "takes into account" is a rather vague term and does not necessarily
 require any action. For accreditation purposes further guidance would need to be
 developed.

 1.1.4. Habitat and native species be preserved and enhanced wherever possible.
 EPOPA, Uganda: Habitat and native species be preserved and enhanced wherever
 possible.
 Note: Clarify the intent of this statement: consider how this relates to pests


                                                                                  18
 JR-MoU & NODPA, US: Deleting‘wherever possible‘, but adding ‗If this is a
 requirement, then the phrase ―wherever possible‖ is totally inappropriate, and should be
 deleted.‘

 WFA, US: Native habitat and native species be preserved and enhanced wherever
 possible. (give examples of wildlife habitat, such as those listed in the 2005 IFOAM
 Standards, p. 14, ―extensive grasslands…hedgerows…woodlands…water rich
 areas…and wildlife corridors.‖

 BB, US: Deleting ‗wherever possible‘, ―whenever possible‘ is subjective

 PGPCS, Sri Lanka: Delete 1.1.4

 IOAS, US: The term "wherever possible" would need parameters to be set for
 accreditation purposes.

 GROLINK: Delete. This is a very strong statement, plants we see as weeds are also
 native species.

 1.1.5. Socially significant elements of the landscape such as historic features or sacred
         sites be preserved with the farming system.
 GROL:
 Delete ―with the farming system‖. Is it possible to preserve sites with a farming
 system?Add: Precautionary measures are taken to preserve the genetic integrity of
 varieties and traditional ecotypes in organic ecosystems and prevent contamination of
 organic products

Mandatory practices:

EPOPA, Uganda: Certifiers may have a problem if this is mandatory; but if
mandatory then knowledge and implementation are both essential.

 1.1.6. Identify measures to contribute to biodiversity on the farm.
 EPOPA, Uganda: Implement measures to contribute to biodiversity on the farm.

 SACL, UK: would like to see some outcome measures identified by IFOAM.

 BB, US: ‗The operator shall identify—‗ is added.

 GROL: Delete. If operators are requested to identify measures they have to have
 the knowledge about the biodiversity on the farm and how it is affected by farming.
 This is ongoing research in this area but there is very much which is still unknown
 and will take many years of research before concrete advice is there, therefor this
 standard is to difficult to enforce both for the operator and the certifier.

 Why is the word ―contribute‖ used? Above in the standards is used ―maintained‖,
 ―enhanced‖, ―promotes‖, ―takes into account‖, ―preserved‖. Further above is ―attain‖,
 ―respect‖, ―improve‖, ―encourage‖, ―protect‖ used. ‖. Are there reasons for the
 variety of wording? Probably this whole chapter will gain in clarity with less diversity
 of language even if it is about biodiversity!

Prohibited practices:

                                                                                  19
1.1.7. Clearing primary ecosystems.
EPOPA, Uganda: Clearing primary ecosystems.

BB, US: New expression: The operator shall not Clear primary ecosystems.
I‘ve included examples of how to structure practice standards using the subject and
directive approach. Each sentence should stand on its own. The practice standards
are unclear when the responsible party is not identified and the action specified is
not explicitly mandatory or prohibited. All practice standards should adopt a
consistent style.

PGPCS, Sri Lanka: [new expression] Clearing mature, natural ecosystems*. (THIS
STATEMENT DOES NOT TAKE INTO CONSIDERATION THAT IN MANY PARTS OF
THE WORLS WHAT EXISTS AS ‗MATURE FORESTS ARE ACTUALLY SECONDARY
FORESTS. THE CASE OF SRI LANKA IS IDEAL.

[Adding] 1.1.8 Clearing natural forests

IOAS, US: The IFOAM definition of primary ecosystem is extremely narrow -
pristine =original and unspoilt condition; anthropogenous = practices of humans,
such as cultivation or monoculture (OED). Restricting the term to "clearing" does
not include management practices which could be equally damaging e.g. draining
of wetland habitats; cropping of tundra, etc. When you add to this the qualification
of "pristine"- ie. without human intervention, there is very little left. For example
ancient moorland which may have been settled in the iron or bronzes ages would
be excluded as there has been intervention by humans albeit some thousands of
years ago. Ancient woodland would be similarly excluded. The problem lies largely
with the definition rather than the standard itself. The IOAS feels that the standard
as it is combined with the definition falls short of consumer expectations for organic
production.

1.1.8. Impinging upon (negatively impacting) designated protected areas.
EPOPA, Uganda: Negatively impacting designated protected areas.
Note: Very important clause, but may be too weak – very few eco-systems are truly
Pristine, so add in other qualifying eco-systems

WWF, Germany: On points 1.1.7 and 1.1.8: these are good and strong points.
However, "primary" and "designated" may be difficult to define. Thus, we would suggest
to replace "primary ecosystems" and "designated protected areas" with High
Conservation Value Areas (HCVA). All natural habitats possess some inherent
conservation values. These could include the presence of rare or endemic species,
sacred sites, or resources harvested by local residents. High Conservation Value Areas
are defined as natural habitats where these values are considered to be of outstanding
significance or critical importance according to www.hcvnetwork.org

JR-UoM, US: Who ―designates‖ the protected areas? This is quite vague for a
―prohibited‖ practice

WFA, US: Deleting 1.1.8 with the following replacements.
1.18 Cultivation setback and protection of native habitat next to water rich area is
less than 25 feet.
1.1.9 Impinging upon (negatively impacting) designated protected areas, and
protected species.

                                                                                20
 BB, US: New expression: The operator shall not negatively impact areas that are
 designated as protected by ???. Who designates and on what basis?

 ICS, US: [desinated] Needs definition or clarification as to who designates it and
 by what criteria.

 FAO, Italy: [new expression] Impinging upon (negatively impacting) designated
 protected areas and/or protected species.
 [add a new item] Destroying or degrading historic features or sacred sites.

1.2.   Resource Management

Fibl/BBV, Switzerland: : The focus of this chapter is too narrow, it does not include air. It
is not just an issue of more resource efficiency but to reduce the use of nonrenewable
resources. Why are no mandatory and prohibited practices mentioned

Principles applied
Organic agriculture is based on the sustainable use of resources.
BB, US: Change to: Organic agriculture uses resources sustainably.
Organic agriculture attains ecological balance through the design of locally adapted
farming systems.

The objective is to use materials and energy efficiently, in order to improve environmental
quality and to conserve resources.
BB, US: The objective is to attains ecological balance at a sustainable steady state
through the design of locally adapted farming systems that uses materials and energy
efficiently, improve environmental quality and to conserve resources.

GROLINK: The objective is to use materials and energy efficiently, to improve
productivity, conserve resources and minimize impact on environmental quality.

Standards must require that:
Fibl/BBV, Switzerland: : The exclusion of the use of fossile water needs to be discussed

 1.2.1. Crop production, livestock production, processing and handling systems shall
      reduce, reuse, or recycle residual materials.
 ICS, US: [ materials] The requirement should be revised to emphasize the concept
 of recycling of materials produced by the farm on the same farm.

 PGPCS, Sri Lanka: [new expression] Crop production, livestock production, processing
 and handling systems shall reduce, reuse, or recycle residual materials.

 IOAS, US: This standard no longer addresses the basic organic principle of
 returning crop and animal residues to the soil and would permit export of such
 residues off farm without restriction, provided they were used elsewhere.

 GROLINK: Management systems shall reduce, reuse, or recycle residual materials.




                                                                                  21
1.2.1 can be seen as very hard if implemented to the letter, shall reduce, shall reuse,
shall recycle….Paragraphs below are more possible to fulfill. The ―or‖ in the sentence
above would be better as an and/or.

1.2.2. Measures are employed to prevent land degradation, such as erosion and
       salinization.
SACL, UK: SACL would like to see measures identified

GCSAR, Syria: May be "salinity" is a better option?

WFA, US: Measures are employed to prevent land degradation, such as erosion,
establishment of invasive species, and salinization.

1.2.3. Water use does not excessively exploit and deplete available water resources.
SACL, UK: SACL needs guidance on what is excessive

CQC, China: Available water resources are not excessively exploit and deplete.

JR-UoM, US: Water use does not pollute or deplete available water resources. [Once
again, the word ―excessively‖ is subjective and open for wide interpretation, and should
be deleted.

BB, US: Water use does not pollute or deplete available water resources.

IOAS, US: The IOAS had hoped that such terms as "excessive" would have been
removed from any further revisions of the IBS as we have commented on this
repeatedly.The standard is vague as it does not require standard setters to set
measurable requirements.

WWF: our suggestion here is to remove the word "excessively" and in addition
include wording on efficient water management. Plans for water management,
appropriate to the scale of use, should be developed to optimise water usage and
reduce waste and ensure that the effects of water use on local water resources
(groundwater and surface water) are sustainable. This could entail for the grower to
demonstrate an efficient use of water, using the best available techniques and the
irrigation systems that are most adequate for the crop in question. Also to include
could be the obligation to calculate the water needs and establish a self-
assessment irrigation protocol with flow meters to determine water usage.

In addition, we suggest wording on the non-use of water from desalinisation areas, and
of water transfers, be included. Where there are conflicts for water, there is a demand to
bring water from other areas. Water transfers are unsustainable and increase the
ecological footprint of the receiving region. The use of water from desalinisation areas is
also doubtful due to the high energy requirements and impacts on the sea.

1.2.4. Measures are employed to prevent pollution, and otherwise preserve water
       quality.

WWF: in addition to this point, our suggestion is to include that water courses,
wetlands and swamps should be protected, including maintaining appropriate
riparian buffer zones along all bodies of water.


                                                                                22
 1.2.5. Measures are taken to maintain and improve the living soil.
 SACL, UK: SA needs guidance on what constitutes measures

IOAS, US: This does not clearly differentiate between organic and conventional
production -see note at 1.2.1. Conventional farmers feel that they also take measures
to maintain and improve the soil - by adding synthetic fertilisers. What is missing is
that there is no requirement to return residual materials which are the by-product of
crop production to the soil.
  WWF: In order to incorporate the issue of CO2 emissions, our suggestion here is to
  add a point 1.2.6: Better Management Practices are applied for continuous
  reduction of CO2 emissions in the production, processing, and handling.

Mandatory practices
None specified
NASAA, Australia: A cycle of improvement in all areas

Prohibited practices
None specified
OPPAZ, Zambia: None specified. The use of environmental degrading practices.
WFA, US: None specified Water use dries up a natural waterway, pool, spring, wetland,
swamp or other water rich area.
Gray water containing sediments or other pollutants is leaching into natural water rich
area.

NASAA, Australia: Burning annual crop residue

1.3.   Collection of Wild Products

Fibl/BBV, Switzerland: : the exclusion of the use of fossile water needs to be discussed

Principles applied
Organic management sustains and prevents degradation of natural biotic and abiotic
resources.

The objective is ensure that the habitats, biodiversity, air quality, waterways and visual
appearance of wild collection areas are protected and benefit from the organic
management system; and that the wild collection system fits within the natural cycles and
ecological balance of the area.
SACL, UK:
 Should there be a mention of sustainable harvesting in the objective.
 CITES should be referenced, as should a requirement to meet local and national
   legislation

RLF; South Africa: ‗The objectives are to‘ is used to replace ‗The objective is ensure‘

GROLINK: The objective is to ensure that the habitats, biodiversity, air quality, waterways
and visual appearance of wild collection areas are not degraded; and that the wild
collection system fits within the natural cycles and ecological balance of the area.

Probably very hard for the habitats, biodiversity etc get any benefit from the wild
collection. In the IFOAM Principles the meaning of the sentence is different


                                                                                  23
Standards must require that:
PGPCS, Sri Lanka. [Add] 1.3.1 The Operator fully understands the ecology of the plant
that he is harvesting in order that he does not jeapordise the plant‘s capacity to survive
and self perpetuate. For instance the pollinator of the plant must be known and the
interrelationship between the plant be understood.

 1.3.1. Operators are thoroughly familiar with the boundaries of the collection area,
        which is free from prohibited inputs.
 SACL, UK: SACL: a boundary should be considered e.g. 10 metres from non-organic
 farming

 SA, UK: ‗free from‘ what does it mean and for how long - stored there or what?

 Biokontroll, Hungary: Operators are thoroughly familiar with the boundaries of the
 collection area, which has been free from prohibited inputs for a certain period set by the
 standards.

 KRAV, Sweden: Operators are thoroughly familiar with the boundaries of the collection
 area, with no use of inputs which are prohibited in IBS .
 Reason: free from is a use of words that normally should be avoided, better to refer to
 ―no use‖ or contaminated with.

 Fibl/BBV, Switzerland: : What means free from prohibited inputs, even if resulting from
 environment pollution? This cannot be guaranteed! Current text should be included: The
 people who harvest, gather, or wildcraft shall not take any products at a rate that
 exceeds the sustainable yield of the ecosystem, or threaten the existence of plant,
 fungal or animal species, including those not directly exploited.

 GROLINK: Operators are thoroughly familiar with of the collection area,
 ―Free from prohibited inputs‖ – do you mean that any traces of a pesticide or other
 contaminant would make the area not possible to use. Another problem is that in this
 draft the appendices are taken out and there is no definition on prohibited inputs. A third
 problem is language, free from prohibited inputs is directing to the boundaries and not to
 the area.
 1.3.2. Products are collected only from within the boundaries of the clearly defined wild
         collection area.
 1.3.3. The collection area is not compromised by pollutants.
 SACL, UK: SACL: would need to know what is a ‗compromise‘. This is very difficult
 to inspect without guidelines.

 SA, UK: ‗comprised by‘. what does this mean? Very woolly and therefore
 uninspectable.

 FAO, Italy: [compromised by pollutant] This should be rephrased: see comments
 on definition of ―contamination‖ above.

 GROLINK: The collection area is not subject to any activity in contradiction to set
 organic standards.
 Isn‘t this the same as in 1.3.1? What does it mean?

 1.3.4. The habitat stability and biodiversity of the collection area is not endangered.

                                                                                 24
 SA, UK: ‗not endangered‘. Very weak – just ‗not endangered‘ is nowhere near sufficient
 (eg it still could be degraded).
 The 2005 IBS was weak enough – this is much weaker and more or less meaningless.

 RLF, South Africa: Add - 1.3.5 Local conservation laws are respected.

 Agrior, Israel: Very important statement missing – one that limits harvest to a rate
 that at any case cannot exceed sustainable yield of ecosystem. See 2.4.1 of IBS
 (2005).

Mandatory practices
None specified
KRAV, Sweden: None specified. The licensee must follow the provisions of CITES for
species included in their register. (CITES; The Convention on International Trade in
Endangered Species of Wild Flora and Fauna) (www.cites.org).

NASAA, Australia: Add - Annual documentation of boundaries and production

Prohibited Practices
None specified
OPPAZ, Zambia : None specified. The use of practices with potential to irreversibly alter
the ecological balance of area.

BB, US: None specified.The use of substances that do not appear on Appendix C, Table
1 in the collection area. Conflicts with 1.3.4. No prohibited practices or substances should
be applied in the producted

NASAA, Australia: Add - Use of substances not appearing in annex xxx

FAO, Italy: None specified collection protected species?

2. Genetically Modified Organisms
BB, US: Why is this a stand-alone chapter? Combine with organic ecosystems.

Principles applied
Immunity, resilience and regeneration are key characteristics of organic production.
Fibl/BBV, Switzerland: : In the context of GMO this need explanation.
Practitioners of organic agriculture can enhance efficiency and increase productivity,
but this should be in a precautionary manner without risk to human health and well-
being or that of the environment. Given the incomplete understanding of ecosystems
and agriculture, care must be taken. Organic agriculture should prevent significant
risks by adopting appropriate technologies and rejecting unpredictable ones, such as
genetic engineering

JR-UoM, US: add: ‗and animal cloning.‘.

BB,US: New expression: Organic agriculture rejects genetic engineering as an
unpredictable technology.
See the principle of care.

FAO, Italy, Change 2nd sentence: Given the incomplete understanding of
ecosystems and agriculture, practitioners of organic agriculture can enhance

                                                                                 25
efficiency and increase productivity, but this should be in a precautionary manner
without risk to human health and well-being or that of the environment.

Fibl/BBV, Switzerland: - Add: Nature takes care that no arbitrary exchange of DNA
happens. Organic farming respects this principle.

GROLINK: Health and well-being are key considerations of organic management.
Efficiency and productivity should be enhanced without risk to human health and well-
being or that of the environment.
Organic agriculture should not introduce unnecessary risks and reject unpredictable
technologies, such as genetic engineering.

The objective is to prevent contamination of organic ecosystems and organic products
with genetically modified organisms (GMO) or GMO derivates and to preserve the genetic
integrity of varieties and traditional ecotypes.

GROLINK: The objective is to prohibit use of with genetically modified organisms (GMO)
or GMO derivates, preserve the genetic integrity of varieties and traditional ecotypes in
organic ecosystems and prevent contamination of organic products.

Standards must require that
 2.1. The deliberate use of genetically modified organisms (GMO) or their derivatives is
       prohibited in all stages of organic production and processing.
Biokontroll, Hungary: if deliberate is not deleted: deliberate or negligent

SACL, UK: SACL: Accidental contamination is also extremely important or GMO
product may enter the organic market if someone claims it was an accident.

SA, UK:
       If the objective is to prevent contamination, which is the most likely source of
GMOs entering organic food and farming, there is nothing in the requirements about
it. This must be rectified, at least to the level of the 2005 IBS.
       ‗or negligent introduction‘ added

JR-UoM, US: Does this mean that the non-deliberate use and the presence of GMOs are
allowed?

KRAV, Sweden - Change to: The deliberate use or negligent introduction of genetically
modified organisms (GMO) or their derivatives is prohibited in all stages of organic
production and processing. Contamination by GMO will alter the organic status of the
operation and/or product.

ICS, US: [new] Measures are taken to monitor the potential of accidental GMO
contamination of organic products, so that substantial GMO content of traded organic
products does not occur.

IOAS, US: Accidental contamination is not regulated. Therefore products which are
heavily contaminated with gmos may find their way into the market place and be
legitimately labelled as organic. The standard which would permit CBs to exclude
gmos on the basis of accidental contamination (2005 - 2.3.6) is now missing and
therefore surely not meeting consumer expectation of organic products..


                                                                                  26
Fibl/BBV, Switzerland: : replace ―Deliberate‖ with ―The use of‖. replace ―Derivates‖
with ―Material‖

Grolink: This is covering a large amount of substances which are not possible for an
organic producer to control, not only seeds, inputs etc but also products which might but
don‘t have to be from GMO origin, enzymes in washing detergents is an example, animal
medications and especially vaccines is another example.

The word ―derivatives‖ is not defined, therefor it is unclear what will be included in a
derivative, will manure from a cloned (GMO) animal be included? Will manure from an
animal which has been feed with GMO soybean?

Mandatory practices
 2.2. Inputs processing agents and ingredients are traced back at least one step in the
        biological chain to the direct source organism from which they are produced.
 SACL, UK: need to insist in the standards that a declaration be sought stating that an
 input is non-GM

 SA, UK: Mandatory for all inputs, even those not at risk? This gives no indication as to
 why this is required, nor what to do having done so.

 JR-MoU & NODPA, US: Inputs, agricultural products, processing agents, and
 ingredients are traced back at least one step in the biological chain to the direct source
 organism from which they are produced to assure that no genetically engineered
 organisms are used in organic production or processing.

 KRAV, Sweden: 2.2 Inputs processing aids (reason: agents is not defined) and
 ingredients are traced back for possible GMOs at least one step in the biological chain
 to the direct source organism from which they are produced.

 Fibl/BBV, Switzerland: : The terminology is not consistent. The term trace back related
 to the use of ingredient is weaker than tracebility – this means that only the producer
 can be verified but not the lot. Was this the intention?

 Grolink: What is ―processing agents‖? It is not defined, below in 2.4 the terms used are
 additives and processing aids, probably that is what is intended.

Prohibited practices
 2.3. The use of GMOs and GMO derivatives or products containing a GMO or GMO
       derivative (organic production).
 GCSAR, Syria: The use of GMOs and GMO derivatives or products containing a GMO
 or GMO derivative (organic production).

 LOS Germany: In 2.3. there is a prohibition of the "use of GMOs and GMO
 derivatives or products containing a GMO or GMO derivative". And there is a
 bracket: "(organic production)". Taking into consideration the detailed and very
 complicated discussion in the US and in the EU about the depth of the exclusion of
 genetic engineering in processes, which lead to organic products, I find it hard to
 understand this draft proposal. What kind of "derivatives" are meant? Those
 substances, produced "with", "from" or "by" or finally "the help with" a GMO? What
 kind of "use" is meant: May fuel produced from GM rape seed be used in organic
 production in the engines of the harvesting machine? Or not? It is important to

                                                                                 27
clearly and precisely delineate, where the exclusion of GMO from production
processes, which lead to an organic product, starts and where it ends. The draft
does not serve this purpose.

KRAV, Sweden: ‗with exception of veterinary medicinal products‖. follows Reason: The
task of finding out if a veterinary medicinal product is produced with GMO is increasingly
difficult and the time needed for decision may compromise animal welfare, and the
exception is limited to medicinal products derived from GMO from contained production.

BB, US: Vague.

IOAS, US: How is this different to 2.1? The IOAS are concerned that neither 2.3 or
2.4 adequately address "cloning" or other genetic engineering of animals.

GROLINK: Delete (organic production). ―Organic production‖? Below ―processed
products‖ Again the same problem as above with derivative (also for 2.4).

2.4.   The use of ingredients, additives or processing aids that are GMOs or are derived
       from GMOs (processed products). The use of GMOs, GMO derivatives or
       products containing a GMO or GMO derivative in any non-organic production
       activity on a farm holding with split (including parallel) production.
OTA, US: First of all, it appears that there should have been a new section number for
the second sentence under 2nd section. We object to this as a necessary prohibition on
the grounds that it would render the NOP non-compliant. It also does not make sense if
one considers that many split farms are likely to have their organic and conventional
fields widely separated geographically. We suggest changing it to a mandatory practice
that split operations that use GMOs as or on conventional crops, as well as organic
operations whose fields border conventional operations, must take appropriate
measures to prevent contamination of organic fields with GMO material.
This section also needs to recognize that livestock vaccines are perhaps universally
produced through GMO technology. This is of course an entirely separate issue from
crop production, but nonetheless needs to be recognized and treated appropriately by
allowing GMO medicines.

SACL, UK: need to add in the statement that product where GM is detected above
the limit of detection (currently) 0.1%, the product is automatically decertified.

LOS Germany: In 2.4., which looks at how organic products are processed, the
use of "ingredients, additives or processing aids that are GMOs or GMO
derivatives" is prohibited. What does that mean? Is the use of an GMO derivative
as a processing aid to produce a synthetic food acid, which is added to organic
product, prohibited? The answer determines, whether the EU organic food
practices meets the IFOAM Benchmark or not. The draft does not reflect an
understanding of the issues, which need regulation and clear guidance.

BB,US: 2.4 Contarddicts
Adding new item: 2.5 Cloning of animals.

Fibl/BBV, Switzerland: : What about composts, plant protection, fertiliser,
conventional inputs? The processing aids and ingredients are not allowed, if the
organisms are GMO‘s What about exceptions for veterinarian vaccines etc.?


                                                                               28
 GROLINK: The use of GMOs, GMO derivatives or products containing a GMO or
 GMO derivative in any non-organic production activity on a farm holding with non-
 organic production.

3. General Requirements for Plant Production and Animal Husbandry

 SACL, UK: SACL: there seems to be a significant lack of guidance on a number of
 areas from 2005 norms
 1      Plant products from annual production shall only be considered organic when a
 conversion period of at least 12 months has elapsed prior to the start of the production
 cycle. In the case of perennials (excluding pastures and meadows) a period of at least
 18 months prior to harvest shall be required.
 2      There shall be at least a 12-month conversion period prior to pastures, meadows
 and products harvested therefrom, being considered organic.
 3      The conversion period may be extended by the standard-setting organization
 depending on conditions such as past use of the land, management capacity of the
 operator and environmental factors.
 4      Where conversion periods exceeding those stated in 4.2.1 are required, and
 labeling of product as ―produce of organic agriculture in the process of conversion‖ or a
 similar description is permitted, the standards requirements shall have been met for at
 least 12 months prior to such labeling.

 This would create significant equivalence issues for SACL and create a lot more
 additional requirements in the MLA.

Agrior, Israel:
 The IBS must define:
 - Minimal time span for conversion of fields and perennial plants.
 - Minimal time span to elapse from last application of prohibited materials- to harvest of
 organic crop.
 - Defined need for submission of production system to inspection, during conversion.
 - Defined terms for optional approval of plots for Organic cultivation, without/with
 reduced than a minimum – time of "formal" (e.g – submitted to formal inspection system)
 conversion
 - Minimal time span for converting animals (of all kind covered by standards), with
 specification for types, and management systems.
 - Minimal requirements for animals to enter conversion process (age, annual addition
 rate to certified herds etc).

ARGENCERT, Argentina:
Part 3.1 Conversion requirements. Point 3.3 Conversion of Animal Production Systems.
Animal conversion is particularly complicated and what the standards must require is not
sufficiently defined (e.g. an animal in transition enters an organic field; how to determine
when it will become fully organic?)

3.1. Conversion Requirements
OFRC, China: This draft is significantly changed and simplified than those in 2001 and
2003. For example, it deleted the basic requirements of conversion period for crop
production and animal husbandry. It seems giving more space for rugulation or
certification standards, but it may cause confusion of conversion period in different
standards. I didn't find the appendix for the materials allowed using in organic growing


                                                                                  29
and processing too. The aim of organic production and processing can't be seen in this
draft, which I think is very important for organic movement.

OIA, Argentina: No clear starting moment for the conversion period, neither a time
frame, is to open or vague.

Fibl/BBV, Switzerland: : The text is very general and does not fully express the
process of the conversion. Labelling of in conversion products is not mentioned.

Principles applied
Organic agriculture attains ecological balance through the design and management
of sustainable farming systems.
PGPCS, Sri Lanka: Change ‗balance‘ to ‗maturity‘. The word balance is misleading
since it can mean many things to different people. The concept of Ecological Maturity
can easily be correlated to shade, biomass, and biodiversity.

GROLINK: Add ―productivity and‖ after ―attains‖

The objective is to clearly identify when organic practices begin and how long they
must be applied before the operation and products can be considered organic, taking
into consideration the balance of the ecosystem and the skills of the operator.
RLF, South Africa: ‗identify clearly‘ replaces ‗clearly identify‘.

OCA, US: Can be ascertained by measuring the extent to which soil fertility has been
improved and contaminants have been reduced.

Standards must require that:
  3.1.1. A specified date or event is identified as the point at which conversion begins.
IOAS, US: Permits retroactive conversion. However 3.2.1 requires an improvement
of soil fertility during the conversion period. The IOAS would need to develop
guidance on this for accreditation purposes.

 3.1.2. A set period of time is defined that must elapse between the start of conversion,
        i.e. when organic management begins, and the achievement of the organic status
        of the corresponding landand products.
 JR-UoM, US & SOFA, Sweden: ‗, animals‘ added

 BB, US: ‗Thirty seconds is a set period of time. Is this sufficient? Who is to decide
 what period of time is long enough?

 WSDA, US: No set period of time is established – could be one day and you are
 organic. Should set minimum standards of 3 years prior to harvest for crops, from last
 third of gestation for livestock.

 IOAS, US: Previously organic management was defined as full application of these
 standards and required evidence to support this. The standard has now become
 vague and IOAS guidance will need to be developed for accreditation purposes

 GROLINK: Land? What about the animals? Are products addressing crops and
 animals?

 3.1.3. The date at which a product may be considered as organic is clearly identified.

                                                                                 30
 SACL, UK: SACL: From 2005 norms - There shall be a period of organic
 management, meeting all the requirements of these standards, before the resulting
 product may be considered as organic.

 SA, UK: So the conversion period could be specified as one week, or even as one day.
 This is not acceptable. This must state a minimum period even if it‘s only 12 months.

 ICS, US: [new] The operator must be subject to surveillance by the certification body for
 at least one production cycle prior to the one in which production will first be certified.
 Without this type of surveillance, more specific minimum conversion period lengths
 must be set, to adequately assess whether or not the standard in question could be
 accepted into the IFOAM family if standards. Sample alternative language below at
 3.2.1 and 3.3.2.

 PGPCS, Sri Lanka: [add] 3.1.4 A set of índicator‘ species in terms of either soil, surface
 or aquatic biopdiversity be used to signal the maturity of the farmland ecosystem under
 conversion.

 GROLINK:
  Delete 3.1.3. Reason: 3.1.1 and 3.1.2 covers this.
  Add: Conversion requirements shall take into account site environmental factors,
   past use and the degradation of the agro ecosystem

Mandatory practices
None specified
JR-MoU & NODPA, US. Records must be maintained to verify compliance with
conversion requirements.

SOFA, Sweden: None specified practices Organic management must be fulfilled
during the conversion period!

KRAV, Sweden: None specified All requirements of IBS are met during conversion.

BB, US: What? Does this mean that one can farm conventionally during the
conversion period?

NASAA, Australia: A period of at least one year in conversion.

WSDA, US: Documented adherence to organic standards for a set period of time
prior to certification.

GROLINK: Add - Compliance to relevant parts of this standard during the conversion
period.
No mandatory practices? Doesn‘t the standard have to be fulfilled during the
conversion period?

Prohibited practices
 3.1.4. The use of prohibited practices and substances during conversion.
 SOFA, Sweden: ??? Of course prohibited practices are prohibited – but what is
 ―prohibited‖?

 BB, US: Where are these defined? See comments in Chapter 4 and Section C.

                                                                                 31
 GROLINK:
  Delete current 3.1.4. It sounds very strange that under the heading Prohibited
   practices mention the use of prohibited practices. This only gives a circle
   reference.
  Please define prohibited practices.

3.2. Conversion of Plant Production Systems
LOS Germany: Conversion of plant production systems (3.2.): There is no minimum
time requirement for the conversion for plant production systems. There is conversion
period of at least one life circle of the organisms or of one year, which ever is shorter.
Where? Only in the rules on the conversion of organic aquaculture (3.4.3.), but no
minimum requirement for plant production systems! Further: The standards must
require, that the length of the conversion period is sufficient for improving soil fertility
and reestablishing ecosystem balance (3.2.1). The language used here for the "hard"
part of the benchmark is surprisingly weak. The text means practically nothing. It is of
no practicable relevance. The new Benchmark for conversion of plant production
systems would require a standard to point out, that activities to enhance soil fertility
must have been undertaken, for example some mulching, and that the production
system meets the overall organic requirements. In this way it would be
unproblematic, to convert a conventional banana plantation in four weeks into an
organic production. I think such benchmarking violates, what most IFOAM members
would consider vital principles of organic griculture.

BB,US: Organic crop production aims to attainfits natural, site specific cycles.
ecological balance.

Fibl/BBV, Switzerland: : The conversion of planproduction is far too generaand
focuses on the non-use oprohibited materials. This doenot allow to make
aequivalency judgement, aeverything is left open. Thicould mean Zero conversion. Iis
extremely difficult tcommunicate to consumerthat IFOAM does practicallnot have a
conversion period


Principle applied
Organic crop production aims to attain ecological balance.
BB, US: New expression. Organic crop production fits natural, site specific cycles.

PGPCS, Sri Lanka. Change ‗balance‘ to ‗stability‘.

Grolink: Organic crop production aims to attain productivity and ecological balance.

The objective is to ensure that a suitable conversion period is set during which
contaminants are reduced, and through organic management healthy soils and
sustainable ecosystems are established.
SA, UK: This is too arbitrary and subjective to base standards on.

WSDA, US: Minimum three year conversion (two years prior to planting or three
years prior to harvest) and one-year monitoring period.

PGPCA, Sri Lanka: Delete ‗healthy soils and‘


                                                                                     32
GROLINK: The objective is to ensure that a suitable conversion period is set during
which a credible organic management systems is established.

Standards must require that:
PGPCS, Sri Lanka: [add] 3.2.1 The operator understands the ecosystem characteristics
of the land under conversion in order that the landscape design adopted facilitates the
restoration of habitat recreation, nutrient cycling, re carge of aquifers for example.

 3.2.1. The length of the conversion period is sufficient for improving soil fertility and
        reestablishing ecosystem balance.

 COG: Restoring ecological balance may be a life-long project not something that can be
 achieved in a few months or years – it depends on the starting point. Is the expectation
 that conversion goes on for as long as it takes? And surely some kind of minimum time
 will be expected by consumers.

 BioKontroll, Hungary: Specific minimum conversion period should be set for annual
 and perennial crops.

 SOFA: How should this be estimated and used in an objective way ? Different
 conversionperiods for different farms? We recommend a more clear stanard - that the
 conversion period will be kept to one year.

 KRAV, Sweden:
 Take away 3.2.1. Take away!
 Reason: There is a need for a time to elapse since prohibited substances were applied
 according to 3.2.3, to diminish risks of rest-substances and to protect the consumers
 from them. However, when that requirement is fulfilled and a farmer has started with
 organic practice it is only good that the products can be sold as organic. Soil fertility is
 improving for a long time, but there is no ―general base-line‖ for soil fertility that is
 meaningful to point out. In many places much too long time is needed before an soil
 fertility increase is measurable. It is thus hard to evaluate which time that is relevant.

 WSDA, US: Does not define ecosystem balance and therefore cannot be measured.

 ICS, US: [balance] Need to specify a minimum conversion period to be able to
 adequately assess whether or not the standard in question could be accepted into
 the IFOAM family if standards. See comment at proposed new section 3.1.4 above.

 PGPCS, Sri Lanka: changes ‗balance‘ to ‗maturity‘

 IOAS, US: With regard to improving soil fertility this can be done within a number of
 weeks; to re-establish ecosystem balance would likely take several years, if ever.
 Therefore the two requirements are incompatible and can, and probably will, lead to
 widespread abuse. The IOAS would have no option but to develop guidance for
 accreditation periods to regulate this in line with organic principles and, possibly,
 consumer expectations.
 Fibl/BBV, Switzerland: : The way it 3.2.1. formulated inot feasible. In general in
 moscases it needs 2-10 years untisoil fertility is fully build upThis needs at least on
 fulrotation. It would have beebetter to remain with one yeaas a minimum.



                                                                                   33
 Old text was better: Plant products from annual production shall only be considered
 organic when a conversion period of at least 12 months has elapsed prior to the
 start of the production cycle. In the case of perennials (excluding pastures and
 meadows) a period of at least 18 months prior to harvest shall be required. There
 shall be at least a 12month conversion period prior to pastures, meadows and
 products harvested therefrom, being considered organic. The conversion period
 may be extended by the standard-setting organization depending on conditions
 such as past use of the land, management capacity of the operator and
 environmental factors.

 GROLINK: Change to - The length of the conversion period is sufficient for
 establishment of a credible organic management system
 The proposal above sounds good but is very difficult to handle. Politically thinking, it is
 alright to recommend the minimum 12-month conversion time for plants as ―one
 production cycle‖. This is in line with aquaculture standards.

 3.2.2. The date at which a harvested crop may be considered as organic is clearly
        defined. Annual and perennial crops need to be handled separately.
 RLF, South Africa: ‗--specified separately‘ replaces ‗handled separately‘.

 SOFA, Sweden: Do not understand the meaning.

 KRAV, Sweden: Followed with ‗, but only as regards the need for an annual crop to
 meet the IBS requirements at least from sowing. ‘

 IOAS, US: Except for the requirement that annual and perennial crops need to be
 handled separately (whatever that means), this is already addressed at 3.1.3. Non
 harvestedcrops such as grassland are addressed by 3.1.2.

 GROLINK:
  Delete 1st sentence. The date is already covered above in 3.1.3
  Delete 2nd sentence. What does this mean? It is not allowed to say it is the same
   conversion time for all crops, or it has to be discussed separately, or it has to be
   different?

 3.2.3. The length of time that must elapse between the application of a prohibited
        substance or practice and being able to achieve organic status is clearly defined.
 SA, UK: Not acceptable - see comment after 3.1.3.

 KRAV, Sweden: Followed with ‗defined and at least 12 months. Reason: a
 minimum time is required.‘

 BB, US: Again, it only requires that the time be stated. A minimum of a day or a
 week would meet the requirement.

 PGPCS, Sri Lanka: [add] Soil and water conservation be practiced as a primary
 step. Delete ‗None specified‘

Mandatory practices
None specified
JR, MoU, US. Records must be maintained to verify compliance with conversion
requirements.

                                                                                   34
SOFA, Sweden: None specified All requirements of IBS are met during conversion.

KRAV, Sweden: None specified All requirements of IBS are met during conversion.

BB, US: Again, nothing is required?

NASAA, Australia: At least one year must elapse in conversion

WSDA, US: Minimum three year conversion and one year monitoring period.

PGPCS, Sri Lanka: Soil and water conservation be practiced as a primary step.
Delete None specified.

Fibl/BBV, Switzerland: : To be added: Mandatory practices: The products produced
under conversion can be labelled as : ―under organic conversion‖

GROLINK: Add - Compliance to relevant parts of this standard during the conversion
period. Same comment as under mandatory practices in 3.1

Prohibited practices
 3.2.4. The use of prohibited practices and substances during conversion.
 SOFA, Sweden: See similair comment above, 3.1!

 KRAV, Sweden: 3.2.5 To go ―In and out‖ in conversion on the same land.
 Reason: It is not trustworthy if to treat organic land conventional and than go into a
 new conversion to organic

 BB, US: Where are these defined?

 GROLINK: Delete. Same comment as under mandatory practices in 3.1

3.3.   Conversion of Animal Production Systems

Fibl/BBV, Switzerland: The conversion of animal production is far too general and
focuses on the non-use of prohibited materials. This does not allow to make an
equivalency judgement, as everything is left open.

Principles applied
Organic animal husbandry aims at attaining a balanced farm ecosystem while
ensuring the health and well-being of individual animals.
PGPCS, Sri Lanka: ‗enhancing the sustainability of a‘ replaces of ‗attaining a
balanced‘

The objective is to ensure that organic production practices are applied to the entire
life cycle of the animals with no routine breaks in the organic management.
RLF, South Africa: Deleting ‗the‘ in ‗in the organic management‘

ICS, US: The objective is to ensure that organic production practices are applied to
the entire life cycle of the animals with no breaks in organic management. Stating
no routine breaks in organic management implies that some breaks may be allowed.


                                                                                 35
Fibl/BBV, Switzerland: : What means no routine breaks in organic management?

Standards must require that:
 3.3.1. Animals are raised organically from birth, or from early ages subject to a
        conversion requirement.

 SACL, UK: SACL: animals raised for meat production must be born on an organic farm

 SA, UK: ‗from early ages‘ is shaded in yellow. This contradicts the objective

 SOFA, Sweden: Wouldn‘t it be better to split this one in two standards. The main
 standard is that animals are raised organically from birth and next step is that they are
 converted, preferably from early age but also older animals are brought in to many
 organic herds for different reasons.

 BB, US: ‗early age‘ is highlighted. Define?

 OIA, Argentina: Animals managed organically from early age, it is not clear the
 starting point.

 IOAS, US: It is highly subjective as to what an "early age" might be. The IOAS
 would need to develop guidance on this issue for accreditation purposes.

 Fibl/BBV, Switzerland: : What means ―or from early ages‖. There was a clear
 requirement that animal for meat have to come from organic holdings, with the
 exceptions of poultry. The old text was better: Where existing animals on a farm are
 converted to organic they shall undergo a one-time minimum conversion period at
 least according to the following schedule:
 Production Conversion period
 meat: 12 months
 dairy: 90 days
 eggs: 42 days

 When organic livestock is not available conventional animals may be brought in
 according to the following age limits:
 a. 2 day old chickens for meat production;
 b. 18 week old hens for egg production;
 c. 2 weeks for any other poultry;
 d. piglets up to 6 weeks and after weaning;
 e. dairy calves up to 4 weeks old that have received colostrum and are fed a diet
 consisting mainly of full milk.
 the adult animals of the same species on the farm.

 Where standards allow for exceptions of more than 10% these shall be limited to:
 a. unforeseen severe natural or man-made events;
 b. considerable enlargement of the farm;
 c. establishment of a new type of animal production on the farm;
 d. holdings with less than 10 animals.

 GROLINK:
   Change: Animals are preferably raised organically from birth,
   Add - Brought in non-organic animals are subject to a conversion requirement.

                                                                                 36
Wouldn‘t it be better to split this one in two standards. The main standard is that animals
are raised organically from birth and next step is that they are converted, preferably from
early age but also older animals are brought in to many organic herds for different
reasons.

3.3.2. Conversion periods appropriate for each species and production type are clearly
       defined.
SACL, UK: SACL: appropriate conversion period needs to be defined for each species
and the type of management involved e.g. nine months organic vet management,
feeding to organic standards for a set period of time.

SA, UK: This contradicts the objective.

RSTWG; Sweden: Animals are raised organically from birth, or from early ages subject
to a conversion requirement except animals which may be brought in only for breeding
purposes.
The RSTWG finds it needed that there is a possibility to buy in older animals for
breeding purposes, this is also included in the EAOPS 6.1.2.

BioKontroll, Hungary: Minimum conversion periods should be set.

KRAV, Sweden: Minimum requirements for different animals/production are needed, or
some sort of principle which excludes to short conversion periods. As long as we lack
that principle ee suggest: 12 months for slaughter. 6 months for dairy, 6 weeks for egg

BB, US: Conventional today, organic tomorrow is OK?

ICS, US: [definition] Need to specify a minimum conversion period to be able to
adequately assess whether or not the standard in question could be accepted into
the IFOAM family if standards. See comment at proposed new section 3.1.4 above.

IOAS, US: This standard does not fit well with 3.3.1 which states that animals
should be raised organically or from an "early" age. Now this standard seems to
imply that if they are not raised organically from an early age, they may be
converted. And even if the contradiction between 3.3.2 and 3.3.1 were not there,
what is the benchmark for what might be an "appropriate" conversion period? The
IOAS will need to develop guidelines on this for accreditation purposes.

GROLINK: Change to - Conversion periods appropriate for each species, purpose and
production type are clearly defined

3.3.3. The conditions for simultaneous conversion of land and animals are clearly
       defined.
GROLINK: Delete. Take out this one, this is more confusing then helpful.

3.3.4. There is a conversion period for the entire operation, including land.
IOAS, US: Prohibits permanent split production. While this is an admirable aim, it
may not be a realistic option where there is an undeveloped or unknown market
situation or where organic agriculture is in early stages of development. This is new
content as previously such a requirement was a general principle.

GROLINK: Delete. This doesn‘t fit under animals – take out.

                                                                               37
 3.3.5. In apiculture the conversion period of a bee colony is based on the time
        necessary for the replacement of wax.
 Agrior, Israel: – Proposed text will enable practically to transfer whole colony from non-
 organic to organic management at once, and thus transfer bees from non organic to a
 productive organic system – without any conversion period .

 SOFA, Sweden: There must be: All requirements of IBS are met during conversion

 IOAS, US: Unlike 3.3.2 above, this is a standard for standards which clearly sets
 out the parameters of the conversion period while leaving it to the standard setter to
 develop the precise details.

 Grolink: Is it the wax which is converted or is it the bee colony? In many places
 there are no need to replace wax as there are no use of chemicals in beekeeping
 and few contamination sources,

Mandatory practices
None specified
JR-MoU & NODPA, US. Records must be maintained to verify compliance with
conversion requirements.

BB, US: What? So a conventional operation is not required to do anything during the
conversion period? At least cross-reference to chapter

NASAA, Australia: Conversion must permit a life cycle of any organism or colony
before completion.

WSDA, US: Organic management for slaughter stock from last third of gestation for
mammals, day old chicks for poultry.

Grolink: Same comment as under mandatory practices in 3.1

Prohibited practices
 3.3.6. Use of prohibited practices and substances during conversion.
 Agrior, Israel: IBS must prohibit switching between organic and conventional
 management.

 SOFA, Sweden. See similair comment above, 3.1.!

 BB, US: Where are these defined?

 NASAA, Australia: New 3.3.7 Conversion of conventional mammals

 WSDA, US: New item: Nonorganic feed during conversion.

 Grolink: Same comment as under mandatory practices in 3.1

3.4.   Conversion of Organic Aquaculture

Fibl/BBV, Switzerland: : This text should be verified with other standards
Include from IFOAM Norms 2005 again: Recommendation

                                                                                38
Production units should have an appropriate distance from contamination sources
and conventional aquaculture.

Principles applied
Organic aquaculture aims at attaining a balanced ecosystem that ensures the health
and well-being of individual animals.
BB, US: New expression. Organic aquaculture manages the aquatic environment in
a way that is based on ecological processes.

PGPCS, Sri Lanka: Change ‗balanced‘ to ‗sustainable aquatic‘

The objective is to convert aquacultural systems in a manner that takes into account
the diversity of the environment, species and production methods.
SA, UK: ‗takes into account‘ What does this mean? From a standards point of view,
nothing.
PGPCS, Sri Lanka: ‗aqua cultural‘ replaces ‗aquacultural‘

Grolink: The objective is to ensure a suitable organic management system that
takes into account the diversity of the environment, species and production methods.

Standards must require that:
 3.4.1. All relevant requirements of chapter 3, 4 and 5 are complied with.
 KRAV, Sweden: Move to mandatory practices, there is no reason why this should be a
 specific requirement only in conversion of organic aquaculture.

 BB, US:
    ‗Relevant‘ is highlighted. Spell out.
    Contradicts 3.4.1?

 IOAS, US: What is relevant will need to be determined by the IOAS for
 accreditation purposes.

 FAO, Italy: [chapter 3, 4 and 5] The reference is not clear.

 Grolink - Replace 3.4.1 with
 3.4.1.       Farmed species are preferably raised organically from birth
 3.4.2.       Brought in non-organic species are subject to a conversion requirement
 3.4.3.       Conversion periods appropriate for each species are clearly defined.
 If IFOAM wants to have a trustworthy aquaculture standard this has to be written out,
 not only referenced. We have added in some proposals from chapter 3. It is interesting
 with the difference between this where standards shall be fulfilled, for plants and
 animals the conversion is to not use prohibited practices and substances.

 3.4.2. Conversion requirements take into account environmental factors and the past
        use of the site with respect to waste, sediments, water quality and contamination
        sources.
 SA, UK: ‗takes into account‘ What does this mean? From a standards point of
 view, nothing.

 IOAS, US: Why is this restricted to aquaculture - past use of land with respect to
 waste and contamination sources would seem to be equally relevant. Therefore it


                                                                               39
 appears that aquaculture is being regulated in more details than agriculture. The
 comments made on "take into account" at 1.1.3 apply equally here.

 3.4.3. The conversion period of the production unit must be at least one life cycle of the
        farmed organism or one year, whichever is shorter.
 SA, UK: Agreed, but if a conversion period is specified for aquaculture, why not for
 anything else?

 KRAV, Sweden: In some cases it is more appropriate to relate to biomass increase
 than time. We suggest that 90% increase in biomass is an alternative option.

 PGPCS, Sri Lanka: [add] 3.4.5 That if exotic species are being farmed, care must be
 taken to prevent their entry in to natural water bodies. The case of alien invasive species
 is a critical problem.

 IOAS, US: Again the standards for aquaculture are more detailed than other types
 of organic production - there is no specific conversion period specified for plants
 and animals. The IOAS is not objecting to such specification here - rather that there
 is a lack of it elsewhere.

Mandatory practices
None specified
KRAV, Sweden: None specified All requirements of IBS are met during conversion.

NASAA, Australia: Conversion must ensure a lifecycle or any organism or cohort
before completion

Prohibited practices
None specified
JR-MoU & NODPA, US. Records must be maintained to verify compliance with
conversion requirements.

KRAV, Sweden: The use of prohibited practices and substances during conversion. None
specified.

BB, US: So unlike terrestrial production, nothing is prohibited for aquaculture?

NASAA, Australia: Use of any prohibited inputs or practices during conversion

PGPCS, Sri Lanka: [add] The destruction of natural, riparian vegetation if found in the
aquatic ecosystem. Delete ‗None specidfied‘.

FAO, Italy: [new clause] 3.4.4 Use of prohibited practices and substances during
conversion? None specified

3.5. Split Production and Parallel Production
CQC, China: We think the GMO prohibited practices should be repeated in this
section, or some confusion may be occurred.

Grolink: Instead of this chapter if would be better to have a general chapter which is
covering all primary production, plants, animals, aquaculture, wild collection, handling
the risk of mixing organic and conventional products in all steps of production. And

                                                                                   40
focus on the risks of mixing. As it is written now it only for farms and the objective is
to get the whole farm converted. The objective is also to guarantee the integrity; this
can be used as a general statement and not only for split farms.

SOFA, Sweden: We agree with the comment from Grolink:

Principles applied
Organic agriculture is managed in a precautionary and responsible manner.

The objective is conversion of the whole farm over time; and to guarantee the
integrity of the organic production and products on holdings with split or parallel
production.
RLF, South Africa: ‗The objectives are —‗ replaces ‗The objective is--‘. Deleting ‗the‘
from ‗of the organic production‘

Grolink: The objective is conversion of the whole operation over time; and to
guarantee the integrity of the organic production and products in operations with both
organic a non-organic production.


Standards must require that:
ICS, US: [Standards] There is no requirement that meets the stated objective, i.e.
conversion of the whole farm over time. We suggest creating a requirement to achieve
that.

  3.5.1. The integrity of the organic farm unit must not be compromised by the
         management of the conventional unit.
IOAS, US: This is presumably meant to cover such things as cleaning of equipment
but as there are no specifics at all, IOAS would need to develop guidance for
accreditation purposes.

Grolink: The integrity of the organic operation must not be compromised by the
management of the non-organic operation

 3.5.2. Holdings with split or parallel production ensure the conventional and organic
        parts and products are completely, clearly and continuously separated.

Fibl/BBV, Switzerland: The terminology is unclear:what means separation. What
means complete, clear, continuous separation? No criteria are given, e.g. same
varieties only when clearly distinguishable in colour and size.

Grolink: Change to - Operations shall ensure that non-organic and organic parts and
products are clearly separated in time or space.
Mandatory practices
  PGPCS, Sri Lanka: [add a clause] That phytoremediation technologies be applied in
  the possibility of contamination of water and soil.

  3.5.3. Prohibited inputs must be stored separately from those used for organic
         production.
SACL, UK: SACL: a prohibition as follows: You must not grow the same variety of
crops on your non-organic land as on your in-conversion or organic land


                                                                                    41
JR-MoU & NODPA, US: 3.5.4. Records must be maintained to verify that organic
products are not commingled with not-organic products or contaminated with
prohibited substances.

BB, US: ‗Prohibited inputs‘ is highlighted. Where defined or named?

Grolink: Change to - Inputs used for non-organic operations must be stored
separately from those used for organic operations.

Prohibited practices
None specified
JR-UoM, US:
Commingling organic and non-organic products.
Contamination of organic land, animals, and products with substances not allowed in
organic production and processing

NASAA, Australia: Storage or use of prohibited inputs on the organic farm

WSDA, US: Organic crops and products must not be commingled with non-organic
crops or products in handling or storage.

PGPCS, Sri Lanka: [add 2 new clauses]
   The use of agrochemicals in the area under conventional production be
    monitored closely in order to prevent their leaching in to the ground water
    table.

      If the production under review runs parallel to areas like natural forests from
       which the collection of wild products are undertaken, then care must be taken
       to maintain separate records on management, yields etc.

3.6. Maintenance of Organic Management
SOFA, Sweden: This chapter is superfluous if not given more substances!

Grolink: This chapter can be taken away or if kept moved together with other
standards, as it is now it is too little content to really make an own chapter.

Principles applied
Organic agriculture works with living ecological systems and cycles, while emulating
and sustaining them.
Grolink: Change to - Organic agriculture works with on-going living ecological
systems and cycles.
The objective is to maintain an ongoing organic system.

NASAA, Australia: The objective is to maintain a productive organic system as an
integrated one that endures through time and space.

Standards must require that:
 3.6.1. A production system does not rely upon switching between organic and
        conventional management.
 JR-UoM, US: An organic production system must not switch between organic and
 conventional management. [What does ―does not rely upon‖ mean? Does it mean that


                                                                                  42
 an operation can switch between organic and not-organic occasionally, but not every
 year?]

 BB, US: But you can do it as long as you don‘t ‗rely‘ on it. ;-)

 FAO, Italy: [new expression] A production system does not switch between organic and
 conventional management.

 Fibl/BBV, Switzerland: : Unclear, what does‖ rely‖ mean. Does this mean one time
 it is possible but not more than 2 or 3 times?

 Grolink: Change to -Management of organic production does not need to switch
 between organic and non-organic measures to maintain viability.

Mandatory practices
None specified
NASAA, Australia: Management practices must capable of sustainable operation on
the farm unit.

Prohibited practices
None specified
OPPAZ, Zambia : None specified. Organic Farm Units must always be kept
separate from prohibited practices and substance.
BB, US: Comment on Mandatory practices and prohibited practices. No difference
from conventional, so switching back & forth between two systems that are the same
is meaningless.

NASAA, Australia: Use of prohibited products within a management cycle that
includes an organic component.

3.7. Avoiding Contamination
LOS Germany: It is interesting to see, that contamination shall be avoided (3.7.).
This is an important and rarely addressed issue. "Contamination" is the ontamination
of organic products by ubiquitarian environmental pollution, or by point pollution, for
example by toxic waste incinerators or by nuclear power plants, but also the impact
of highways or the growing of products in arsenic soils. The standards must require,
that precautionary measures are taken to avoid contamination (3.7.1.) I think it is very
wise, to addressed the issue, but to use broad language to define a benchmark,
makes little sense, when it is clear, that the benchmark is not met.

There are very more points, which would require similar scrutiny, but let me finally
concentrate on a procedural aspect:

For the average IFOAM member or staff member of IFOAM, it is practically
impossible, to understand, which hidden, political issues are addressed in the draft.
Only when one approaches the draft analytically looking for those hidden issues, one
recognizes that the concept of conversion is practically dropped for plant production. I
think it would be fair to the IFOAM membership, to point out what kind of strategic
decisions of proposals are hidden in the draft proposal.




                                                                                 43
Fibl/BBV, Switzerland: : Again the text is very general and does not give guidance.
What happens when contamination does happen, does it mean decertification as in
the definition? What has to be undertaken against drift?

Principle applied
Organic agriculture is managed in a precautionary and responsible manner.

The objective is to ensure that organic production is conducted in a precautionary
manner that seeks to avoid contamination of the environment and the products it
produces.

Grolink: The objective is to ensure that organic production is conducted in a
precautionary manner that seeks to avoid contamination of the environment and
prevent contamination of the products it produces.

Standards must require that:
 3.7.1. Precautionary measures are taken to avoid contamination.
 SACL, UK: SACL: We cannot inspect and certify to ‗precautionary measures‘. We need
 more guidance on limits

 BB, US: new expression: Organic practices take measures to avoid contamination by
 prohibited substances.

 ICS, US: [contamination] Should include language about actually making some sort
 of risk assessment.

 IOAS, US: Has lost the risk assessment element. There may be no precautionary
 measures needed.

 Grolink: Precautionary measures are taken by operators to avoid contamination of
 the environment and prevent contamination.

 3.7.2. Where there is reasonable suspicion of contamination, the relevant products are
        analyzed and the source of the contamination sought.
 SACL, UK: SACL: what constitutes reasonable suspicion. Guidance needed.

 KRAV, Sweden: Contamination may alter the organic status of the operation and/or
 product

 ICS, US: [suspicion] What ―reasonable‖ means could be defined by requiring a
 risk assessment, as suggested above.

 IOAS, US: What constitutes "reasonable suspicion"? The IOAS will need to
 develop guidance for accreditation purposes.

 Grolink: By whom, e.g. farmers or CB?

 3.7.3. Restrictions are set on the use of synthetic coverings, mulches; taking into
        consideration the environmental impacts.
 RLF, South Africa: ‗coverings and mulches, taking into‘ takes place of ‗coverings,
 mulches; taking into‘.


                                                                               44
 KRAV, Sweden: Restrictions are set on the use of synthetic coverings, mulches,
 applied fertilizers, soil conditioners and pest control agents; taking into consideration the
 environmental impacts and possible content of heavy metals, medical residues,
 radioactive substances, poisonous substances and contagious substances.

 BB, US: And then do nothing about it???

 IOAS, US: An earlier draft of this benchmark standard defined environmental
 impact as avoidance of contamination from residue and litter. The IOAS will
 develop an interpretative document for accreditation purposes.

 Grolink:
  3.7.1 is very general and could be expanded to specify what is covered it is both
    in the production (land, inputs, contamination from neighbors, own conventional
    production, factories etc) and if it is also covers contamination in products
    product.
  3.7.3 Is very specific and can be made more general, is really covering and
    mulches the big, general problem in organic agriculture, why not cover all inputs
    use and all waste.

Mandatory practices
 3.7.4. All mulches and coverings must be biodegradable or recyclable.
 SACL, UK: SACL: Difficult to enforce for silage wrap etc, which contains a lot of
 material making it hard and costly to recycle

 JR-UoM, US: Buffer zones must be established to protect organic production units from
 contamination with prohibited substances used on adjoining conventional production
 units.

 COG, Canada: There are also inconsistencies where this new IBS is more
 prescriptive than the old. Eg 3.7.4 requiring that all mulches and coverings must be
 biodegradable or recyclable

 SOFA, Sweden: This is difficult and also too detailed compared to other parts of
 the IBS

 OMRI, US: Adding an new item: The operator shall take measures to prevent the
 contamination of organic crops, livestock, and food by substances that do not
 appear in Section C. BB, US:
  – Define
  – New item: 3.7.5 The operator shall take measures to prevent the
      contamination of organic crops, livestock, and food by substances that do not
      appear in Section C.

   ICS, US: [recyclable] Biodegradable‖ needs to be defined in the IBS, if this
   language is to be used in a way that meets the objective.

   IOAS, US: This is entirely new content and will effectively ban plastic tunnels in
   many parts of the world where recycling possibilities are limited. It also effectively
   bans use of horticultural black plastic (which most recycling operations won't
   handle because it is too dirty with soil and crop debris) although there are
   beginning to be biodegradable mulches on the market at least in Europe and

                                                                                   45
   possibly elsewhere. This standard alone would effectively bar access to IFOAM
   accreditation for most of the currently accredited certifiers and to bring in this
   standard as a "non negotiable" while admirable seems unrealistic and counter
   productive to accessibility. Protected cropping is necessary for the survival of
   many crop producers - as a mandatory practice, this is hugely more restrictive
   than the 2005 norms.

   Grolink: Replace with - Disposal arrangement for non-biodegradable or
   recyclable materials
   This is a very hard standard to fulfill, there are not so many recycling systems for
   plastic. Also this is much to detailed, why regulating this in this type of standard.

Prohibited practices
None specified
RSTWG; Sweden: None specified Use or handling of products or waste in manner or
methods that endanger human health or the environment
The RSTWG propose that the text in the EAOPS about contamination can form the base
for the IBS chapter on contamination. It is understood that the EAOPS is to detailed but
that the essence can be used, especially 4.2.1 which is both restricting the use of
dangerous chemicals in general and is requiring the use of the least harmful product.

BB, US:
   New item: The operator shall not commingle organic and non-organic products.
   This permits the commingling of organic and non-organic products, contamination
     by GMOs, contamination by pesticides, etc. Etc.

NASAA, Australia: Admission of contamination to the farm unit through lack of
precaution by the operator

WSDA, US: Any crop or product that comes into contact with a prohibited substance
or is in any way ―contaminated‖ by a prohibited substance may not be sold, labeled or
represented as ―organic.‖

4. Crop Production

4.1.   Seed and Propagation Material

Principle applied
Organic management sustains production at all crop stages.
OCA, US: Crops sold as organic…
• Do not contain GMOs.
• Were fertilized with organic compost and/or manure.
• Were protected from exposure to contaminants by buffer zones.

NOFA, US: Plant Production and Animal Husbandry: there is no definite time
requirement for the conversion to organic. For equivalency to be meaningful, the 3-
year requirement should be universal.
Crop Production, a mandatory practice might be – keep something growing as much
of the year as possible. The absence of any mandatory practices makes it sound like
any agricultural practice will suffice for organic agriculture.



                                                                                  46
The objective is to ensure that organic practices are implemented along the entire
production chain from propagation to final product including the production of seed
and propagation materials.
Agrior, Israel: The new IBS represents an approach that is taking the organic
movement few steps back with respect to Organic seeds: Instead of requiring the use
of organic seeds, and developing standardization or at least principles of plant
breeding for organic management, we surrender to the convenience of the "non
availability" excuse. The requirements for standards cannot provide for achieving the
objective in this issue.

Biokontroll, Hungary: Basically organic seed and propagation material is to be
used. The seed or propagation material is considered to be organic in the following
cases:

Standards must require that:
 4.1.1. When available, seed and plant propagation materialfor annual crops comes from
        plants that have been under organic management for at least one generation.
 JR-UoM, US: This standard must be accompanied by criteria for determination of when
 seeds and propagation materials for annual and perennial crops are not available from
 organic sources.

 RSTWG, Sweden: ‗and seedlings‘ is added

 BB, US: Highlighting ‗When available‘ How defined? Determined by whom?

 IOAS, US: This is not really a standard for standards as it could be reproduced in a
 CB standards as written. IOAS guidance will need to be developed for accreditation
 purposes on how to determine availability or the lack of it.

 NOFA, US: The statement that seed and plant propagation material must be
 organic ―when available‖ is open to many different interpretations. Who decides on
 availability? Is price a factor?

 Fibl/BBV, Switzerland: : No criteria are given how the availability is determined.
 Nothing is said about biodiversity. No exclusion or at least preference of certain
 breeding techniques. Nothing is said about thresholds of impurity regarding GMO‘s.
 Purity should be at detection limit.

 Current text is better: To promote and establish the use of organic seed and plant
 material, standard-setting organizations shall set appropriate standards and/or time
 limits for the selected use of non-organic seed and plant material. Where untreated
 conventional seeds and plant materials are not available, chemically treated seed and
 plant material may be used. The certification body shall establish time limits and
 conditions for exemptions that permit use of any chemically treated seeds and plant
 materials.

 4.1.2. When available, seed and plant propagation material for perennial crops comes
        from plants that have been raised organically for at least one year.
 Biokontroll, Hungary: Deleting ‗When available‘

 RSTWG, Sweden: ‗and seedlings‘ is added


                                                                               47
4.1.3. Treatment of seed and propagation material is restricted to substances listed on
       the standard setting body‘s list of permitted substances.
SACL, UK: SACL: Comments on treatments in Section C

RSTWG, Sweden: ‗plant propagation material and seedlings are‘ follows after
propagation material.

SA, UK: See comments under Section C.

SOFA, Sweden: Again we fully agree with the comment from Grolink: This is probably
an attempt to not allow any use of chemically treated seeds. That is not a way to
facilitate the growth of organic production world wide. There are still many places where
there is no access to untreated seeds. In some countries there is mandatory legislation
to treat seeds. Also in early stages of development organic agriculture the farmer have
no chance to influence the provider of seeds to have a supply of untreated seeds.

The standard might also be intended to mean that the standards setter can make a list
of chemical treatments which is allowed for seed treatements. This is not a solution
which will work well.

The best solution is to make a possibility to use treated seeds if no other solutions are
possible,

BB, US: What is the basis of this?

IOAS, US: New content: Use of chemically treated seeds as the final option when
organic and untreated are not available was the subject of a motion at the last GA.
In some parts of the world and in particular where legislation requires chemical
treatment, there is no other option. Therefore adding it back is more restrictive than
the 2005 norms. and is counter to the GA motion which carried.

ARGENCERT, Argentina:
Chapter 4. Crop Production, point 4.1.3 Non treated seeds should be made
mandatory. In case that conditions require not prohibition but a restriction, it must
be properly qualified in order to avoid discrepancies between standards.

Fibl/BBV, Switzerland: : Add to last sentence: and to mechanical, and physical
treatments.
Compulsory treatment by the authorities must be excluded

Grolink: This is probably an attempt to not allow any use of chemically treated seeds.
That is not a way to facilitate the growth of organic production world wide. There are still
many places where there is no access to untreated seeds. In some countries there is
mandatory legislation to treat seeds. Also in early stages of development organic
agriculture the farmer have no chance to influence the provider of seeds to have a
supply of untreated seeds.

The standard might also be intended to mean that the standards setter can make a list
of chemical treatments which is allowed for seed treatements. This is not a solution
which will work well.



                                                                                 48
 The best solution is to make a possibility to use chemically treated seeds if no other
 solutions are possible, please reuse current text in the IBS.

 4.1.4. Seedlings are from organic production.
 RSTWG, Sweden: Deleing Item 4.1.4 with the replacement of When seed, plant
 propagation material and seedlings from plants that have been raised organically are
 not available, treated seed, plant propagation material or seedlings are restricted to
 cases of demonstrated need. Such cases must be documented.
 The use of treated seeds when untreated seeds are not available is taken away from the
 IBS.
 The RSTWG are requesting to keep a possibility for the use of chemically treated seeds
 when untreated seeds are not available. All members of the RSTWG are of course in
 favour of the use of organic seeds, and if that is not available, of untreated seeds. The
 situation today in the countries of the East African Community (Burundi, Kenya,
 Rwanda, Tanzania and Uganda) has a lack of supply of untreated seeds for some crops
 as maize and several vegetables. In several (all?) of the countries represented in the
 RSTWG there are mandatory legislation for imported seeds. Therefore we urge the
 IFOAM SC to make it possible for the use of treated seeds when untreated seeds are
 not available.

 When untreated seeds are not available it could be a limiting factor to adoption of
 Organic agriculture. Through the proposed changes we provide for a demonstrated
 need which means that it can be verified that there is a cause for use of treated seeds. It
 takes care of any cases where operators could continue to use treated seeds when they
 could obtain untreated seeds ort produce them themselves.

 Biokontroll, Hungary: If there is no organic seed or propagation material available
 the standards-setting organization may grant authorizations for exceptions if non-
 availability is verified.

 PGPCS, Sri Lanka: [add a new clause] Open Pollinated seed be preferred.

 IOAS, US: This would seem redundant as plant propagation material i.e. seedlings
 are already covered in 4.1.1. There is also a contradiction - 4.1.1. states that
 seedlings must be organic where available; 4.1.4 says they must be organic full
 stop. If seedlings are not to be considered plant propagation material, then a
 detailed explanation of what both those terms do mean must be given.
 Transplanted seedlings are commonly considered to be plant propagation material.
 If seedlings are somehow shown to be different to plant propagation material, then
 this is both new content and a major change to the 2005 standard and is greatly
 more restrictive. It will inhibit the development of organic agriculture in many
 countries.

 Grolink: Why so strict on seedlings? In case of sprout production, this should be
 required to use organic seed

Mandatory practices
None specified
BB, US:
  – The operator shall use organically produced seed and plant propagation
      material when commercially available.
  – Contradicts 4.1.1.

                                                                                49
NASAA, Australia: Operators must look for organic seed and propagative material

WSDA, US: Use of organic seeds and planting stock to produce organic crops,
except when such organic seeds or planting stock are documented as unavailable.

Fibl/BBV, Switzerland: : Add:
      In order to promote the maintenance of local varieties, landraces and
agricultural biodiversity the use of non-organic seeds should be allowed if there are
no equivalent organic seeds available.
      Whenever possible the use of organically bred varieties should be enhanced
Prohibited practices
None specified
KRAV, Sweden: Seeds and plant propagation material treated with chemical
pesticides. The only exception is when the use of treated seeds is a legal
requirement.

BB, US: The operator shall not use any seed treatment that does not appear in Section C,
Table 2.

NASAA, Australia: Operators must not add substances to seed or seedlings that are not
contained in annex xxx

WSDA, US: Use of any seed or planting stock treated with a prohibited substance.

Fibl/BBV, Switzerland: : Add:
 Use of GMO varieties
 Use of treated seeds

4.2.   Soil Conservation and Crop Rotation

Unilever: Missing standards on: avoid salinization, acidification/alkalinisation and
decline of soil organic matter

OMRI, US: Conversion The proposed revision makes it impossible to know what
inputs are permitted and what inputs are prohibited under the Benchmark, with only a
few exceptions. Because the conversion standards are so vague, it is also not clear
what happens to an operation that applies a prohibited substance. Each section has
a prohibited practices clause. In the conversion section, in several times the
proposed IBS states that ―The use of prohibited practices and substance during
conversion.‖ However, there are three problems with this statement.
First, the sentence does not make sense on its own or even in the context of the
document. A prohibited practice should say who shall not do what. It is not clear who
shall not use what.
Second, prohibited substances are not clearly defined either in the standards or by
the criteria. The current IBS contains lists of substances acceptable as fertilizers and
soil conditioners; as crop protectants and growth regulators; and as additives and
processing aids. In addition, there are clear criteria for the addition of substances to
the Appendices. Those that do not appear in the Appendices are prohibited. The
proposal removes this structure and makes it entirely unclear which substances
prohibited.


                                                                                 50
Third is that conversion itself has no established period. A farm that applies a
pesticide that would be clearly prohibited under the current IBS might not be in
violation of the proposed IBS. Even if one were to establish that such a pesticide is
prohibited, the conversion requirement could mean ‗spray today, organic tomorrow.‘
In contrast with terrestrial farming systems, there are no prohibited practices in the
conversion of organic aquaculture, which implies that nothing is prohibited in organic
aquaculture. Without a baseline minimum period, there is nothing to prevent a trivial
conversion period in a standard. For maximum market access, the appropriate
minimum period is three years, because that is the period that would comply with
every major market.

WWF, Germany: On point 4.2: here, our suggestion is to include that soil suitability
for cultivation should be established to ensure the long-term suitability of land for
cultivation. Soil suitability maps or surveys should be appropriate to the scale of
operation and should include information on soil types, topography, rooting depth,
moisture availability, stoniness and fertility. This information can then be used to plan
rotations, planting programmes, etc.

Principle applied
Organic crop production sustains and enhances the health of the soil and ecosystem;
healthy soils produce healthy crops that foster the health of animals and people.

The objective is to practice crop rotation, soil management and suitable
conservation techniques that improve the health and condition of the soil and crops,
and avoids the use of fertilizers and pesticides.

RLF, South Africa: The objective is to practice crop rotation, soil and water
management and suitable conservation techniques that improve the health and
condition of the soil and crops, use water resources responsibly and avoid the use of
fertilizers and pesticides.

Grolink: The objective is to practice crop rotation, water as well as soil management
and conservation techniques to improve the health and condition of the soil and
crops, and avoid the excessive use of fertilizers and pesticides.

Standards must require that:
 4.2.1. A suitable crop rotation is included as an integral part of the management system
      of the holding.
 SACL, UK: SACL: Need guidance on suitable.

 SA, UK: A suitable crop rotation fulfilling the objective above is included as an integral
 part of the management system of the holding.

 JR-UoM, US: A soil-building crop rotation is included as an integral part of the
 management system of the holding. [Who determines what is ―suitable‖? It is much
 better to replace the term ―suitable‖ with ―soil-building‖, which can be measured
 objectively.

 SOFA, Sweden: Is crop rotaion also required for perennials?

 IOAS, US: This is new content. The 2005 norms are not so specific with regard to
 rotation -previously "rotation and/or variety of plantings". Again the vague

                                                                                   51
 terminology i.e. "suitable" will necessitate the IOAS to develop an interpretative
 document for accreditation purposes.

 Fibl/BBV, Switzerland: : The requirements forsoil conservation and crop rotation are
 too general and could also stand for a integrated production on a low level. What are the
 criteria to be applied, e.g. maintenance of humus content? What means appropriate? It
 might be appropriate for economic reasons to make monocultures. Nothing is said about
 biodiversity in crop production.
 Current text is better: For perennial crops, the certifying body shall set minimum
 standards for orchard/plantation floor cover and/or diversity or refuge plantings in the
 orchard.

 Grolink: What about perennials is a crop rotation required?

 4.2.2. Cover crops, plant-based ground cover are used where appropriate in the organic
        production system.
 JR-UoM, US: Who determines ―where appropriate‖? This subjective and vague phrase
 should be deleted. If this is to be a standard, it must be precise and objective.

 SA, UK: Cover crops, (SA, UK: ‗green manures and‘ added)

 ICS, US: Cover crops and/or plant-based ground cover are used in the organic
 production system. Cover crops/green manures are integral to organic systems
 everywhere.

 PGPCS, Sri Lanka: [add] Where the area is already under tree cover (crop trees), then
 no till could be promoted.

 IOAS, US: The comment is the same as at 4.2.2 but the term in question is "where
 appropriate".

 Grolink: Cover crops, plant-based ground cover are used where appropriate

 4.2.3. The management system includes means of conserving or improving soil fertility
        and structure.
 IOAS, US: This standard is extremely vague as it lacks any detail at all of what
 might be considered conservation or improvement of fertility and structure. The
 IOAS will need to develop some guidance on assessment of this issue.

 Grolink: This is already covered in 1.2.2 and 1.2.5, where do you want to keep it?

 4.2.4. The management system prevents erosion and depletion of soil nutrients.
 RLF, South Africa: 4.2.5 The management system uses water resources responsibly.

 WWF,: For this point, we suggest that mechanical cultivation should be used only
 where proven to improve or maintain soil structure, and to avoid soil compaction.

Mandatory practices
None specified
Biokontroll, Hungary: None specified. The inclusion of soil building crops such as
legumes or green manure crops in the crop rotation.


                                                                                 52
NASAA, Australia: Management practices must maintain and improve soil carbon
levels.

ICA, US: Green manure must be part of every soil building system.

Fibl/BBV, Switzerland: : Add - Humus content should be stable or enhanced.

Prohibited practices
None specified
Unilever: what about exporting nursery substrate from native forest (often done in
Africa and Asia), peat bogs or other sensitive natural areas?

SACL, UK: SACL: A prohibition on continuous arable rotations
BB, US: Comments on Manadatory practices and prohibited practice: Not different
from conventional ag.

NASAA, Australia: Failure to plan for, pre-empt and prevent soil erosion events.

ICS, US: Perennial systems must not have bare ground for more than 6 months out
of any given year.

PGPCS, Sri Lanka: [Add] Scraping of the top soil through the use of a hoe

Fibl/BBV, Switzerland: : Add - Slashing and burning?
4.3. Fertilization
Opdebeek, Switzerland: I would like to express my surprise that fertilizers based on
animal protein such as meatmeal, feathermeal, bloodmeal etc. are currently allowed
and apparently still would be allowed in future. They should be anchored in the
Benchmark as prohibited substances for the fundamental reasons as described
below.

Executive Summary
Organic farming is a holistic system based on the Principles of Health, Ecology,
Fairness and Care: the use of animal protein waste as a fertilizer does not fit in this
system and is in contradiction with any and all of these fundamental principles.
It is contrary to the natural nitrogen cycle, is unacceptable for consumers such as
vegetarians and other health conscious consumer groups, is a non-traditional
practice that puts at risk farmers, consumers and ultimately the organic farming
system itself, mostly originates from conventional sources and is not used as
intended as it does not even produce humus and is mostly chemically or high-energy-
input processed to enhance its properties artificially.
Animal protein used as fertilizer does not belong in organic farming
In the mind of many people there seems to exist confusion between soil-conditioner
type fertilizers such as compost and manure on one side and those nitrogen
fertilizers derived from animal protein.
Compost and manure are undigested plant-based excrements mixed with other plant
material (such as straw) and form the basic input of any sound and sustainable
organic farm.

Animal protein waste is something completely different.
 First it is important to note that the natural nitrogen cycle (and the food chain as
   well) goes in the sense of plant towards animal or in other words plants are fed

                                                                                53
    to animals and not vice-versa. (Trying to reverse this cycle is believed to have led
    already to Mad Cow (BSE) disease).
    Therefore already for this reason alone the use of animal protein as fertilizer does
    not have a place in organic farming where the respect of natural cycles is
    paramount (Principles of Health, Ecology and Care).
   Vegetarians, a consumer group with a philosophy and ideals close to that of the
    organic movement and enthusiastic consumers of organic produce are mostly not
    aware of this practice and, according to spot interviews including among family,
    friends and the general public, would strongly protest if they would learn that for
    example lettuces and other vegetables are being dusted with meat and other
    cadaver                   sourced                  waste                   products.

    Indeed when vegetarian associations, such as the Irish Vegetarian Society
    became aware of this practice they consequently discouraged consumption of
    organic                                                           produce.

    If this information would get spread widely among vegetarian consumers it could
    not only severely affect organic produce sales but would be seen as a direct
    breach of the Fairness Principle and, because of this manifest lack of
    transparency, a direct threat to the credibility of organic farming.
   Not only consumers but certainly farmers worldwide too should be protected
    against unhygienic practices.

    - For example feather meal.
    Since Avian Flu is principally transmitted thru the air, by far most of infections
    occur thru breathing. For that reason, besides vaccines, masks are currently
    being distributed in several countries worldwide (for example at this very moment
    the distribution of mouth masks to all citizens is being promoted by the Swiss
    government).
    We don‘t believe that farmers will be willing to wear masks when spreading
    feather meal (that is easily respirable) as fertilizer, by hand or with a mechanical
    spreader.
    In any case the Care (Precautionary) Principle should be applied in first instance
    to protect the principal stakeholder: the farmer, small or large, in any country of
    the world.

    - Another example: In some countries leather meal has been recently introduced
    as fertilizer: Again this is a practice contrary to good sense and tradition.
    Leather is known since centuries to be linked to the risk of Anthrax transmission
    to animals and humans, a disease indigenous in many countries such as India,
    South-America, Mexico and the US where still regular outbreaks in cattle occur.
    Traditional practices are encouraged in organic farming because they are linked
    to the Precautionary (Care) Principle i.e. what has endured the test of time
    should be preferred. Use of such animal protein waste as fertilizer has not
    endured the test of time; In the past, before the organic movement took root,
    farmers did not use dead animals as fertilizer; on the contrary, it is a recently
    introduced risky practice.

    - Last example: fishmeal. Some persistent contaminants are concentrated in
    every step of the food- chain. A typical example is PCBs.
    Fish, one of the last links in the maritime food chain is high in persistent
    contaminants such as PCBs.

                                                                                 54
    Concentrations are sometimes so high that it has been found that some organic
    farmed soils are higher in PCBs than conventional soils (a Swiss governmental
    study has pointed to this problem).
    Also OMRI (Organic Materials Review Institute, US) in last winter‘s edition of its
    journal pointed towards the risks of enriching the soil with PCBs when using
    fishmeal (Principle of Health).

   By far most of these animal protein wastes originate from animals that are not
    raised on organic farms but mostly on industrial-size conventional farms1. This is
    once again a practice contrary to Organic Farming rules as it would maintain
    indefinitely the farm in a state of transition between conventional and organic and
    again would not be appreciated by the consumer if he would be aware of this
    aspect as well (Principle of Health, Ecology and Fairness)
   The first goal of organic fertilizers is to produce a significant amount of humus.
    Animal protein has an iso-humic coefficient =0 or in other words animal protein
    waste does not produce humus whatsoever.

    This is one of the flagrant confusions that are being maintained in the mind of
    people: animal protein based fertilizer is seen as belonging in the same family as
    compost, manure and other plant waste. It does not: for all practical purposes it
    belongs, in this context at least, in the mineral fertilizer category.
   Animal protein is a fast acting nitrogen source particularly when hydrolysed.

    - Hydrolysing is a synthetic chemical process that does not exist in nature in the
    form that it is carried out when animal protein waste is processed into nitrogen
    fertilizer i.e. at high temperature(above 100°C, well above composting T), and/or
    use of strong acids. Synthetic fertilizers are not allowed and should of course not
    be allowed in organic farming.
    The sole argument that could be used in its favour is that it (still) contains carbon.
    Yet its C/N ratio is only a shadow of that of compost, manure and other plant
    wastes and is much closer to that of urea or in other words negligible. As already
    mentioned, in practice it is a (synthetically) mineralised quick acting fertilizer that
    does not stimulate soil life any more or any less than mineral nitrogen.
    Natural mineral fertilizers are allowed in organic farming under certain conditions
    but should be clearly distinguished from soil conditioner type fertilizers such as
    compost. The illusion should not be given to the farmer that he would directly
    maintain or even add humus in his soil thru this practice (He only would indirectly
    if he would, thru this practice, obtain higher yields and therefore more plant
    waste).
    Organic farming is a system based on sustainability and ultimately should be
    sustainable itself. It can only last in the long run when straightforward and
    transparent towards all stakeholders. Contorted loopholes will not contribute
    towards this goal.

    - Further the hydrolysing process is a high energy demanding endothermic
    process and therefore does not contribute to sustainability and preservation of
    energy sources. It is counter to the Principle of Ecology.

1
  Where state subsidies are lacking or are insufficient, the production of those kinds of fertilizers is in most
countries only economically (logistically) feasible if the raw materials are concentrated in a few large enterprises
close to the fertilizer plant. For example: almost all poultry feathermeal and meat/blood meal originates from
“conventional” industrial type farms.

                                                                                                           55
    As a sustainable system, maximizing recycling is one of the principal aims of
     organic farming (Principle of Ecology) yet recycling should not become an aim
     on itself. This non-holistic understanding of the system led to practices such as
     use as fertilizer of city waste-water purification plant slurries. This was quickly
     abandoned in most countries as this not only introduced all kind of harmful
     substances into the organic farming cycle and food chain but also seriously
     threatened the good image of organic produce.
     Animal protein wastes should instead be recycled as food for carnivores which
     is its natural and logical destiny and which is already successfully being
     applied in the pet food industry, organic and conventional.

Conclusion: Organic farming is a holistic system based on the Principles of Health,
Ecology, Fairness and Care: the use of animal protein as a fertilizer does not fit in
this system and is in contradiction with any and all of these fundamental principles.

Complexity is the signature for life. Let‘s not forge this signature for the sake of
wrongly perceived marketing benefits.

Agrior, Israel: Mandatory practice should be cropping, which is not detached from
native soil.

OMRI, US: Fertilization For soil fertility, only sodium (Chilean) nitrates and
hydroponics are prohibited. The prohibition on hydroponics directly contradicts the
aquaculture standards, which do not prohibit anything, not even hydroponics. Without
a list of permitted substances or clear criteria to determine what is permitted and
what is prohibited, the prohibition of only one fertilizer is totally inadequate.
The proposed criteria state that ‗[i]n execptional [sic] circumstances chemically
synthesized substances may be considered.‘ However, there is no guidance for what
is ‗exceptional‘ and no definition of who is considered competent to make that
judgment. The proposed IBS would open the door to all fertilizers other than sodium
nitrate.
For example, sodium nitrate is prohibited by both the current standard and the
proposed standards. The current standards also prohibit calcium nitrate. However, it
is not clear if the proposed standards would prohibit calcium nitrate. Many
agronomists and soil scientists say that it is less harmful to the environment than
sodium nitrate.

Principle applied
Organic crop production systems enrich the living soil, creating an environment that
can support the production of healthy, productive crops.

The objective is to practice a crop management system that seeks to nourish plants
primarily through the soil ecosystem, enhances the natural fertility of the soil and
avoids the excessive use of fertilizers.
KRAV, Sweden: The re-cycling of nutrients from feed or food back to fields shall be
promoted. This means that animal production preferable is integrated with plant
production, that farm yard manure is used efficiently and that clean rest-products
from food –production is permitted, as well as source separated human excrements
free of pathogens and pollutants.




                                                                                 56
NASAA, Australia: The objective is to practice a crop management system that
nourishes plants primarily through the soil ecosystem, naturally enhances the
fertility of the soil and avoids the unecessary use of fertilizers.

Standards must require that:
Fibl/BBV, Switzerland: : Again the wording is very general. This could also be
standards for integrated production on a low level. Nothing is said that synthetic
fertilisers are not allowed. Nothing is said that highly soluble fertilizers are avoided or
strongly restricted. What means contamination is avoided, e.g. when conventional pig
slurry with high copper content is used.

Current text is better: Nutrients should be used in such a way and at appropriate
times and places to optimize their effect.
Accumulation of heavy metals and other pollutants should be prevented. Manures
containing human excrement (feces and urine) are prohibited for use on crops for
human consumption. Exceptions may be made where detailed sanitation
requirements are established by the standard-setting organization to prevent the
transmission of pests, parasites and infectious agents and to ensure that manures
are not mixed with other household or industrial wastes that may contain prohibited
substances.
Mineral fertilizers shall be applied in the form in which they are naturally composed
and extracted and shall not be rendered more soluble by chemical treatment, other
than addition of water and mixing with other naturally occurring, permitted inputs.
Under exceptional circumstances, and after consideration of all relevant information,
and having regard to Appendix 1, the standard-setting organizations may grant
exception to this requirement. These exceptions shall not apply to mineral fertilizers
containing nitrogen.

 4.3.1. The management system maintains and enhances soil fertility.
 KRAV, Sweden: The management system maintains and enhances soil fertility to a
 reasonable level.

 PGPCS, Sri Lanka: [add] 4.3.2 The tendency twards tree crops is encouraged
 especially in the light of mitigating the impacts of climate change.

 IOAS, US: New content. Enhancing fertility is not always desirable - e.g. in species
 rich permanent pasture. Here, a "where appropriate" might have been expected
 and useful!

 4.3.2. The management system provides an environment for healthy growing plants
        that produce yields appropriate for the crop and region.
 IOAS, US: There is a wide variability of organic yields and this standard seems to
 imply that a farmer must achieve the norm for a particular region. This does not
 seem rooted in organic principles. It is difficult to see how this can be addressed
 and assessed in a CB's standards - when looking at accreditation conformity, it is
 impossible without the development of elaborate interpretative documents.

 4.3.3. Contamination of the environment is avoided.
 Grolink: Delete here and move to contaminiation chapter




                                                                                    57
4.3.4. The fertility program of a holding is based on the enhancement of the soil-
       ecosystem by the use of biodegradable material, green manure and nitrogen
       fixation from plants; and that mineral fertilizers are only used as a supplement.
JR-MoU & NODPA, US & BB, US: ‗compost and animal manure‘ is added;

OPPAZ, Zambia: Does mineral fertilizer also imply that some synthetic inorganic
substances, say Ammonium Nitrate or Urea in Zambia, are permitted so long as they
are being used as supplement?

4.3.5. The use of fertilizing agents must be site adapted and correspond to the need of
       the plants.
SACL, UK: SACL: difficult to inspect to and may create problems with additional
requirements in the MLA.

SA, UK: ‗be site adapted‘ and ‗correspond to the need of the plants‘ Neither of these is
clear – without a context or criteria, both are meaningless.

Biokontroll, Hungary: Adding an item: The positive list in the annex should be
maintained.

KRAV, Sweden: The fertility program of a holding is based on the enhancement of the
soil-ecosystem by the use of biodegradable material of microbial, plant or animal orgin,
green manure and nitrogen fixation from plants; and that natural occurring mineral
fertilizers are only used as a supplement.

NASAA, Australia: [New expression] The use of fertilizing agents must be site
adapted and correspond to the needs of the soil and plants .

IOAS, US: Would likely be impossible to assess on the accreditation level - at the
very least will require substantial interpretation by the IOAS.

FAO, Italy: ‗proportional‘ replaces ‗correspond‘

4.3.6. All substances used must be on the standards setting body‘s list of permitted
       substances.
SA, UK: ‗standards setting body‘s list of permitted substances‘ is shaded in yellow. See
comments under Section C.

KRAV, Sweden: There should be a link to animal husbandry and the use of animal
manure primarily from farming systems that comply with these standards. This does
not mean that each farm must have both animal and crop production. Different
forms of cooperation is also a possibility.

BB, US: How is this evaluated for compliance?

IOAS, US: See comments on criteria for evaluating inputs

FAO, Italy: [as a guidance for organic standard-setting,] replaces [as a guidance
for organic standards setting,]

Fibl/BBV, Switzerland: : Add - for compost activation, appropriate micro-
organisms or plant-based preparations may be used; biodynamic preparations from

                                                                                58
 stone meal, farmyard manure or plants may also be used for the purpose covered
 by paragraph 5.

 Grolink: Are we doing a positive list only, this can be very restrictive!

Mandatory practices
None specified
OMRI, US: The operator shall develop a management system that maintains and
enhances soil fertility through the application of organic matter derived from plants
and animals. BB, US:
    The operator shall develop a management system that maintains and
       enhances soil fertility through the application of organic matter derived from
       plants and animals.
 Contradicts 4.3.1 and 4.3.4.
NASAA, Australia: Routine objective assessment by operator of fertility and any
input requirements during cropping cycle

Fibl/BBV, Switzerland: : Add - Fertilisation should be done according to regular soil
analyses

Prohibited practices

 4.3.7. The use of sodium (Chilean) nitrate.
 BB, US: Add - The operator shall not use any fertilizer or soil amendment that does not
 appear in Section C, Table 1.

 Argencert, Argentina:If we are going to prohibit specific substances (Chilean nitrate)
 there should be a negative list. If there is no such a list, all products should be evaluated
 through Section C: Criteria for the Evaluation of Substances. In that case there is no
 need to mention in the text one specific prohibited substance.

 SA, UK: ‗If there is no IBS permitted list, then prohibiting only sodium nitrate is totally
 inadequate. ‘ should follow.

 SOFA, Sweden: We agree with Grolink: Take away – this is a detail The lproblem
 with mentioning Chilean nitrate is that it might be understood that for example chemical
 fertilizers can be used but not Chilean nitrate

 KRAV, Sweden: The use of sodium (Chilean) nitrate and all synthetic nitrogenous
 fertilizers, including urea.

 OMRI, US: [New]: The operator shall not use of any fertilizer or soil
 amendment on organic crops or soil that does not appear in Section C, Table
 1.

 NASAA, Australia: [New expression] The use of sodium (Chilean) nitrate and other
 substances not appearing on annex xxx.

 Grolink: Take away – this is a detail - even if very important in the US. The larger
 problem with mentioning Chilean nitrate is that it might be understood that for example
 chemical fertilizers can be used but not Chilean nitrate


                                                                                    59
 Opdebeeck, Switzerland: I would like to express my surprise that the natural fertilizer
 sodium nitrate is proposed as a prohibited practice (substance) IBS.

Executive Summary
 Including natural sodium saltpeter as a prohibited practice (substance) IBS is
  contrary to IFOAM‘s aim to include substances in the IBS.
 It is also contrary to the requirements IFOAM imposes on those IBS.
 It suggests to the organic farming stakeholders that somehow the use of, for
  example, synthetic fertilizers and, for example, animal protein waste (see my
  former comments) would be preferable as the use of those fertilizers is not a
  prohibited practice IBS.

 I am referring to: section 4.3. Fertilization of IFOAM Benchmark for StandardS, 1st
 Revision Draft (16 April 2007), Prohibited practices: the use of sodium (Chilean) nitrate
 and I would like to add the following comments:

   1. In the ―Question and Answer‖ section on the IFOAM Benchmark for
      Standards(IBS), the following question is asked:

“There are no lists of substances! How then can this IBS be a valid and useful
organic benchmark?”

 And the answer is the following: ―…………..IFOAM intends to keep and revise the
 current lists of substances in the Appendix of the current IFOAM Benchmark for
 Standards. The lists and their development will be very transparent”.

 So why then is the prohibited use of the natural fertilizer sodium (Chilean) nitrate an IBS
 or in other words why is this natural input singled out as an IBS i.e. why this defensive
 and apparently pre-judged and arbitrary position about this input?
 And further why is this single input precluded from a ―transparent development ―as
 should be the case for all inputs of the Appendixes (positive and /or negative lists) as
 was intended according to above IFOAM answer?

 If then, for reasons we would like to hear , the prohibition of natural sodium nitrate
 would remain as an IBS, shouldn‘t it then at least be tested or evaluated whether its
 use would fulfill the requirements you impose on those very IFOAM Benchmark for
 Standards which are the following according to this same §4.3. (Fertilization):

“Principle applied
Organic crop production systems enrich the living soil, creating an environment that
can support the production of healthy, productive crops.

The objective is to practice a crop management system that seeks to nourish plants
primarily through the soil ecosystem, enhances the natural fertility of the soil and
avoids the excessive use of fertilizers.


Standards must require that:
 4.3.1. The management system maintains and enhances soil fertility.
 4.3.2. The management system provides an environment for healthy growing plants
        that produce yields appropriate for the crop and region.
 4.3.3. Contamination of the environment is avoided.
                                                                                 60
     4.3.4. The fertility program of a holding is based on the enhancement of the soil-
            ecosystem by the use of biodegradable material, green manure and nitrogen
            fixation from plants; and that mineral fertilizers are only used as a supplement.
     4.3.5. The use of fertilizing agents must be site adapted and correspond to the need of
            the plants.
     4.3.6. All substances used must be on the standards setting body‘s list of permitted
            substances.

And further according to: Section C - Criteria for the Evaluation of Substances Used in
Organic Production and Processing:

“Introduction
Substances used in organic production, processing and handling must be consistent
with the Principles of Organic Agriculture. The Principle of Care states that precaution
and responsibility are the key concerns in management, development and
technology choices in organic agriculture, processing and handling. Standard setting
bodies must use the following criteria, which are based upon a precautionary
approach, when evaluating substances for inclusion in their standards.

General Criteria
       All substances used in organic production and processing must meet all of the
following general criteria and be evaluated as a whole in order to protect the integrity
of organic production and processing:
i)        use of the substance is consistent with principles of organic agriculture as
          outlined in the IBS.
ii)       the substance is necessary/essential for its intended use.
iii)      approved alternatives are not available in sufficient quantity and/or quality
iv)       manufacture, use and disposal of the substance does not result in, or
          contribute to, harmful effects on the environment.
v)        they have the lowest negative impact on human or animal health and quality of
          life;
vi)       the consumer shall not be deceived concerning the nature and quality of the
          substance,
vii)      the substance is not known to be incompatible with consumer expectations in
          the region where the standard is applied.
viii)     consideration may be given to social and economic impacts of sourcing and
          manufacturing the substance

In addition, the following criteria must be applied in the evaluation process:
a)     if the substance is used for fertilization and/or soil conditioning purposes:
           it is essential for obtaining or maintaining the fertility of the soil or to fulfill
            specific nutritional requirements of crops, or specific soil-conditioning and
            rotation purposes which cannot be satisfied by other relevant parts of the
            IBS.
           the ingredients are of plant, animal, microbial, or mineral origin and may
            have undergone the following processes: physical (e.g., mechanical,
            thermal), enzymatic, microbial (e.g., composting, fermentation);
                 In execptional circumstances chemically synthesized substances
                    may be considered.
           use does not have a harmful impact on the balance of the soil ecosystem
            or the physical characteristics of the soil, or water and air quality.
                                                                                       61
       use may be restricted to specific conditions, specific regions or specific
        commodities.
b)    if the substance is used for plant protection, growth regulation or weed control:
       it must be essential for the control of a harmful organism or a particular
           disease for which other biological, physical, or plant breeding alternatives
           and/or other management practices consistent with this IBS are not
           effective.
       account must be taken of the potential harmful impact on the environment,
           the ecology (in particular non-target organisms) and the health of
           consumers, livestock, aquatic animals and bees.
       substances must be of plant, animal, microbial, or mineral origin and may
           undergo the following processes: physical (e.g. mechanical, thermal),
           enzymatic, microbial (e.g. composting, digestion);
       however, if in exceptional circumstances, a chemically synthesized
           substance (such as a pheromone) is used in traps and dispensers, then it
           maybe considered for addition to lists; but only if the substance is not
           available in sufficient quantities in its natural form, and provided that the
           conditions for use do not directly or indirectly result in the presence of
           residues of the substance in the edible plant parts;
       use may be restricted to specific conditions, specific regions or specific
           commodities;
c)    if the substance is used as an additive and/or processing aid in the preparation
      or preservation of the product:
      – it must otherwise be impossible to produce or preserve the product
       the substance is found in nature, and may have undergone
        mechanical/physical       processes     (e.g.   extraction,   precipitation),
        biological/enzymatic     processes    and     microbial   processes     (e.g.
        fermentation).
             In execptional circumstances chemically synthesized substances
               may be considered.
       use of the substance does not compromise the authenticity of the product
        or detract from its overall quality.
       In the case of textile processing, the relevant criteria above are applied,
        and in addition
             The substance may be allowed only if it is biodegradable, generally
               recognized as safe and hypoalerginic
             The substance shall be prohibited if it is carcinogenic, mutagenic,
               teratogenic, or toxic
             Use of pigments or mordents containing heavy metals in excess of a
               specified amount defined by the standard are not allowed.
             Additives and processing aids including sizes and lubricants must be
               either organic or biodegradable.
             The use of non-biodegradable, bio-accumulating input products and
               heavy metals shall be prohibited.

   3. If then, despite the 2 arguments as mentioned above, you would still, for reasons
 we would like to hear, insist on considering the prohibition of this input as an IFOAM
                                                                                 62
 Benchmark for Standards, we then would like to ask if you would agree whether the
 credibility and the impression of consistency within the IFOAM Benchmark for Standards
 would be promoted with the inclusion of this particular Benchmark.
 Or in other words could you please explain how you would avoid that this singling out of
 a most natural, essential and beneficial plant nutrient would then inevitably cause the
 impression and even suggest to the organic farming stakeholders that somehow the use
 of, for example, synthetic fertilizers and, for example, animal protein waste (see my
 former comment) would be preferable as the use of those fertilizers is not a prohibited
 practice IBS?

 Conclusion: Including natural sodium nitrate as an IFOAM Benchmark for Standards is
 not warranted and damages the credibility of the IBS concept.

 Consistency leads to credibility and credibility is what makes the Organic Farming label
 sustainable.

PGPCS, Sri Lanka: The creation of a diverse agro ecosystem that promotes the
increase in biomass in the soil.

IOAS, US: Although by no means against the inclusion of this prohibition which has
been traditional in organic agriculture for many years, it is a level of detail not found in
most other aspects of this standard.

 4.3.8. Hydroponics
 OTA, US: Both of the above would render the NOP non-compliant. There is no reason
 to single out a specific substance for prohibition, since they are covered by requiring that
 ―All substances used must be on the standards setting body's list of permitted
 substances.‖ (4.3.6) If a standards setting body determines that Chilean Nitrate meets
 the criteria identified in Section C, it contradicts their intent in creating a ―benchmark‖ for
 standards to dictate prohibition of a specific substance that otherwise complies with their
 own criteria.

 Hydroponic systems are the subject of an old NOSB recommendation, and while
 controversial, continue to be certified as long as all methods and substances used are
 NOP compliant. NOSB recommended that an organic hydroponic operation be part of a
 greater organic system and not stand alone. The problem is that it is soil-less
 production, a manufactured ecosystem. It should not be prohibited but it does need a
 full discussion, which IFOAM might consider hosting.

 BB, US: This is not defined and contradicts 4.5. What is the difference between
 ‗hydroponics‘ and ‗aquatic plants‘? These need to be distinguished.

 Argencert, Argentina: Also in the case oh hydroponics, its prohibition is in the
 basis of the organic production that states that organic products shall be based on
 natural systems. It does not seem necessary to mention it here.

 Grolink: Is this the right place to cover hydroponics? There are probably growing
 systems in water which can be allowed, what about sprouts? What about endives?
 For sprouts organic seed shall be required.




                                                                                     63
4.4. Pest-, Disease-, Weed-, and Growth Management
Agrior, Israel: IBS must define, at least, prohibited substances/methods, and terms
for conversion and allowed/prohibited practices for reproduction/propagation.

OMRI, US: Pest Management Even more disturbing is that there are no prohibited
practices specified in the section for pest-, disease-, weed- and growth management.
The proposed IBS thus permits any and all pesticides to be used in organic crop
production. Such a benchmark falls far below all known standards. In fact, because
there is no mandatory requirement for the use of biological and cultural methods, the
proposed IBS falls short even of most Integrated Pest Management (IPM)
certification programs. All pesticides—save for those produced by genetic
engineering—could be justified under the vague and weak criteria proposed in the
Appendix.

Principle applied
Organic crop production sustains and enhances the health of ecosystems and all
living matter, from the smallest organisms found in the soil to human beings.

Grolink: Replace with - Organic crop production sustains and enhances the health of
the soil and ecosystem; healthy soils produce healthy crops that foster the health of
animals and people.

The objective is to improve and sustain the health of crops while maintaining
productivity and the integrity of the agro-ecosystem.
NASAA, Australia: [New expression] The objective is to improve and sustain the
health and yield of crops while maintaining the integrity of the agro-ecosystem.


Standards must require that:
Fibl/BBV, Switzerland: This could also be standards for integrated production on a
low level. Nothing is said that synthetic pesticides are not allowed. Nothing is said
about habitat management.

 4.4.1. Natural resistance of the crops is enhanced by a combination of interrelated
      positive processes and mechanisms capable of accounting for the management of
      significant pests, diseases, and weeds. These include but are not limited to a site-
      and crop adapted fertility and soil cultivation program, choice of appropriate
      varieties, the enhancement of functional biodiversity; and in case additional
      measures are required, a restricted use of allowed crop protectants and growth
      regulators.

 Staff Comment: SC in March decided to improve wording of IBS 4.4.1 All SC members
 were asked to make proposals for improvements during comment period.

 SA, UK: This is much more narrow than the existing IBS, eg leading on natural
 resistance (and natural resistance doesn‘t apply to weeds). Suggest: Crop production
 be based on management practices that maintain soil and crop health by a combination
 of interrelated…

 RLF, South Africa: ‗crop-adapted‘ replaces ‗crop adapted‘.



                                                                                64
KRAV, Sweden: only to be used in exceptional cases where other methods are not
sufficient.

PGPCS, Sri Lanka: [add 5 new clauses]
  The creation of habitat for predators in order to enhance the interlay between pest
   and predator. For instance the deliberate use of weeds around a paddy field.
  The landscape design of the farm be such to include a high diversity of cops which
   leads to ecosystem stability and lowering of the risk since there are many food
   plants (for he pests)..
  The avoidance of monoculture production.
  The use of ‗shade‘‘ to control weeds.
  The use of mulch to control weeds.

Fibl/BBV, Switzerland: : Terminology not clear. Resistance often cannot be achieved
but a better tolerance to pests and diseases. Current text is better: Physical methods for
pest, disease and weed management are permitted, including the application of heat.

Grolink: The language above is very complicated and abstract. Simplify -
Natural resistance of crops is enhanced by a combination variety selection, design of
ecosystems and cultural measures for the enhancement of functional biodiversity and
management of pests, diseases, and weeds.
4.4.2. All active substances used must be on the standards setting body‘s list of
       permitted substances.
SA; UK: ‗setting body‘s list of permitted substances.‘ is highlighted in yellow. See
comments under Section C.

RSTWG, Sweden: [add] ‗Natural substances are restricted to those not explicitly
prohibited. Use of active substances is restricted to methods that do not harm health or
the environment.‘
The IBS propose that all standard setting bodies make a list of all allowed active
substances. In the EAOPS there is another solution which is similar to the NOP, all
natural substances is allowed if not explicitly prohibited and all synthetic substances are
not allowed if not the opposite is directly stated.

The EAOPS is an East Africa Community standard which will be revised every 5th year,
therefore it must be another procedure to add substances to the list as five years
interval is far too long to handle upcoming new substances and practices, organic
agriculture is developing. One solution can be that the CB should be able to add
substances too. Another possibility will be to allow references to input lists in other
standards for organic agriculture as Codex Alimentarius or the NOP.

It was discussed in the RSTWG and was found difficult to handle as it is very time and
knowledge consuming. It would be good to have a recommended list from IFOAM which
can be adopted by a standards setter or a CB

How will plant preparations etc be handled? Organic agriculture is in an early stage of
development still in East Africa and we foresee a lot of development in the area with
plant based preparations.

Biokontroll, Hungary: But a basic positive list should be maintained in this benchmark
of standards.

                                                                                65
KRAV, Sweden: All active substances used must be on the standards setting body‘s list
of permitted substances. They should primarily be of plant, animal and microbial or
otherwise naturally occurring mineral origin. The criteria in section C should be used to
evaluate active substances on the standard setting body‘s list of permitted substances.

BB, US: How is this evaluated for compliance?

Grolink: Is it really a good solution to let the standards setters make their own list?
Wouldn‘t it be good that IFOAM showed some examples? not in the IBS but possibly a
reference to another document. The worry is not that the lists get to wild but it is a lot of
competence needed to get a list together through using the criteria. If there is a
reference list, please make a reference
Only using a positive list can be very restrictive.
4.4.3. Co-formulants in formulated products must not be carcinogens, mutagens,
         teratogens or neurotoxins.
KRAV, Sweden: Co-formulants in formulated products shall fulfill the general criteria (i-
viii)of section C.
Reason:better wording

IOAS, US: This has already proved impossible to assess with regard to
accreditation and the SC has already had this communication through an IOAS
PoR. The standard might be somewhat improved in this aspect by the addition of
the word "known" before carcinogens. There is a certain lack of logic as this
prohibition would appear to apply only to the co-formulantss (inerts) and not to the
active substances of 4.4.2. Perhaps moving this to the prohibited practices would
better serve the intention of the SC (although it would not help the IOAS with regard
to assessment).

Grolink: Define Co-formulants

4.4.4. Soil sterilization is restricted to methods that do not damage the soil‘s recovery
        capacity.
SA, UK: So chemical sterilisation could be possible – not acceptable. Also needs
restrictive criteria for when soil sterilisation is allowed.

GCSAR, Syria: Could the word "formulates" be a better option?

KRAV, Sweden: Inputs that severely disturbs soil or water ecosystems and/or are
persistent in the ecosystem or is contaminated with such substances.

WSDA, US: This seems like a difficult (impossible) standard to measure.

ICS, US: [capacity] Needs clarification as to what this really means.

IOAS, US: The standard would appear to be completely subjective and will require
the IOAS to develop some guidance or interpretation.

NOFA, US: ―Soil sterilization restricted to methods that do not damage the soil‘s
recovery capacity.‖ Like availability, recovery capacity is open to interpretation and
this would be almost impossible for certifcation agencies to monitor.

Fibl/BBV, Switzerland: : Text from Codex GL could be added:

                                                                                  66
 − protection of natural enemies of pests through provision of favourable habitat,
 such as hedges and nesting sites, ecological buffer zones which maintain the
 original vegetation to house pest predators; diversified ecosystems.
 - diversified ecosystems. These will vary between geographical locations. For
 example, buffer zones to counteract erosion, agro-forestry, rotating crops, etc.

 Grolink: All soil sterilizations damage the soils recovery capacity to some extent,
 still soil sterilizations are done in several organic systems.

Mandatory practices
None specified.
OMRI, US: New item: The operator shall use biological, cultural, mechanical
and physical methods to prevent and manage pests, weeds, and diseases.

BB, US:
   New item: The operator shall use biological, cultural, mechanical and physical
     methods to prevent and manage pests, weeds, and diseases.
   Contradicts 4.4.1. What? No proactive cultural and biological measures to
     prevent pests, weeds, and diseases?

NASAA, Australia: Completion of a management plan by operators describing the
use and application of organic management practices and products to achieve
production and organic integrity
Crop rotation including alternative species.

Prohibited practices
None specified

SA,UK: SACL, UK: Steam sterilization
OMRI, US: New: The operator shall not use of any crop protectant or growth
regulator on organic crops that does not appear in Section C, Table 2.

BB, US:
   New: The operator shall not use any crop protectant or growth regulator that
     does not appear in Section C, Table 2.
   This permits the use of any active pesticide in organic production. This isn‘t
     even as good an some IPM program standards.

NASAA, Australia: Use of products not appearing on annex xxx

WSDA, US: Organophosphates, organochlorines, carbamates, thiodicarbamates,
phenoxy herbicides, sulfonourea herbicides, and other synthetic pesticides not
specifically approved.

4.5. Aquatic Plants
PGPCS, Sri Lanka:[add a aquatic variety for plant coming before aquatic animal]

BB, US: is this distinguished from hydroponics? Does it include paddy rice culture?

Grolink: Move the collection part to wild production and the other to crop production.
The standard itself can be used generally for crop production.


                                                                                67
Principles applied
The health of aquatic plants and their communities cannot be separated from the
health of the ecosystem.

The objective is to produce and harvest aquatic plants without negatively impacting
the production area or surrounding areas.
NASAA, Australia: [New expression] The objective is to sustainably produce and
harvest aquatic plants without negatively impacting the production area or
surrounding areas .

Standards must require that:
 4.5.1. The harvest of aquatic plants does not disrupt the ecosystem, and does not
        cause any degradation of the production area or the surrounding aquatic and
        terrestrial environment.
 JR-UoM, US: It appears that this standard is based on the harvest of wild or
 spontaneous aquatic plants. It does not apply to aquatic plants that are ―farmed.‖
 More detailed standards are needed for the organic production of aquatic plants

 BB, US: Any harvest will disrupt the ecosystem to some degree. The question is
 whether the system can recover and be sustainably harvested.

 IOAS, US: The IOAS will develop an interpretation of what harvesting methods
 would disrupt the ecosystem or degrade the aquatic/terrestrial environment but
 wish the SC to note that this standard would bar the use of calcium seaweed, which
 may or may not have been intentional.

PGPCS, Sri Lanka – Add:
- If the aquatic plants are exotic to the area, then care must be taken to avoid the
  escape of those plants in to other water bodies.
- The ecology of the exotic plants be understood by the operator before he
  introduces them into a natural environment.

Mandatory practices
None specified
NASAA, Australia: Operators must define and manage the production unit using
relevant practices outlined in this standard

Prohibited practices
None specified
BB, US: Comments on Manadatory practices and Prohibited practices: No
differences with conventional production.

NASAA, Australia: Use of products not appearing on annexes xxx, xx, etc

5. Animal Husbandry

Grolink: A general comment is that the animal husbandry standards have been
reduced too much, there to little content left to guide what is organic animal
husbandry what is not. The most developed part is treatments of animals, more then
welfare or feeding which have become very lean.



                                                                                68
5.1. Animal Health and Welfare
Agrior, Israel: General management policy, and specific withdraw periods are to be
defined in IBS, with regard to use of antibiotics and allopathic medicine.

SOFA, Sweden: We find that this chapter has been reduced too much and lacks
important content. As it is now written a majority of the Swedish conventional
production would be accepted as organic.
We also think the chapter should be re-organized with the important parts first The
production methods should sustain and enhance the health of the animals.
   – not treatments (used when the practices to raise healthy animals has failed!)

KRAV, Sweden: Organic animal husbandry is based on the harmonious relationship
between land, plants and animals. It provides animals with conditions that meet their
physiological needs and are in accordance with their natural and social behavior and
well-being. The production methods sustains and enhances the health of the
animals.

Principles applied
Organic animal husbandry is based on the harmonious relationship between land,
plants and animals. It provides animals with conditions and opportunities of life that
meet their physiological needs and are in accordance with their natural and social
behavior and well-being.
OCA, US: Animal products sold as organic come from animals who…
• Have been in organic management continuously since birth.
• Have eaten only what is consistent with their natural diet and is certified organic.
• Are not clones or the progeny of clones.
• Were not factory farmed or kept in confine d animal feeding operations.
• Were not given antibiotics or other allopathic medicines.
• Have been protected from exposure to contaminants.

NOFA, US: Plant Production and Animal Husbandry: there is no definite time
requirement for the conversion to organic. For equivalency to be meaningful, the 3-
year requirement should be universal.

The objective is to produce organic animal products while ensuring that animals are
treated respectfully their health and welfare are assured and that environment is
preserved.
NASAA, Australia: New expression: The objective is to produce organic animal
products while ensuring that animals are treated respectfully in ways that ensure the
health , welfare and productivity of themselves and the environment.

Grolink: The objective is to produce healthy animal products through ensuring that
animals are treated with respect and in accordance to their health and welfare needs
and that environment is preserved.

Standards must require that:
BB, US: You have a requirement of a positive list of crop protectants, why not for
medications?

ARGENCERT, Argentina:
Chapter 5: Animal Husbandry. Standards must require that: There is no provision
to withdraw from the organic system those animals that for humane reasons have

                                                                                 69
been treated with antibiotic or allopathic medicines. Also, withholding times after the
use of non organic medicines are not mentioned.

Grolink: The first four paragraphs 5.1.1 – 5.1.4 is about treatment of animals – is this
the most important in the chapter of animal health and welfare? Wouldn‘t it be good
to start with how animals shall be kept in organic agriculture?

 5.1.1. Health care practices and medications that may be used in organic production
      are clearly defined.
 SACL, UK: SACL: within a Livestock Management Plan indicating how livestock will
 meet the standards.

 SA, UK: This is too wide open, therefore meaningless. What about withholding periods
 and the principle of positive health?
 Biokontroll, Hungary: Emphasis should be taken on the gradual approach: 1st:
 prevention, 2nd natural medicines and treatment, 3rd unavoidable treatment with
 allopathic drugs. Practical measures to ensure health and well-being of animals should
 be defined. (Specific requirements on management practices should be included as it
 was in the IFOAM Basic Standards.)

 ICS, US: Health care practices and medications that may be used in organic production
 are clearly defined and linked in the standards to applicable requirements for
 conversion, as well as respecting the maintenance of organic management (section 3.6
 of the IBS).

 FAO, Italy: [new expression] The objective is to produce organic animal products
 while ensuring that animals are treated respectfully, their health and welfare are
 assured, and that the environment is not negatively impacted upon.

 5.1.2. Vaccinations are allowed only for known endemic disease that are likely to be a
        problem or when legally required.
 Biokontroll, Hungary: [and only if GMO-free] added [after required].

 SA, UK: ‗endemic‘ is highlighted in yellow. In the country, the region, on the farm?

 FAO, Italy: [likely to be a problem] This formulation is too vague: diseases that are
 likely to affect the animals?

 5.1.3. Medical treatment considered necessary for the welfare of an animal is never
        withheld in order to maintain the organic status of the animal. Animals must not
        be allowed to suffer for lack of treatment.
 SACL, UK: Justified to the CB

 RLF, Soth Africa: ‗through lack--‘ replaces ‗for lack--‘

 JR-UoM, US: Animals and products from animals treated with prohibited medications
 must not be sold as organic.

 NASAA, Australia: New expression: Medical treatment considered necessary for the
 welfare of an animal is never withheld in order to maintain the organic status of the
 animal,ensuring that the animal is not allowed to suffer for lack of treatment.


                                                                                  70
OIA, Argentina: In animal production there is a lack of clear definitions about the
one will accepted as medicinal treatment, with synthetic medicines.

5.1.4. The use of antibiotic and other allopathic medication is strictly limited to the
       treatment of illnesses and injuries.
SACL, UK: Justified to the CB

Biokontroll, Hungary: ‗and can be administered only with the supervision of the
veterinarian. Specified withholding periods shall be kept. .‘ should follow.

JR-UoM, US: Animals and products from animals treated with antibiotics must not be
sold as organic.

SOFA, Sweden. How is parasite treatment classified?
Withholding periods should also be included.

BB, US: Currently prohibited with a derogation.

NASAA, Australia: the [emergency] treatment

ICS, US:_This is a ridiculously large loophole that must be better defined in order to
be closed, especially when taken together with sections 5.1.1-5.1.3!

IOAS, US: 5.1.1- 5.1.4 will permit the use of just about any veterinary medicine and
does notspecify the conditions under which organic status will not be maintained. It
is up to the individual CB standards to define when, if ever, use of medication would
result in loss of organic status. Not only will the IOAS need to develop some
guidance about what is acceptable in an organic system, but this clearly does not
meet consumer expectations of an organic product.

Grolink: Please define allopathic, this makes problems for readers. Is parasite
treatment included?

Grolink: Withholding periods are totally taken away – is that intended?

5.1.5. In order to minimize animal suffering mutilation practices are defined and
       restricted to necessity and regional needs.
SACL, UK: SACL: will create additional requirements in the MLA

SA, UK: ‗necessity‘ is highlighted in yellow. Necessity for what – commercial
expedience, to cover management/system deficiencies? Not sufficient.

Biokontroll, Hungary: It makes possible to apply mutilation routinely, the language of
the IFOAM Basic Standards should be kept.

JR-UoM, US: In order to minimize animal suffering surgical practices are defined and
restricted to necessity and regional needs. [―Mutilation‖ is a subjective and inflammatory
term. Better to replace it with ―surgical,‖ which is a neutral term.

SOFA, Sweden: Re-introduce the wording from the current IBS. This is too weak!



                                                                                  71
NASAA, Australia: restricted to [those necessary and to] necessary and regional
needs.

ICS, US: [needs] Needs more definition to prevent factory farming or overly dense
stocking rates from being accepted as reasons for the ―needs.‖

IOAS, US: There appears a lack of logic here - mutilations are unlikely to minimise
animal suffering in most cases. IFOAM standards now essentially permit any
mutilation provided that the CB can provide some justification for it. The lack of
regulation is unlikely to meet the expectations of consumer who view organic
agricultural production as welfare friendly. The IOAS would be unable to restrict any
mutilation that a CB deemed necessary.

Grolink: This standard is much weaker then in the current IBS. Replace with -
Mutilation practices are defined and restricted to clearly established necessity and
carried out in the way that minimize animal suffering.

5.1.6. Living conditions (including housing) provided to the animals allow them to exhibit
       natural behavior and have freedom of movement and access to open air,
       including pasture.
COG, Canada: There are also inconsistencies where this new IBS is more
prescriptive than the old. Eg 5.1.6 which seems to require pasture for all livestock.

SA, UK: ‗access to‘ is highlighted in yellow. So one day‘s access would suffice. This
means nothing without at least stating minimum criteria.

RSTWG, Sweden: Tethering of animals is a common used practice by smallholder
farmers in East Africa. The RSTWG suppose that this practice can still be used if the
animals have the possibility to move and have adequate access to feed, shade and
water as outlined in EAOPS 6.3.6

IOAS, US: The standard has added new and restrictive content. It may be a
problem with the phrasing - but this requires all housing to have accessible pasture.
where previously there could be temporary housing with access to an exercise
yard. Currently there are many countries where this pose a problem.

FAO, Italy:_ to open-air [spaces]

5.1.7. Nutrition practices are consistent with their natural needs and behavior and a
       weaning period for young mammals must be defined.
SA, UK: ‗weaning period for young mammals must be defined‘ is highlighted in yellow.
So one week weaning period would suffice. This means nothing without at least stating
minimum criteria.

ICS, US: [defined] Needs minimum weanig times, probably species specific.

OIA, Argentina: There is no clear definition about the weaning moment.

IOAS, US: This is now very vague and will be open to a very wide interpretation.
There is no guidance on minimum lengths of time before weaning, which at any
rate would need to be species specific and which leaves them wide open to


                                                                               72
 interpretation. The IOAS will be obliged to develop some guidance on this for
 accreditation purposes .

 Grolink: Will this really work out, it will be easy to argue that milk powder for a quite
 short time will fulfill the request of this standard. This paragraph would fit better under
 the feed chapter. Split into 2:
 5.1.7.      Nutrition practices are consistent with the animals natural needs, diet and
 behavior
 5.1.8.      Weaning period for young mammals must be defined.

 5.1.8. Management practices according to sustainable land and water use.
 SA, UK: ‗according to‘ highlighted in yellow. Don‘t know what this means.

 NASAA, Australia: Management practices according to [ensure] sustainable land and
 water use.

 IOAS, US: Does not work with "standards must require that". It is not a sentence
 and doesn't mean anything. Suggest alternative of "management practices are
 compatible with sustainable land and water use". This would still require
 interpretation from the IOAS for accreditation purposes.

 Grolink: Replace with - The number of animals kept can be sustainably supported in
 accordance to the land, operation size and water available.

 5.1.9. Cruel treatment of animals is prohibited.
 SACL, UK: SACL: IFOAM should seriously consider outcomes as a measure of
 animal welfare not just listinput indicators and assume welfare will be guaranteed

 KRAV, Sweden: It is prohibited to cause any harm to animals.

 BB, US: Vague. Does calling them bad names count?

 WSDA, US: How is ―cruel‖ defined?

 PGPCS, Sri Lanka: [add a new clause] 5.1.10 The use of traditional methods of animal
 husbandry be allowed for use as long as they are found to be non detrimental to the
 animal or to the environment in general.

 IOAS, US: Would be strengthened by having this in the section on prohibited
 practices.

 Grolink: Replace with - Harsh treatment and forceful handling of animals are
 prohibited.

 Grolink/SOFA, Sweden: 5.1.6 – 5.1.9 are to general to give guidance enough for
 organic animal husbandry

Fibl/BBV, Switzerland: : Why is no differentiation between Management and Veterinary
Treatment The requirements are very general and good go for an non-organic standards
animal welfare programme and good conventional animal husbandry practise. The first
objective ―to draw a distinct line between organic and not organic‖ is therefore far from
being achieved. With other words, such a standard makes absolutely no sense and is as

                                                                                   73
good as no standard at all. Nothing is said about stocking densities, the non-allowance of
some mutilation/surgical practises. The implementation of the system approach is
missing, e.g. by giving more criteria that prevention goes first and preference is given to
phyto-therapeutic and homeopathic treatments.

The old IBS text was better: The operator shall ensure that the environment, the facilities,
stocking density and flock/herd size provides for the behavioural needs of the animals and
provides for:
a. sufficient free movement and opportunity to express normal patterns of behavior;
b. sufficient fresh air, water, feed and natural daylight to satisfy the needs of the animals;
c. access to resting areas, shelter and protection from sunlight, temperature, rain, mud
and wind adequate to reduce animal stress;
d. the maintenance of social
structures by ensuring that herd animals are not kept in isolation from other animals of the
same species;
e. construction materials and production equipment that do not significantly harm human
or animal health.

This provision does not apply to small herds for mostly self-sufficient production.
Operators may isolate male animals, sick animals and those about to give birth. where
animals require bedding, adequate natural materials are provided; That construction
provides for insulation, heating, cooling and ventilation of the building, that permits air
circulation, dust levels, temperature, relative air humidity, and gas concentrations to within
levels that are not harmful to the livestock;

All animals shall have access to pasture or an open-air exercise area or run, whenever
the physiological condition of the animal, the weather and the state of the ground permit.
Such areas may be partially covered.

Landless animal husbandry systems are prohibited. The maximum hours of artificial light
used to prolong natural day length shall not exceed a maximum that respects the natural
behavior, geographical conditions and general health of the animals.

Mutilations are prohibited. The following exceptions may be used only if animal suffering
is minimized and anaesthetics are used where appropriate:
a. castrations;
b. tail docking of lambs;
c. dehorning;
d. ringing;
e. mulesing only for breeds that require mulesing.

An operator may use chemical allopathic veterinary drugs or antibiotics only if:
•       preventive and alternative practices are unlikely to be effective to cure sickness or
injury;
•       they are used under the supervision of a veterinarian, and
•       withholding periods shall be not less than double of that required by legislation, or a
minimum of 48 hours, whichever is longer.
Substances of synthetic origin used to stimulate production or suppress of natural growth
are prohibited.

Mandatory practices
None specified

                                                                                   74
BB, US: Supervision of a veterinarian & extended withhold and for an animal to be
treated? These are major mandatory practices in the current IBS that distinguishes
organic from conventional.

NASAA, Australia: Pasture, shelter and shade must be made available to animals.


Prohibited practices
BB, US: Clarification of 5.1.9 is missing.

 5.1.10.     Routine use of antibiotics and parasiticides.
 BB, US:
     ‗Routine‘ is highlighted. Vague and subject to abuse. Current IBS proihbits use
        with a derogation.
     Two new items to be numbered:
        Use of any medical treatment in the absence of illness.
        Use of hormones or other drugs to promote growth and production.

 ICS, US: Use of antibiotics and parasiticides. Again, routine implies some use is
 acceptable for organic stock.

 Grolink: Here antibiotics and parasiticides is used, above allopathic medicines.

 5.1.11.  Keeping rabbits, pigs and poultry confined in cages.
 KRAV, Sweden: Keeping any animals including rabbits, pigs and poultry confined in
 cages.

 FAO, Italy: it be better to keep this more general, and jsut day ―animals‖ rather than
 resricting it only to rabbits, pigs and pultry?

 5.1.12.      Confinement of calves for veal production.

 5.1.13.      Landless animal husbandry systems.
 SOFA, Sweden: Also here we agree with Grolink: these paragraphs are a mixture
 of general statements and details, 5.1.11 and 5.1.12 and very details. Reading it a
 conclusion can be that cows can be kept in cages (5.1.11) and it is allowed to
 confine all other animals then calves for veal production.

 BB, US: Define. Where does aquaculture fit in? This contradicts the aquaculture
 standard in a way similar to the hydroponics prohibition.

 Grolink: Here are some a mixture of general statements and some details, 5.1.11
 and 5.1.12 are very detailed. Reading it a conclusion can be that cows can be kept
 in cages (5.1.11) and it is allowed to confine all other animals then calves, or
 confine calves for other purposes then for veal production.

5.2.   Feed

Principles applied
Organic animal production sustains and enhances the health of the animals and is
integrated with organic crop production systems.


                                                                                75
KRAV, Sweden: Organic animal production is integrated with organic crop
production systems. Supply of feed meet their natural foraging behavior .

NODPA, US: Pasture must provide a significant amount of the dry matter intake for
ruminant livestock during the growing season.

The objective is to provide a diet to the animals that contains high quality and
nutritious feed that maximizes the content of organic feed.
SA, UK: Far too weak – it would allow barley beef systems.

Agrior, Israel: Allowances and limits for non-organic portion of feed, must be clearly
defined in IBS, in terms of ingredient ranges, percentage and method of calculation.

NASAA, Australia: The objective is to provide a high quality and nutritious diet to
the animals that that consists of organic feed.

WSDA, US: The ―Objective‖ must be that organic livestock are provided with only
organic feed.

OIA, Argentina: On feed if it is properly justified any amount of conventional feed
could be given to the animals, it is acceptable that in front of a problematic situation
the animals welfare is more important than exceeding limits. But for the animal
production should be have clear definition of the feed limits.
ARGENCERT, Argentina: The Objective must be that all feed must be organic, not
that in animal feeding organic feeds shall be ―maximized‖.

Standards must require that:
BB, US: You have a requirement of positve lists for crop fertility, why not for animal
feed?

 5.2.1. Feed requirements are suitably addressed.
 SA, UK: Nothing about this in the objective so it means nothing, eg forced feeding
 would be acceptable.

 Biokontroll, Hungary: Basically organic feed is to be used.

 JR-UoM, US: Feed rations meet the nutritional requirements of the species.. [This is
 totally vague and unenforceable.

 SOFA, Sweden: This is too unspecified.

 KRAV, Sweden: Feed requirements and practices are suitably addressed.

 BB, US: Vague and subjective.

 NASAA, Australia: Organic Feed is defined.

 WSDA, US: How do you define ―suitably‖?

 IOAS, US: 5.1.7 and 5.2.1 together give little guidance to what is acceptable in
 animal nutrition e.g feeding of roughage to ruminants may no longer be considered
 "suitable" thus opening the door to high concentrate input feeding. The IOAS would

                                                                                   76
develop an interpretative document on what was "suitable" for accreditation
purposes.

Grolink: Suitably? For whom? In what way

5.2.2. The use of non-organic feed is strictly limited to necessity, based on regional
        production practices.
COG, Canada: A minimum organic content is necessary except in emergencies
and more elaboration is needed in 5.2.2 to make it clearer the circumstances that
allow for the use of non-organic feed –what does ‗ based on regional production
practices‘ mean in this context? The requirements 6.3.1 and 6.3.2 under aquatic
nutrition are much more explicit and similar wording would be appropriate in 5.2.

SACL, UK: Non-organic feed will be outlawed in the EU as of the 1/1/2008

SA, UK: . Too weak – it‘s too easy to justify necessity.

Biokontroll, Hungary: Maximum percentages should be set for in conversion and
conventional feed. This is too general.

JR-UoM, US: The use of non-organic feed is prohibited. [If you do not feed organic
feed, then you do not have organic animals.]

BB, US:
   ‗necessity‘ is highlighted. Subjective. Who determines necessity?
   ‗Regional‘ is highlighted. Define regional.

NASAA, Australia: The use of non-organic feed portion is defined and is strictly limited
to necessity, based on regional production practices.

WSDA, US: Use of non-organic feed must be prohibited for certified stock.

ICS, US: This item changed to: 100% certified organic feedstuffs be fed. See D14
comment. At the very least, strict, very specific parameters for using non-organic feed in
emergencies be specified.

PGPCS, Sri Lanka: [add a new clause] 5.2.3 The use of traditionally used, medicinal
plants to increase health are permitted for inclusion in the diets.

IOAS, US: There is no absolute limit to the amount of non organic feed which might
be fed - certain feedstuffs could be fed in unlimited amounts on the basis that they
were not available organically. This is not meeting consumer expectation of organic
products which expects organic animals to be fed a predominantly organic diet..

NOFA, US: Animal Husbandry: ―the use of non-organic feed is strictly limited to
necessity based on regional production practices.‖ This statement opens the door
to widely varying amounts of non-organic feed. Consumers do not expect organic
meat to have been fed non-organic feed.

Grolink – Change to: The use of non-organic feed is strictly limited to necessity and
non-accessibility of organic feed supply,


                                                                               77
 5.2.3. The carrying capacity of the organic production unit is suitably addressed.
 SACL, UK: SACL: need guidance on what is suitable

 SA, UK: Nothing about this in the objective so it means nothing.

 SOFA, Sweden: This is important – but the wording not so clear.

 BB, US: ‗suitably addressed‘ is highlighted. Vague and unenforceable.

 NASAA, Australia: The carrying capacity of the organic production unit is
 circumscribed

 IOAS, US: This would require a guidance or interpretative document developed by
 the IOAS for accreditation purposes.

 ARGENCERT, Argentina: non organic feed should not be limited by necessity; it
 should not be allowed at all or, if we want to allow limited use of non organic feed,
 the conditions to allow it must be clearly specified.
 There is no mention of feed produced outside the farm. If it is to be allowed in
 limited cases, the Standards must require part must require that the standard
 should specify precise percentages allowed of feed produced outside the farm.

 Grolink: What is intended, to not have more animals then feed and land? If so write
 that.

Fibl/BBV, Switzerland: : It would be better to speak about animal nutrition. The
requirements are very weak. What means limited to necessity? Stress should be
given more on ―organic feed‖ than ―non-organic feed‖. The principle to go for 100 %
organic feed is not mentioned. The importance of roughage, especially for certain
species, is left out. What about feed additives? What about the list of allowed silage
preservation additives and processing aids Current text is better:

Animals shall be fed organic feed.
Operators may feed a limited percentage of non-organic feed under specific
conditions for a limited time in the following cases:
a. organic feed is of inadequate quantity or quality;
b. areas where organic agriculture is in early stages of development.

In no case may the percentage of non-organic feed exceed 10% dry matter per
ruminant and 15% dry matter per nonruminant calculated on an annual basis.
Operators may feed a limited percentage of non-organic feed under specific
conditions for a limited time in the following cases:
a. unforeseen severe natural or man-made events;
b. extreme climatic or weather conditions.

Animals may be fed vitamins, trace elements and supplements from natural sources.

Synthetic vitamins, minerals and supplements may be used when natural sources are
not available in sufficient quantity and quality.
All ruminants shall have daily access to roughage. Young stock from mammals shall
be provided maternal milk or organic milk from their own species and shall be


                                                                                 78
weaned only after a minimum time that takes into account the natural behavior of the
relevant animal species.
Operators may provide non-organic milk when organic milk is not available.
Operators may provide milk replacers or other substitutes only in emergencies
provided that they do not contain antibiotics, synthetic additives or slaughter
products.

Codex GL text could be taken up:
Specific livestock rations should take into account:
   the need of young mammals for natural, preferably maternal, milk;
   that a substantial proportion of dry matter in the daily rations of herbivores
       needs to consist of roughage, fresh or dried fodder, or silage;
   that polygastric animals should be not fed silage exclusively;
   the need for cereals in the fattening phase of poultry;
   the need for roughage, fresh or dried fodder or silage in the daily ration for
       pigs and poultry.

Mandatory practices
None specified
BB, US: Contradicts 5.2.1. So some idiot can starve his animals and be certified?

NASAA, Australia: Feed must be supplied in sufficient quantity to maintain a fat
reserve of at least 2 score or equivalent.

ICS, US: Minimum requirements for setting the percentage of organic feed need to
be set, in order to adequately evaluate if the standard in question can be accepted
into the IFOAM family of standards.

Prohibited practices
 5.2.4. Feeding:
 BB, US: Inserting a new item: [non-organic feedstuffs].
         a. slaughter waste to ruminants.
         b. slaughter products of the same species.
         c. all types of excrements.
         d. any product subjected to solvent extraction (e.g. hexane) or the addition
         of other chemical agents.
         e. amino-acid isolates.
         f. urea and other synthetic nitrogen compounds.
         g. synthetic growth promoters or stimulants.
         h. synthetic appetizers, preservatives and coloring agents.
   JR-UoM, US:
     feeding not-organic feed
     feeding genetically engineered feed ingredients.

   SOFA, Sweden: This is detailed – not in consistency with other parts of this draft.
   But these details are important and should be kept.

   KRAV, Sweden: any product subjected to solvent extraction (e.g. hexane, water and
   etanol are permitted solvents) or the addition of other synthetic chemical agents
   (different salts are not regarded as synthetic chemical agents.).

   BFA & ACO, Australia: references prohibition of amino acid isolates.
                                                                                79
  We propose elimination of this clause OR note that prohibition is noted for all but
for monogastrics.
  We note that more than half the world of organic production (by value of
production) has organic standards that permit restricted use of amino acid
(methionine) for monogastrics only (USDA, Japan). We recognize that this has a
sunset clause on this allowance, however it highlights that many areas of the
world by production region have not yet established sustainable and suitable
alternatives. It has also been deemed in Australia currently a critically important
addition to diets, managing animal welfare, environmental management aspects
(greenhouse has emissions etc) and balancing diets of monogastrics.
This is indicated in Australia by a complete absence of certified poultry producers
of any considerable production size except where the restricted use of methionine
(like in the US and Japan) has been permitted.
  There is an extensive briefing document on this provided by one of the world‘s
experts on this area - Dr Michael Evans. This was submitted to the recent ACB
meeting in Bonn and we reference this as a key part of our submission.
  The context of this submission is as follows:
  Biological Farmers of Australia Co-op Ltd (BFA) has 12 subcommittees (from
Consumer, Retailer and Processor committees to producer sectors - such as
monogastics) and these subcommittees inform the elected Board of the BFA and
the Standards SubCommittee standards setting process. Some of these
subcommittees have been very active over the past 12 months in reviewing this
situation of feed allowances in monogastrics.
  The BFA is a broad based member group, that encompasses a range of
stakeholders. It covers over 70% of the Australian organic industry by certified
clients as well as the majority of industry members. Importantly its subcommittees
cover a range of other certification agencies in Australia.
  The BFA has over the past 12 months conducted extensive industry briefings,
including presentation and debate at its AGM (the industry‘s most attended
industry organization annual event) and presentations and determinations by 3
separate nutritionist experts that advise the organic industry (from ―competing‖
businesses). These briefings have been across certifiers and non partisan. The
clear direction taken from these group and industry briefings was to permit a
restricted allowance for methionine with review in alignment with both the USDA
NOP and Japan MAFF allowances.
  We suggest that this is judicious, equitable to the poultry sector and recognizes
the regional requirements of the global organic industry. We also suggest, based
on extensive review of this issue, that it ensures the organic industry can most
effectively meet its obligations and ideals of animal welfare, environmental
management and animal health and well being.
   We believe the risk to the organic sector and its integrity is otherwise at stake
without this allowance at this point in time.

PGPCS, Sri Lanka: [add a new clause] i. the banning of meat from ‗free range
cattle‘‘. In India and Sri Lanka, it is common to see cattle eating garbage that
oftens contains polypropylene bags etc.

IOAS, US: There has been considerable discussion among CBs as to what an
"amino acid isolate" is. It is necessary to have a definition at the very least.




                                                                              80
   Grolink: This is much to detailed compared with the rest of the chapter and also
   compared with not having any lists for inputs in farming. Some more general
   statements would be better.
   5.3. Transportation and Slaughter
   SOFA, Sweden: We find 5.3 better addressed in the current IBS. This is too
   weak.

   Fibl/BBV, Switzerland: : Nothing is said about a maximum transport time for
   animals anymore.

Principles applied
Animals are treated with respect and care.

The objective is to minimize stress and suffering during the movement, handling and
slaughter of animals.
NASAA, Australia: The objective is to minimize stress , suffering and identity loss
during the movement, handling and slaughter of animals.

Standards must require that:
Fibl/BBV, Switzerland: : Current text is better: Animals shall not be treated with
synthetic tranquilizers or stimulants prior to or during transport. The use of electric
prods and other such instruments is prohibited. Slaughterhouse journey times shall
not exceed eight hours.

 5.3.1. The organic integrity of the animal be maintained during movement, handling
        and slaughter.
 5.3.2. Measures are taken to minimize stress and avoid suffering during transit and
        holding prior to and during slaughter.
 SA, UK: There is nothing to prevent transport times being excessive.

 5.3.3. Each animal or group of animals are identifiable at each step of the transport and
        slaughter process.
 SACL, UK: SACL: it is essential to provide guidance on when animals must fed if they
 need to stay overnight. Also need guidance on what is an acceptable journey time.

 RLF, South Africa: ‗animals is‘ replaces ‘animals are‘.

 KRAV, Sweden: 5.3.4 Journeys to slaughterhouses are shortest possible.

Mandatory practices
None specified
BB, US: Contradicts 5.3.1 and 5.3.2. What are the minimums required?

NASAA, Australia: Animals must not fall outside the organic chain of custody from
farm to abbatoir.

Prohibited practices
 5.3.4. Use of electric prods, tranquilizers, and stimulants.

NASAA, Australia: Use of solid injurious devices to promote movement, tranquilizers,
and stimulants.


                                                                                   81
5.4.   Breeds and Breeding

Principles applied
Animal breeds adapted to local conditions perform best in organic agriculture.
JR-UoM, US: Animals should be raised and managed organically from birth or
hatching in order to produce organic products.

Grolink: Change to - Immunity, resilience and regeneration are key characteristics of
healthy organisms. Animal breeds adapted to local conditions perform best.

The objective is to promote organic production through the use of appropriate
animal breeds.
SA, UK: The objective is to promote base organic livestock production through on
the use of appropriate animal breeds.

NASAA, Australia: The objective is to promote appropriate animal breeds for the
environment, the market and the well being of the animal itself using organic
production.

Grolink: The objective is to ensure the use of appropriate animal breeds and
breeding methods.

Standards must require that:
Fibl/BBV, Switzerland: The requirements are far too general. This could be a
standard for good conventional farming. There should be at least some information
about which breeding techniques are acceptable or about criteria‘s for consistency
with organic production methods.

Current text is better: Artificial insemination is permitted. Embryo transfer techniques
and cloning are prohibited.

 5.4.1. Animal production systems use breeds suited to the region and the production
        method.
 ICS, US: [method] Basic indicators should be provided, or some further definition,
 for how it would be determined that a breed is suitable.

 IOAS, US: The IOAS would be at a loss to assess whether a breed were suited to
 the region - production method is a little easier, although even here there would
 need to be IOAS guidance to be developed for accreditation purposes.

 5.4.2. Animal production systems use breeds that reproduce successfully under natural
        conditions and without routine human involvement.

 Grolink – Change 5.4.1 and 5.4.2 to:
 5.4.1.      Animal breeds used are suited to the region and the production
 method.
 5.4.2.      Animal breeds used can reproduce successfully under natural
 conditions and without routine human involvement.

 5.4.1 and 5.4.2 uses a language ―animal production systems‖ which is not used in
 the rest of the animal husbandry chapter. Need to describe what are breeding
 techniques that are consistent?

                                                                                  82
 5.4.3. Only breeding techniques consistent with organic production methods are used.
 SACL, UK: SACL: how about saying something about avoiding breeds bred for
 intensive systems??

 SA, UK: ‗organic production methods‘ is highlighted in yellow. Not clear what these are
 – they need to be defined or referenced.

 JR-UoM, US: 5.4.5 Animals must be raised and managed organically from birth or
 hatching in order to produce organic products.

 NASAA, Australia: Delete item 5.4.3

 ICS, US: [used] If there are other envisioned prohibited methods, those should be
 specified below (e.g., embryo transfer, etc.).

 IOAS, US: What does this mean? 5.4.2 states that they must be capable of
 breeding naturally.
 Use of hormones is prohibited in 5.4.4. If this is meant to cover embryo transfer or
 cloning, then it would be more satisfactory to have a standard prohibiting this. IOAS
 guidance would need to be developed for accreditation purposes.

Mandatory practices
None specified
NASAA, Australia: Animals must be capable of copulation, gestation and giving birth
without assistance.

Prohibited practices
 5.4.4. The use of hormones to induce ovulation and birth. unless for medical reasons
 Biokontroll, Hungary: , and only with the supervision of the veterinarian; embryo
 transfer; cloning. should follow.

 JR-UoM, US: Two new items:
 The use of cloned and transgenic animals and their progeny.
 Rotation of animals between organic and not-organic management.

 KRAV, Sweden: 5.4.5 Embryo-transfer techniques and cloning are prohibited.

 BB, US: Inserting a new item: Rotation of animals between organic and not-organic
 management.

 NASAA, Australia: The use of hormones and other products not contained in relevant
 annexes to induce ovulation and birth. unless for medical emergencies.

 FAO, Italy: unless [necessary]

 NODPA, US: Section 5.4.4 prohibits ―The use of hormones to induce ovulation and
 birth. unless for medical reasons.‖ If hormones are used as such, then any organic
 animal so treated, or the animal‘s products, must no longer be organic. To allow
 hormones to be used in organic production, even for medical reasons, is anathema to
 organic production.


                                                                                83
 Grolink: Change to -The use of hormones to induce ovulation and birth unless
 prescribed for medical reasons

5.5. Bee Keeping
Grolink: The language and statements in the bee keeping chapter is much better then in
the animal husbandry chapter.

Principles applied
The role of organic agriculture, whether in farming, processing, distribution, or
consumption, is to sustain and enhance the health of ecosystems and organisms
from the smallest in the soil to human beings.
KRAV, Sweden: We prefer to take this introduction away. If you want it , put it in the
beginning somewhere and not related to ―bee-keeping‖.
Within the context of organic production systems bee colonies behave as single
organisms.
Bee management should fit the cycles and ecological balances in nature. These
cycles are universal but their operation is site-specific.
KRAV, Sweden: Bee keeping is an important activity that contributes to
enhancement of the agriculture and forestry production through the pollinating action
of bees.

The objective is to ensure that bee colonies are managed as an integral part of the
sustainable environment and that their natural cycles are respected.
RLF, South Africa: ‗The objectives are to

NASAA, Australia: The objective is to ensure that bee colonies are maintained
through natural and seasonal cycles to provide organic honey and pollination within
an environment guarded from contamination.

Grolink: The objective is to ensure that bee colonies are managed as an integral part
of the sustainable ecosystem and that their natural cycles are respected.

Standards must require that:
ARGENCERT, Argentina:
  What about wax? Wax handling in conversion is not mentioned.
  Supplementary feeding besides being restricted it should be done with organic
   food.

 5.5.1. Bee races/breeds are adapted to the local environment and conditions.
 OIA, Argentina: On bee keeping there are not definition on distance to
 conventional, neither the area surrounding the hives

 IOAS, US: Does this prohibit use of "foreign breeds"? Brazilian breeds in
 Switzerland etc.? IOAS would need to develop an interpretative document for
 accreditation purposes.

 5.5.2. Hives are placed in sites with a low risk of contamination within a defined foraging
        distance.
 SA, UK: So can be nowhere near an organic farm or wild natural area?




                                                                                84
Agrior, Israel: This statement is not as inclusive as it should be in order to provide
for the objective, and for clean and healthy organic production. Text of 5.4.1 in 2005
IBS should not be replaced.

Biokontroll, Hungary: Hives are placed in organically managed fields / natural areas /
agricultural areas where it can be verified that no prohibited substances have been
applied for a set period within a defined foraging distance.

JR-UoM, US: How is ―low risk of contamination‖ defined?

BB, US: ‗low risk‘ is highlighted. Subjective?

ICS, US: [distance] Either a minimum radius is needed or a requirement that the
standard have other criteria for assessing what the minimum radius should be on a
case-by-case basis. Otherwise difference among members of the Family of
Standards is liable to be wildly out of proportion.
IOAS, US: No defined foraging distance and therefore IOAS guidance would need
to be developed for accreditation purposes.

Grolink: Defined foraging distance? What is intended with ―defined‖, the foraging areas
depends on the state of the crop, when it is flowering, it is not constant.

5.5.3. The health and welfare of the bee colony is primarily achieved through good
       management and hygienic practices, including the use of non-contaminating
       building material and physical sanitation methods.
PGPCS, Sri Lanka: [Add a new item] The cultivation of known bee plants, specifically
the native plants is recommended where the operator knows the time of flowering etc of
such plants.

IOAS, US: The intention of the standard is not clear - are physical sanitation
methods the only acceptable methods?

5.5.4. Methods permitted for hive disinfection are restricted.
SA, UK: ‗restricted‘ is highlighted in yellow. The methods or the use of them?
Restricted to what?

COG, Canada: … Other statements could use more elaboration in order to
understand the issue and intent. For example … the meaning when the word
restricted is used is unclear in 5.5.4 and 5.5.8.

Biokontroll, Hungary: 5.5.4 should be specified to what…

JR-UoM, US: In what ways are they to be restricted?

BB, US: ‗Ristricted‘ is highlighted. To what? On what basis?

ICS, US: [restricted] Practices and/or materials that would be prohibited should be
specified below.

IOAS, US: What does this mean- that they must be on a permitted list? That they
may only be used under certain conditions? Restricted to anything a CB wishes to


                                                                                 85
say ? Are the actual substances which may be used in tended to be regulated
under 5.5.4?

Grolink: What does this mean? Restricted, to what??

5.5.5. All substances used for pest and disease control must be on the standards
       setting body‘s list of permitted substances.
SA, UK: ‗standards setting body‘s list of permitted substances‘ is highlighted in yellow.
See comments under Section C.

BB, US: Why not have this for all animals?

WSDA, US: New clause: Prohibit antibiotics and synthetic medications.

IOAS, US: See general notes on the criteria for permitted substances.

5.5.6. Where preventative measures fail, veterinary medicinal products may be used
       provided that:
       a. preference is first given to phyto-therapeutic and homeopathic
          treatments, or substances on the standards setting body‘s list of
          permitted substances .
       b. products are not labeled as organic when allopathic, chemically
          synthesized medicinal products are used.
SA, UK: ‗standards setting body‘s list of permitted substances‘ is highlighted in
yellow. See comments under Section C.

JR-UoM, US: What is the withhold time after use before organic products can be
collected?

BB, US: For how long after treatment?

IOAS, US: This is inconsistent with the general livestock standards - why are there
additional restrictions for been products when dairy products, for example, can be
sold as organic after allopathic, chemically synthesized medicinal products are
used?

5.5.7. Harvesting methods are sustainable and ensure sufficient food reserves are left
       behind.
SA, UK: ‗sufficient food reserves‘ is highlighted in yellow. For what? Needs
specifying.

ICS, US: Harvesting methods are sustainable and ensure sufficient food reserves
are left behind to ensure the survival of the colony. This does not necessarily
contradict 5.5.8.

IOAS, US: Sustainable harvesting and sufficient reserves are not defined so IOAS
guidance will need to be developed for accreditation purposes.

5.5.8. Supplementary feeding is restricted.
SA, UK: ‗restricted‘ is highlighted. To what? Needs specifying.



                                                                                86
 COG, Canada: … Other statements could use more elaboration in order to understand
 the issue and intent. For example … the meaning when the word restricted is used is
 unclear in 5.5.4 and 5.5.8.

 Agrior., Israel: Supplementary feeding should be from certified organic source,
 only.

 Biokontroll, Hungary: Supplementary feeding is possible only with organic honey or
 sugar)

 IOAS, US: Type of restriction not specified - time of year? type of feedstuff? IOAS
 guidance to be developed for accreditation purposes.

 Grolink: What does this mean? Restricted??

 5.5.9. Processing practices should maintain the original quality and characteristics of
        the honey.
 SA, UK: ‗SHOULD‘ is deleted. ‗Should‘ is not a requirement

 Biokontroll Hungary: Adding three new items:
 Conversion should be specified (1year, wax replacement)
 The use of chemical repellents during extraction is prohibited.
 Restrictions on smoking should be included.

Fibl/BBV, Switzerland: : Why is the prevention only mentioned here and not in the
general animal section? What means restricted, without giving criteria (specify or
omit)? In general this part is more in accordance with the first objective than the rest
of p.5.

Current text is better: At the end of the production season, hives shall be left with
reserves of honey and pollen sufficient for the colony to survive the dormancy period.
Any supplementary feeding shall be carried out only between the last honey harvest
and the start of the next nectar or honeydew flow period. In such cases, organic
honey or sugar shall be used.
Exceptions may be made, for a limited time, if organic sugar is not available.

Where no prohibited products have been previously used in the hive and there is no
risk of contamination of wax, replacement of wax is not necessary.
In cases where all the wax cannot be replaced during a one-year period, the
conversion period may be extended with the approval of the standard-setting
organization.

Mandatory practices
None specified
 NASAA, Australia: A minimum of 3km from conventional farms

Prohibited practices
 5.5.10.      The destruction of bees in the combs as a method of harvesting.
 RSTWG, Sweden: Proposal: The prohibition of killing bees at harvest will lead to
 that traditional bee-hives can not be used in organic bee-keeping in Africa, they will
 have to be replaced with frame hives. There are suspicions that the frame hives


                                                                                   87
 have supported the spread of the varroa mite, and a reason why most of Africa still
 is not affected is because the frame hives has not been used.
 Brood killed at harvest of honey also provides a source of protein for kids and
 grown ups, also it is a sustainable use of the resource, provided that enough brood,
 honey and pollen is left for a healthy sustainable colony. It can be questioned if
 there are any principal reasons for the prohibition to kill bees in comparison with
 other insects, for example pollinating wild insects which can be destroyed in large
 numbers at harvest of crops?

 The interpretation of this should be that it is prohibited to destroy the brood
 deliberately in order to harvest. Rather if brood is inadvertently destroyed due to
 limitations in the methods then the concern is on the survival of majority of the
 brood to sustain the colony and minimize adverse effects on the welfare of the
 colony.

 NASAA, Australia: new Item: annual destruction of colonies

 5.5.11.     Clipping the wings of the queen bees.

 NASAA, Australia: New item: The use of substances not contained within annex.xxx

ARGENCERT, Argentina: [add]
  Use of chemical repellents is not prevented
  Avoid harvesting frames with brood is not mentioned.

 Grolink: Both (5.5.10+5.5.11) these paragraphs are to detail to fit in the structure.
 In harvesting of honey in traditional African hives some brood is destroyed/killed,
 bee larvae is often consumed by kids and grownups as a protein source. This
 standard is prohibiting the most common way of bee-keeping in East Africa. The
 important topic should be to not kill so many bees when harvesting so that the
 sustainability of the colony is threatened.
 In the animal husbandry standards mutilations are very generally covered while
 wing clipping of bees is prohibited. This makes a very uneven approach to similar
 topics.

6. Aquaculture Production
SACL, UK: SACL: we would need to rewrite this section in line with our own
aquaculture standards. We would also need to carry out more equivalence checks of
any aquaculture certified by another CB to this standard. This is because as soon as
you introduce words like ‗account‘, ‗ensures‘, ‗minimizes‘, etc, that opens the door for
many interpretations, which need to be checked to ensure they meet our standard

SA, UK: there seem to be significant inconsistencies between chapters 5 and 6, which are
not logical (in the context of Baseline Standards).

6.1. Aquatic Ecosystems
Agrior., Israel:
- IBS must at least require standardized limitation on purchase form non Organic
sources. Organic standards must aim for "closed cycles" of Aquaculture production.
E.g - reduce reliance on conventional breeds and promote Organic breeding,
hatching and nursing practices.


                                                                                 88
-"Appropriate techniques" are to be defined by IBS. Organic movement is to take one
step forward with standard setting for organic aquaculture, and this is defining
"shoulds" and "must nots" for organic broad stock keeping, and for hatchery
management practices.

Principles applied
Organic aquaculture supports a healthy and diverse ecosystem that provides
conditions and opportunities of life to the farmed species that meet their physiological
needs in accordance with their natural and social behavior and well-being.

The objective is that aquaculture management maintains well-being of the farmed
species, the biodiversity of natural aquatic ecosystems, the health of the aquatic
environment, and the quality of surrounding aquatic and terrestrial ecosystem.

Standards must require that
 6.1.1. Verifiable and effective measures are taken to maintain the integrity of the
        aquatic ecosystem. In particular, the release of nutrients and waste into the
        aquatic ecosystem must be minimized.
 IOAS, US: The first sentence is not verifiable and therefore effectively, the standard
 will become the second sentence.

 Grolink: What it means ―integrity of the ecosystem‖. What happen if the measure are
 not so effective ==> decertified the farm?

 6.1.2. Adequate measures are taken to prevent introduced or cultivated species from
        escaping into the ecosystem.
 IOAS, US: What would be considered adequate measures will require the
 development of guidance by the IOAS for accreditation purposes.

Fibl/BBV, Switzerland: : Text from Naturland standards should be added: Where
suitable, polyculture shall be preferred.

IFOAM Norms 2005 are better:
a. encourage and enhance biological cycles;
b. utilize preventive, system based methods for disease control;
c. provides for biodiversity through polyculture and maintenance of riparian buffers
with adequate plant cover.

Mandatory practices
None specified
NASAA, Australia: Nutrients generated must be cycled on site or released into a
sustainable environmental sink.

Prohibited practices
 6.1.3. All active substances used must be on the standards setting body‘s list of
        permitted substances.
 SA, UK: ‗standards setting body‘s list of permitted substances‘ is highlighted. See
 comments under Section C.

 BB, US: Why not have this for all animals? See comments on Appendices.



                                                                                 89
 NASAA, Australia: All active substances used must be on the standards setting body‘s
 list of permitted substances and on the annex xxx of this standard.

 Grolink: Is this a prohibited practice? Please define what an active substance is, use
 the same terms as in the other chapters. Is the positive list approach is appropriate?

6.2. Sources, Breeds and Breeding of Aquatic Animals
Fibl/BBV, Switzerland: : This is generally good.

Principles applied
Aquatic species and breeds adapted to local conditions are best suited for organic
aquaculture.
Fibl/BBV, Switzerland: : That‘s a little bit tricky: some species are locally adapted
because there are used for a long time in an area, but they are not local. It should be
committed, that the species are naturally occurring in the region.

The objective is that species and breeds used in organic aquaculture are locally
adapted and that the individual animals spend their entire lives on organic units.

Standards must require that
 6.2.1. Animals are raised organically from hatching or from early ages subject to a
        conversion requirement
 SA, UK: ‗from early ages ‘ is highlighted. This contradicts the objective.

 IOAS, US: This standard could usefully be combined with 6.2.3 - i.e. the conversion
 period must be at least 2/3 of the animal's life span. What constitutes "early ages"
 could usefully be specified as the IOAS will need to make some interpretation on
 this for accreditation purposes.

 Grolink: Change to –
 6.2.1 Animals are preferably raised organically from hatching
 6.2.2. Brought in non-organic seed should be of an early age

 What is meant with a conversion requirement? Conversion as mandatory requirements
 is already state two thirds lifetime or more

 6.2.2. Appropriate techniques are used for organic breeding and production.
 SA, UK: Appropriate to what? Need to specify.

 NASAA, Australia: New expression: Naturally analogous techniques are used for
 organic breeding and hatching.

 PGPCS, Sri Lanka: [add a new clause] If the farming of aquatic fauna involves native
 fauna like endangered fish species, then the operator could be encouraged to
 participate in the re-introduction of a percentage of such fingerlings in to their native
 habitat thus fostering their conservation thereof.

 IOAS, US: Use of phrases such as "appropriate" are not useful for assessment
 purposes. The would need to develop guidance for accreditation purposes.

 Grolink: What is an appropriate technique, this gives very little guidance. Replace
 with – Reproduction and breeding techniques used should be as close to natural

                                                                                 90
 conditions as possible and human involvement should not include prohibited
 practices below.

Mandatory practices
 6.2.3. Brought-in conventional animals must spend two thirds or more of their life span
        in an organically-managed system.
 SA, UK: This contradicts the objective.

 IOAS, US: This is the mandatory part of the conversion requirement at 6.2.1.

 Grolink: Brought-in conventional animals must spend two thirds or more of their life
 span in an organic system.

Prohibited practices
 6.2.4. The use of artificially polyploided organisms.
 6.2.5. The use of synthetic hormones to artificially stimulate reproduction.
 RLF, South Africa: ‗stimulate reproduction artificially‘ replaces ‗stimulate reproduction‘.
 NASAA, Australia: [New item] The use of products not contained in annex xxx

 Fibl/BBV, Switzerland: : The use of hormones is not allowed.

6.3. Aquatic Animal Nutrition
Agrior., Israel: IBS should define what sort of verifications could be accepted as
evidence for sustainability of fish meal & fish oil sources. IBS should prohibit use of
fish meal and fish oil, form sources hunted exclusively for production of these items.
IBS should also state specific limit for non organic feed allowances.


Principles applied
In organic aquaculture the health, well-being and nutritional needs of the animals are
closely integrated with the maintenance of a healthy ecosystem.
NASAA, Australia: In organic aquaculture the health, well-being and nutritional
needs of the animals are closely integrated with the maintenance of a healthy
ecosystem both immediately and worldwide.

The objective is to ensure animals are fed according to their natural feeding
behavior, and that they receive their nutritional needs from good quality organic feed.
NaturLand, Germany: Adding ‗Pressure on wild aquatic resources must be
minimized. ‘

NASAA, Australia: The objective is to ensure animals are fed according to their
natural feeding behavior, from the production unit itself and that they receive
additional nutritional needs principally from good quality organic feed and surplus
marine products .

Standards must require that:
 6.3.1. The animals are fed predominantly organic feed.
 JR-UoM, US: Does this mean over fifty percent of the feed must be organic?

 NASAA, Australia: The animals are fed organic feed and defined marine waste.



                                                                                 91
ICS, US: The animals are fed predominantly organic feed. 100% organic feed should be
fed. Need to set a minimum, otherwise this only means greater than 50%.

IOAS, US:_ Predominantly means 51%. Is this really acceptable in an organic
system. It is not what consumers expect when they buy organic aquatic products.

6.3.2. Non-organic feed is only used when available organic feed is of inadequate
       quantity or quality or when organic aquaculture is in early stages of development.
NaturLand, Germany: To delete Item 6.3.2

Biokontroll Hungary: Non-organic feed is only used when available organic feed is of
inadequate quantity or quality or when organic aquaculture is in early stages of
development, and allowed to use for a limited time, and not more than in 15% dry matter
per year, specific limitations should be set on type.

ICS, US: [development] Need to specify what the limitations are on the types of non-
organic feed (i.e., plant materials, kinds of animal materials, fish by-products, etc.).
Otherwise this opens the door wide to non-organic farm products.

IOAS; US: Slight restriction on 6.3.1 but "early stages of development" needs
defining.

6.3.3. Non-organic aquatic animal protein and oil may be used provided it is harvested
       from verifiable sustainable sources and have contamination levels below limits
       established by the standard-setting body.
SA, UK: ‗established by‘ is highlighted. Too weak - needs criteria to at least define
how these should be set.

RLF, South Africa: ‗they are harvested--‘ replaces ‗it is harvested --‘.

ICS, US: Need to specify what kinds of contaminants are included in this
requirement.

PGPCS, Sri Lanka: [add a new clause] That natural controls such as a protective
vegetation barrier are in place to prevent he leaching of feed residues into the ground
water table. The case of errant shrimp farming in Sri Lanka is a classic case in point.

IOAS, US: Not clear whether this is in addition to 6.3.2 or within the limits
established by 6.3.2.

Fibl/BBV, Switzerland: : Difficicult to determine contamination levels.

Grolink: Why only regulate the contamination in the conventional feed, why not in all
feed? Why fish should have better conventional feed than chicken.

6.3.4. Where relevant the diet fed to aquatic animals complies with the requirements of
       section 5.2.
NaturLand, Germany: Adding two items:
Use of by-products from fishery for human consumption is encouraged.
Use of wild aquatic sources, if harvested solely for feed purpose, is limited.
Non-organic agricultural products must not be used as feed ingredients.


                                                                                92
 IOAS, US: As 6.3.3 presumably includes aquatic slaughter waste, 5.2.4 a and b
 would not apply. "Where relevant" is largely subjective and would need
 interpretation by the IOAS for accreditation purposes.

 Grolink: Write this paragraph so it stands on its own.

Fibl/BBV, Switzerland: : To be added:
 Feed brought into the operation should be comprised of by-products from organic and
   wild sources not otherwise suitable for human consumption.
 The percentage of animal components in feed shall, as far as possible, be decreased
   or replaced by vegetable products. The use of components from agriculture production
   must be organic origin.

Mandatory practices
None specified
WSDA, US: 100% organic feed

Prohibited practices
 6.3.5. Non-organic aquatic animal protein and oil must not constitute 100% of the diet.
 CQC, China: Non-organic aquatic animal protein and oil must not constitute 100% of
 the diet.

 JR-UoM: But it could constitute 99.9% of the diet?

 BB, US: So 99.99% is OK?

 NASAA, Australia: Aquatic animal protein and oil collected primarily for the
 purpose of feedstock manufacture shall not constitute more than 50% of the total
 diet.

 IOAS, US: predominantly organic - this seems to indicate that it could consist of
 99% non organic. If this is the case, then it certainly would not conform to consumer
 expectations of an organic product.

 Grolink: Is it allowed with 99%?

6.4. Aquatic Animal Health and Welfare
Agrior. Israel: Standards must have definitions and rates for stocking densities.

Principles applied
Organic aquaculture promotes and maintains the health and well-being of the
animals.
NASAA, Australia: Organic aquaculture promotes and maintains the health well-
being and productivity of the animals.

The objective is that disease control is based on preventive, system-based
methods.
KRAV, Sweden: [method] is followed with [, such as balanced organic nutrition,
stress-free living conditions appropriate to the species and breed selection for
resistance to diseases, parasites and infections].



                                                                                93
NASAA, Australia: The objective is that disease control is based on preventive,
system-based methods that do not place reliance on veterinary inputs

Standards must require that:
 6.4.1. Stocking densities do not compromise animal welfare.
 IOAS, US: Extremely vague standard and IOAS guidance would need to be
 developed for accreditation purposes.

 6.4.2. Production units are managed to maintain water quality and the health and
        natural behavior of the stock.
 SA, UK: This is far too brief - it should reference section 5.1 as well (including
 withholding periods, principle of positive health, etc).

 IOAS, US: The IOAS would need to develop an interpretative document for
 accreditation purposes to include the parameters for water quality and what
 constitutes health and natural behaviour

Fibl/BBV, Switzerland: : Add - The husbandry conditions must enable the animal to
behave in a way natural to the species; this refers, in particular, to behavioural needs
regarding movement, resting and feeding as well as social and reproduction habits.
The husbandry systems shall be designed keeping all this in view, e.g. in respect of
stocking density, soil, shelter, shade and flow conditions.

Stocking densities must be fixed for the species which licensed by the labels.

Operators shall routinely monitor water quality, stocking densities, health, and
behavior of each cohort (school) and manage the operation to maintain water quality,
health, and natural behavior.

Mandatory practices
None specified
NASAA, Australia: Water quality control must complement the health of the stock

Prohibited practices
 6.4.3. The use of chemical allopathic prophylactic veterinary drugs.
 6.4.4. The use of chemical allopathic veterinary drugs and antibiotics for invertebrates.
 IOAS, US: Repetition of 6.4.3 which says such drugs may not be used at all in
 aquatic systems. Inconsistent with the general livestock standards which do permit
 use of such drugs and antibiotics provided that they are not routine.

 6.4.5. The use of synthetic hormones and growth promoters to artificially stimulate
        growth.
 RLF, South Africa: ‗stimulate growth artificially‘ replaces ‗stimulate growth‘.

 NaturLand, Germany: 6.4.6 The use of chemical anti-fouling agents on net-cages.

6.5.   Aquatic Animal Transport and Slaughter

Principles applied
Handling, transport and slaughter of aquatic animals is managed in a responsible
and humane manner.
RLF, South Africa: ‗are managed‘ replaces ‗is managed‘.

                                                                                  94
The objective is to respect species-specific needs and to minimize stress and
suffering.
RLF; South Africa: ‗The objectives are to---‘ replaces ‗ The objective is to---‘.

Standards must require that:
 6.5.1. All relevant requirements of section 5.3 are complied with.
 IOAS, US: As a determination of what is "relevant" will need to be made, the IOAS
 will develop guidance on this issue.

 Grolink: Write this paragraph so it stands on its own.

 6.5.2. Animals are handled, transported and slaughtered in a way that minimizes stress
        and suffering, and respects species-specific needs.

Fibl/BBV, Switzerland: : Add - The handling of the aquatic animals outside the
water should be minimized to the act of slaughtering. The use of electrocution in the
water is allowed.

Mandatory practices
 6.5.3. Aquatic vertebrates must be stunned before slaughter.
 ICS, US: [slaughter] Eliminate this as a mandatory requirement. In some cases live
 bleeding of the fish results in a much higher quality product and the fish dies virtually
 instantly anyway. Also, the stunning method needs to be more specific. (Is clubbing a
 fish into unconsciousness acceptable?)

Prohibited practices
None specified

7. Processing and Handling
OMRI, US: In processed food products, there is no minimum organic content stated in
section 7.2, and the proposed IBS would permit all kinds of non-organic agricultural
ingredients. Based on experience with the cotton and apparel market a few years ago
before there were well-defined standards such as in the current IBS, one could easily
imagine a standard that would permit the organic label on a 1% organic content product,
with pesticide-treated and genetically engineered agricultural products as well as synthetic
ingredients not on the current Appendices included in the product. Genetically engineered
ingredients are not explicitly ruled out. The proposal also fails to prohibit ionizing radiation
and the use of pesticides and preservatives in post-harvest handling. There is no
distinction between organic and conventional processing methods.

NOFA, US: Processing and Handling: again, the wording would allow for many non-
organic and synthetic ingredients based on the special pleading of manufacturers.

Grolink: Is this chapter only for food processing, or also for feed processing, is
handling, storage and transport on the farms covered? If this chapter is only for food
processing, where are then other handing and transport covered? This is an old
problem with the IBS which has never been sorted out properly, hopefully it is time
now!

7.1.   General


                                                                                    95
Principle applied
Care, precaution and responsibility are the key concerns in management,
development and technology choices in organic processing.

The objective are
 To process products with care, avoiding unnecessary processing, maintaining the
   organic integrity and the authenticity of processed products, avoiding misleading
   the consumer by preserving the true nature of the product.
   Grolink: To process products with care, avoiding unnecessary processing,
   maintaining the organic integrity and the authenticity of processed products,
 To use techniques that are least damaging to the environment, reducing and
   treating waste and limiting the use of energy.
FAO, Italy: [waste and minimizing? the use of energy], or ensure energy efficiency?

Fibl/BBV, Switzerland: : Difficult the most cautious technique is not always the best
for the environment. It‘s not regulated in this form yet.

Standards must require that:
 7.1.1. Good organic manufacturing practices are followed throughout all organic
        processing.
 IOAS, US: This is more of a general principle rather than a standard. and will
 require interpretation by the IOAS for accreditation purposes.

 Fibl/BBV, Switzerland: : What is good organic manufacturing practice, definition?

 Grolink: Delete ―Good organic. What is ―good organic‖? Are there bad organic?

 7.1.2. Potential sources of product contamination as well as pollution and ecological
        contamination are identified and eliminated.
 IOAS, US: Unverifiable. It is unlikely that all potential sources can be eliminated
 although steps could be taken to minimise the risk.

 Grolink:
     Ecological contamination is a new interesting term, please define.
     Eliminated is a very strong word – replace with addressed

 7.1.3. Transparency and traceability of the organic processing chain are guaranteed.
 IOAS, US: Intention of standard unclear - is this referring to record keeping and the
 ability to do audits? IOAS guidance will need to be developed for accreditation
 purposes

 7.1.4. Substances and methods that chemically react with or modify organic products
        are restricted.
 Biokontroll Hungary: The positive list in the annex should be maintained.

 JR-UoM, US: In what ways are they restricted?]

 KRAV, Sweden: Delete ―and methods‖. Reason: A lot of normal processing methods,
 used for a long time do lead to chemical reactions. It is adding a substance that form a
 synthetic endresult that should be restricted, as well as any type of ―manipulation‖ that
 not is likely seen as trustworthy in the eyes of consumers.


                                                                                96
 BB, US: ‗restricted‘ is highlighted. How?

 ICS, US: [ORIGINAL followed with] A list of specific materials (and/or categories of
 materials) and their allowances and/or restrictions is maintained as part of the
 standards.

 IOAS, US: Language unclear. Presumed that chemically applies to "react" but not
 to "modify" as otherwise substances such as yeast and methods such as grinding
 or pulverizing would be restricted. Will require the IOAS to develop extensive
 guidance for accreditation purposes

 ARGENCERT, Argentina:
 Substances and methods that chemically react with or modify organic products.
 What about saponification in the production of organic soaps, or as an intermediary
 step in the production of an otherwise perfectly acceptable organic product (e.g.
 acid hydrolysis in organic gelatine production).

 Grolink: Allowed Substances and methods that chemically react with or modify
 organic products are defined.
 Restricted to what? Defined is better, is that the intention with the paragraph?

 7.1.5. Processing , handling and storage use physical , mechanical and biological
        methods
 KRAV, Sweden: Processing , handling and storage use physical , mechanical and
 biological/enzymatic Reason: enzymatic reactions are not ―biological‖ in a self-evident
 way and at least some enzymatic methods should be allowed) methods.

 IOAS, US: Apparent contradiction between 7.1.4 and 7.1.5 - the former discusses
 chemical reactions, the latter states that processing methods are restricted to
 physical, mechanical and biological methods.
 And would this standard permit controlled atmosphere packaging or storage?

 Fibl/BBV, Switzerland: : In general good, but processing steps which us e.g citric
 acid as an antioxidant is also a chemical process?!

Mandatory practices
 7.1.6. Organic products must be processed separately, in time and/or place, from non-
        organic products.
 7.1.7. Measures must be taken to enable traceability for preventing co-mingling of
        organic products with non-organic products in processing, storage and transport.
 Grolink: This seems like a mixture of two things, one is to have a traceability to check
 so that nothing has been commingled, the other is to not commingle the products.
 Change to - Measures must be taken to prevent co-mingling of organic products with
 non-organic products in processing, storage and transport,. which also enable
 traceability to ensure such contamination do not arise.

Prohibited practices
 7.1.8. Ionizing radiation
 7.1.9. Extraction of products, ingredients, additives and processing aids with other
        solvents than water , ethanol, plant and animal oils, vinegar, carbon dioxide and
        nitrogen.,


                                                                               97
 NASAA, Australia: [new item] Cleaning and handling of products with substances not
 listed on annex xxx

 Fibl/BBV, Switzerland: : Include prohibition of the use of GMO like in the EU regulation
 Be careful title is prohibited practice and extraction is listed, could confuse in this form.
 Whole section should be moved to chapter processing methods.

 Grolink: This is again a very detailed standard. Is this applicable for food production or
 also for feed production?

7.2.   Ingredients

Principle applied
Organic processed products are made from high quality raw materials.
Grolink: Organic processed products are made from organic raw materials.

The objective is to maintain the organic integrity of processed products by ensuring
that organic ingredients are used whenever possible.
BB, US: ‗used‘ is highlighted, to delte ‗whenever possibile‘.

NASAA, Australia: whenever possible

ICS, US: Delete ‗whenever possible‘

Standards must require that:
 7.2.1. Organic processed products are made from organic ingredients whenever
        possible.
 JR-UoM, US: Organic processed products are made from organic ingredients and
 approved processing aids that appear on the list established by the standard setting
 body..

 NASAA, Australia: whenever possible

 ICS, US: Delete ‗whenever possible‘

 Grolink: This is a too strong language, it is always possible to import a product from far
 away or buy a product for a very high price, but it will not make it a sellable organic
 product. Please use the old language from the current IBS 6.2.1 and simplify it. This is
 to make the IBS much stricter then the previous standard.

 7.2.2. The use of non-organic additives and processing aids is limited. For organic food
        the use of non – organic substances will be to the minimum extent unless they
        are legally required, alternatives are not available, and they are needed for
        particular nutritional purpose or essential technological need
 Biokontroll, Hungary: The standard-setting organization may authorize the use of such
 ingredients subject to a periodic review and reassessment. The materials shall not be
 genetically modified or derive from such products.

 JR-UoM, US: Followed wth: ‗ , and only if the substance appears on the approved
 substance list established by the standard setting body.‘

 ICS, US: Delete ‗or essential technological need‘

                                                                                  98
IOAS, US: If a substance is legally required, then whether alternatives are available
or they are needed for a particular nutritional or technological purpose is irrelevant.
Should this be "or" instead of "and"?
Would appear to permit addition of minerals, vitamins and such like as "needed for
particular nutritional purpose" which is contrary to consumer expectations of organic
food as wholesome, unadulterated food. The IOAS will need to develop an
interpretative document for accreditation purposes.

FAO, Italy: organic substances will be [undertaken/limited] to the minimum extent

NOFA, US: Section 7. 2. 2. would allow non-organic ingredients according to the
―need for particular nutritional or essential technological needs.‖ This is much too
loose a statement. In the US, manufacturers of organic yogurt insist that pectin and
powdered milk are essential ingredients, yet there is much higher quality organic
yogurt that contains neither additive. Other manufacturers claim that various
additives are necessary for this or that product resulting in the proliferation of foods
on the market that are much more highly processed than organic food ever needs
to be. A company that markets organic macaroni and cheese argued in favor of
allowing non-organic annatto saying: ‖orange colored macaroni and cheese is an
important element of our offering. Without annatto, our macaroni-and-cheese
products would be white.‖ Clearly this company‘s view of essential technological
needs is different from mine. Does the world really need the organic ―Twinkie?‖ The
NOP denial of National Organic Standards Board control over ―food contact
substances‖ may soon bring us organic coke and pepsi.

Fibl/BBV, Switzerland: : Terms/conditions have to be defined when non-organic
ingredients can be used!

Grolink: There are a few additives and processing aids available in some parts of the
world but so far there are very few. It is too strict to require organic quality yet. The
second sentence is talking about conventional ingredients – but it is unclear if it is only
additives and processing aids – or all conventional ingredients. How will it be decided
which additives and processing aids which can be used?
A third issue is if the it is any limitations to use additives and processing aids if they are
of organic quality or not, an organic nitrate for example, sodium benzoate from
lingonberries are probably quite easy to get, but even if organic should it be used in
organic products?

Change to - The use of additives and processing aids is limited to the minimum
necessary unless they are legally required, alternatives are not available,

7.2.3. Substances in organic processed products are from natural sources only, all
       other substances used must be on the standards setting body‘s list of permitted
       substances
SA, UK: ‗standards setting body‘s list of permitted substances‘ is highlighted. See
comments under Section C.

IOAS, US: Contradiction - there is a restriction to "natural substances only" but then
there is a reference to "all other substances" Should this be "ingredients in organic
processed products...."?


                                                                                   99
 Grolink: What is a substance?
 In the GMO chapter there is a processing agent, above are additives and
 processing aids, are they the same? Natural, see comment above to 7.2.2

 7.2.4. Microorganisms and microbiologically produced ingredients are grown on
        substances that consist entirely of organic ingredients and permitted substances
 OTA US: We approve of the intent of the requirement, but it would render the NOP
 non-compliant. We suggest adding, ―when available.‖

 RSTWG, Sweden: By this standard there will be required to have organic yeast for
 example for beer or bread, there is very little organic yeast available in the world. The
 RSTWG find the requirement of organic ingredients for substrates to grow
 microorganisms almost impossible to fulfill. Please take 7.2.4 out or give a possibility to
 use conventional substances when organic is not available.
 KRAV, Sweden: Microorganisms and microbiologically produced ingredients are grown
 on substances that consist entirely of organic ingredients and permitted substances,
 where possible. Reason: This is a recommendation from IBS 2005 that is difficult to
 have as a must, as it leads to a lot of more investigation into the production methods,
 and limit possible use of many ingredients.

 ICS, US: [substance] Does this mean that a cheese culture, enzyme, or other
 fermentation agent needs to be grown on organic substrates? Highly unlikely for the
 foreseeable future.

 Fibl/BBV, Switzerland: : Origin of microorganisms and microbilogically produced
 ingredients: Much stronger than the label organisations like Bio Suisse, Naturland,
 Bioland!

 Grolink: This is again a too strict standard, probably works in one way or another in
 central Europe but not for an international benchmark standard. What is a permitted
 substance?
 Change to Microorganisms and microbiologically produced ingredients are grown on
 substrates that consist entirely of permitted substances

Mandatory practices
 7.2.5. All ingredients must be in compliance with the labeling provisions.
 KRAV, Sweden: We do not understand this at all, how can an ingredient comply
 with a provision?

 Grolink: Delete - This is not understandable, in what way?

Prohibited practices
 7.2.6. The use of the same ingredient in organic and non-organic quality in products.
 7.2.7. The use of substances to correct improper processing.
 OTA US: The term ―improper processing‖ is overly vague. We suggest substituting NOP
 205.600(b)(4) verbiage: ―The use of any substance primarily as a preservative or to
 recreate or improve flavors, colors, textures, or nutritive value lost during processing,
 except where the replacement of nutrients is required by law.‖

 SA, UK: ‗improper‘ is highlight. sure what this means. Needs defining.



                                                                                100
 RLF, South Africa: 7.2.6 The use of substances to correct improper processing.
 Deleting Item 7.2.7

 JR-UoM, US: New Item: The use of genetically engineered ingredients and processing
 aids.

 OMRI, US: The operator shall not use any non-organic ingredients and processing
 aids in organic food that do not appear in Section C, Table 3.
 The operator shall not apply any crop protectant to harvested organic crop that does not
 appear
 in Section C Table 2.
 The operator shall not apply any disinfectant or fumigant to organic food that does not
 appear in
 Section C Table 4.

 BB, US: Inserting two new itesm to be numbered:
    Agricultural ingredients in organic processed foods shall be organically produced.
    The operator shall not use non-organic ingredients and processing aids that do
      not appear in Section C, Table 3.

 NASAA, Australia: The use of ingredients other than those allowed under labeling
 provisions in annex xxxx that are not organic

 ICS, US: [processing]. ―Improper‖ needs to be defined.

 IOAS, US: This is not verifiable - what constitutes "improper" processing. The IOAS
 would need to develop substantial guidance on this issue.

 Fibl/BBV, Switzerland: : Whole sentences like in the other sections should be
 written

 Grolink: Delete - This is not easy to define, who defines what is improper
 processing?

7.3.   Processing Methods

Principles applied
Technologies in organic processing ensure that the finished product is healthy, safe
and produced in an ecologically sound manner. The Precautionary Principle governs
the introduction of new organic processing technologies.

The objective is to ensure that processing methods do not compromise the organic
integrity of the final product and, in the case of food, ensures the nutritional value is
maintained.
RLF; South Africa: „The objectives are to---‘ replaces ‗ The objective is to---‘. ‗food,
to ensure‘ replaces ‗food, ensures '.

Standards must require that:

Fibl/BBV, Switzerland: : Minimum and careful processing is not mentioned as in
Codex and in the EU.


                                                                                 101
7.3.1. Practices used in organic processing do not contaminate the environment.
Fibl/BBV, Switzerland: : Difficult the most cautious technique is not always the best for
the environment. It‘s not regulated in this form yet.

Grolink: This is already covered by the general standards.

7.3.2. Processing methods are kept to a minimum.
SACL, UK: SACL: need guidance on minimum

RSTWG, Sweden: The RSTWG is unclear what this standard means, how will it be
interpreted for coffee roasting? Only mild/light roast is allowed? What about instant
coffee?

KRAV, Sweden: Take away! Reason: it is manipulative methods that not shall be
allowed. It must be possible to prepare for example a ―ready-toe eat meal‖. Perhaps
criteria are needed to specify methods and substances that are OK? (Compare with
7.3.5)

WSDA, US: Delete – not appropriate, how is this measured?

ICS, US: [minimum] Undefined and unenforceable as written. Specifically
restricting individual processes is an option.

IOAS, US: Unverifiable. IOAS guidance will need to be developed for accreditation
purposes.

Grolink: This is too unclear and vague. Is it allowed to use frozen berries to make a
jam, can the jam be boiled or does it have to be made without heating (it is possible)?

7.3.3. Only biological, mechanical or physical processing techniques are used.
IOAS, US: How does this differ from 7.1.5?

7.3.4. Any additives, processing aids or other substances that are used and modify
       organic products shall be restricted and must be on the standards setting body‘s
       list of permitted substances
SA, UK: ‗standards setting body‘s list of permitted substances‘ is highlighted. See
comments under Section C.

Biokontroll, Hungary: but a general positive list should be maintained

Grolink: Already covered above, remove

7.3.5. Techniques or substances that negatively affect the product must be restricted.
SA, UK: ‗restricted‘ is highlighted. Restricted to and for what?

KRAV, Sweden: Again: It is manipulative techniques that not shall be allowed. Do we
need some criteria similar as Section C for methods and techniques?

WSDA, US: How do you define ―negatively affect?‖, Undefined section – delete.

ICS, US: [new clause] Techniques that chemically modify or remove parts of the whole
raw food material are restricted.

                                                                             102
 IOAS, US: Unverifiable. IOAS guidance will need to be developed for accreditation
 purposes.

 Fibl/BBV, Switzerland: : All processing methods have a positive e.g. shelf life or a
 negative effect: e.g. lost of vitamins. Must be defined clearer with this article
 homogenisation for milk must be restricted. We propose to cancel this point.

 Fibl/BBV, Switzerland: : Add - The following conditions of storage are permitted (for
 allowed substances in these conditions, see Appendix 4):
 a. controlled atmosphere;
 b. temperature control;
 c. drying;
 d. humidity regulation.
 Ethylene gas is permitted for ripening.

 Grolink: Unclear in many ways, take away or develop.

Mandatory practices
None specified.

Prohibited practices
 7.3.6. The use of filtration techniques that chemically react with or modify the organic
        product at the molecular level.
 7.3.7. The use of filtration equipment that contains asbestos.
 BB, US: To insert a new item: The operator shall not use ionizing radiation.

 NASAA, Australia: Two new items: 1)The use of substances not appearing on annex
 xxxx
 2) The entry of contamination of any kind iton the process or product that results from
 lack of precaution by the operator

 ICS, US: [new clause] The addition to product formulations of flavoring agents or
 coloring agents that are intended to mimic and/or replace actual agricultural ingredients.
 Use of flavoring/coloring agents in this manner is not compatible with the Principles of
 Organic Agriculture – namely it discourages use of organic ingredients and allows
 product manufacturers to get by with less of them by replacing them with specific
 chemicals. This practice is becoming increasingly widespread.

 Fibl/BBV, Switzerland: : Why is irradiation not excluded?

7.4. Packaging and Containers
OIA, Argentina: Packaging, open to interpretation.

Principle applied
Organic products are packaged in a manner that has minimal adverse impact on the
product and on the environment.

The objective is to maintain the organic integrity of the product while efficiently and
responsibly using resources.



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Grolink: The objective is to maintain the organic integrity of the product as well as
efficient and responsible use of resources.

Standards must require that:
 7.4.1. Packaging and storage/transportation containers do not contaminate the organic
        product they contain.
 7.4.2. Packaging materials are reusable, recycled, recyclable and biodegradable
      whenever possible.
 ICS, US: [possible] Difficult to enforce.

 IOAS, US: New content. There has not hitherto been a requirement to use
 reusable, recycled, recyclable or biodegradable packaging - it is almost always
 possible to do so, though may be economically unfeasible, so the addition of
 "wherever possible" is superfluous. However this is a big change from the 2005
 norms..

 Fibl/BBV, Switzerland: : This is not practiced in the moment: Practice is the
 packaging with the best protection for the product.

 Grolink: Whenever possible is too strong language. Replace with:
 7.4.2.     Measures are taken to reuse or recycle packaging materials
 7.4.3.     Use of non-recyclable and non-biodegradable packaging materials is
 minimized.

Mandatory practices
 7.4.3. Using only necessary packaging.
 SA, UK: ‗necessary‘ is highlighted. Necessary for what? Needs defining.

 ICS, US: [packaging] If this is to be a mandatory practice, then ―necessary‖ needs
 to be defined.

 IOAS, US: Unverifiable - what constitutes "necessary IOAS would need to develop
 some sort of guidance or interpretation on this issue.

 7.4.4. Measures to ensure that all storage and transportation containers are not
        contaminated with non-allowed substances.
 OTA US: We suggest changing ―non-allowed‖ to ―prohibited‖ in the two above
 statements

 Grolink: Delete 7.4.3 and 7.4.4 - Non specific. General requirement already addressed
 above]

Grolink: Reading this chapter a non-allowed substance is probably additives and
processing aid which is not allowed. There is different language in different chapters,
somewhere prohibited substances is used. A general question is why contamination
is only mentioned for storage and transport but not for processing. Again – it would
be better to have a general section on contamination.

Prohibited practices
 7.4.5. Using packaging that has been treated with non-allowed substances.
 OTA US: We suggest changing ―non-allowed‖ to ―prohibited‖ in the two above
 statements.

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 BB, US: Update the original item: Using packaging that has been treated with
 substances that do not appear on Section C, Table 4.

 Grolink: Unclear, is there a list for non-allowed substances, or a list for allowed
 substances

7.5.   Cleaning, Disinfecting, and Sanitizing Food and Food Processing Facilities

Grolink: Why is this only for food? Is the whole chapter for food only? What about
feed? Fibers?

Principles applied
Organic processing produces high quality products under hygienic conditions while
preventing significant risks and protecting the environment.

The objective is to maintain the organic integrity of the product while producing
hygienically safe food products and minimizing the negative impact of cleaning and
sanitation on the environment.
NASAA, Australia: sanitation [products] on

Standards must require that:
 7.5.1. Management systems for cleaning and disinfecting surfaces, machinery and
      processing facilities are in place.
 7.5.2. Measures are taken to protect the organic integrity of the product by preventing
         contamination from pollutants and cleaning, disinfecting and sanitizing
         substances.
 IOAS, US: 7.5.1-7.5.2: Unclear what a management system is in this context and
 how the standard differs in essence from 7.5.2. Surely a management system
 detailing how equipment must be cleaned is a "measure" so suggest that 7.5.1 is
 superfluous or could be combined with 7.5.2

 Grolink: This would again fit better in a general clause.

 7.5.3. Measures are taken to ensure high hygiene quality of the products.
 Grolink: Measures are taken to ensure hygiene quality of the products meets applicable
 food and feed regulations.

 7.5.4. Only water and substances not deleterious to organic food can be used in direct
        contact with organic produce after harvest as cleaners or disinfectants. All other
        substances are only allowed if legally required.
 SACL, UK: SACL needs guidance on measures

 NASAA, Australia: Only water and listed substances can be used in direct contact
 with organic produce after harvest as cleaners or disinfectants. All other substances are
 only allowed if legally required.

 ICS, US: [new expression] Only water and substances listed for direct addition to
 organic food (i.e., as additives or processing aids) can be used in direct contact with
 organic produce after harvest as cleaners or disinfectants. All other substances are only
 allowed if legally required.



                                                                                105
 IOAS, US: Does not regulate gums and other coatings which are currently
 permitted in the IBS. IOAS guidance would need to be developed for accreditation
 purposes.

 Fibl/BBV, Switzerland: : What does ―not deleterious‖ mean?

Mandatory practices
 7.5.5. Substances used to clean, disinfect and sanitize food handling equipment must
        be clearly separated from those applied directly to food.
 IOAS, US: The meaning of this standard is unclear. What is it intended to mean?

 7.5.6. Flushing, or a similar intervening event, must be applied after the use of any
        cleaner, sanitizer or disinfectant before organic products can be allowed to come
        into contact with any surface or equipment.
 NASAA, Australia: Use of substances not proscribed in relevant annex(s)

 ICS, US [new clause] Flushing or purging of equipment that is shared with non-organic
 products must take place if no other sanitation methods or materials are used, before
 organic products can be allowed to come into contact with any surface or equipment.

 IOAS, US: This would exclude the use of any terminal sanitiser, no matter how
 benign – even if the substance in question were organic

 BETP, Philippine: Under 7.5.6, mentioning cleaners, sanitizers used (how organic
 are these?) before contamination with organic products.

 Grolink: is this not covered well enough by food legislation? Quite detailed
 compared with other chapters. Consider to take away

Prohibited practices
None specified.
RSTWG, Sweden: The text in the EAOPS is better then the above proposed text.
The EAOPS standards are too detailed to fulfill the same task as the IBS but the
essence can be used for the IBS. It is also better to handle the risk of contamination
separately and generally as proposed earlier.

BB, US: Updating the original item: 7.5.7 Use of any substance on food that is not on
Section C, Table 4.

7.6.   Pest and Disease Control

Fibl/BBV, Switzerland: : Very general, not clear what it means

Principle applied
Pests and diseases are controlled in ways that avoid adverse health and
environmental effects.
JR-UoM, US: Pests and diseases are controlled in ways that avoid adverse health
and environmental effects and protect the integrity of organic products.

The objective is to protect organic products from pests and diseases by using
proper cleaning, sanitation and hygiene without compromising the health of humans
and the environment and while upholding organic integrity.

                                                                                106
Grolink: The objective is to protect organic products from pests and diseases by
using proper cleaning, sanitation and hygiene measures without compromising the
health of humans and the environment

Standards must require that:
 7.6.1. Pests are managed according to a hierarchy of practices starting with prevention
        and then with physical, mechanical and biological methods.
 JR-UoM, US: with prevention [sanitation and exclusion] and then—

 7.6.2. Before any pest or disease control is undertaken the implications of its use on the
        ecology is considered and issues arising are addressed.
 SA, UK: ‗ecology‘ is highlighted. Ecology of what?

 RLF, South Africa: ‗the ecology are considered‘ replaces ‗ the ecology is considered--‘

 WSDA, US: Too broad of a statement – what do they mean by this?, unenforceable.

 IOAS, US: Is the standard requiring an environmental impact assessment for any
 and all measures utilised for pest and disease control? If so, this is new content as
 there was no such requirement in the 2005 norms. It is also pretty burdensome on
 processors.

 Grolink: Before any pest or disease control substance is used the implications of
 its use on the ecology is considered and issues arising are addressed.

 7.6.3. Processing facilities are designed in such a way that pest infestation is avoided.
 ICS, US: [new expression] Processing facilities are designed in such a way that pest
 infestation is avoided, or that existing facilities are adapted or improved to avoid such
 infestation.

 IOAS, US: Does not appear to be a workable standard. Pest infestation is
 sometimes unavoidable.

 Grolink: This can be included in 7.6.1 and can be rewritten to cover all kind of
 facilities.

 7.6.4. Measures are taken to protect organic products from being contaminated with
        pest control substances. In particular, procedures for ensuring the maintenance
        of the organic status of products must be in place where prohibited substances
        are used.
 SACL, UK: SACL: guidance needed

 SA, UK: MAINTENANCE is replaced with WITHDRAWAL.

 KRAV, Sweden: Measures are taken to protect organic products from being
 contaminated with pest control substances. In particular, procedures for ensuring the
 maintenance of the organic status of products must be in place in cases when
 substances prohibited in organic production are used.

 IOAS, US: Assessment would require the development of IOAS guidance for
 accreditation purposes.

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Mandatory practices
None specified
JR-UoM, US: [New item] Contact of pesticides used for facility pest management
with organic products and packaging.

NASAA, Australia: Active prevention of pests through structural and operational
management

Prohibited practices
None specified
BB, US: Comments on Mandatory practices and Prohibited practice: Inserting
three new items: Application of any crop protection material that does not appear in
Section C Table 2 on harvested crops.
 Application of any disinfectant or fumigant that does not appear in Section C
   Table 4.
 Contact of pesticides used for facility pest management with organic products and
   packaging.
   So now it is OK to fumigate with ethylene methyl bromide, aluminum phosphide,
   etc.?

7.7. Textile Fiber Processing
FAO, Italy: Attention should be paid to the fact that there is no clear international
standard on organic fibers. Attention should be made to the interest of the parties to
incorporate such a detailed list of standards

Principle applied
Organic fiber is processed from organic raw materials in an environmentally sound
way that takes into account the entire production cycle and the life cycle of the
product.

The objective is to ensure the manufacture of organic textiles does u upholds the
organic integrity of the product, and protects the environment and end user.
RLF, South Africa. The objective is to ensure the manufacture of organic textiles
upholds the organic integrity of the product, and protects the environment and end
user.

Grolink: The objective is to ensure the manufacture of organic textiles upholds the
organic integrity of the product, minimise impact to the environment and end user.

Standards must require that:
 7.7.1. Whenever possible, organic fiber products are processed using only mechanical,
        physical and/or microbiological methods.
 IOAS, US: New content. This was previously a recommendation. IOAS guidance
 for exceptions will need to be developed for accreditation purposes.

 7.7.2. A management system is in place that ensures any effluents resulting from wet
        processing are properly treated before being released into the environment.
 IOAS, US: New content. Standard is undeveloped with regard to "properly treated"
 which will make assessment very difficult and IOAS will need to be developed for
 accreditation purposes.



                                                                                108
7.7.3. All chemical substances used in organic fiber processing are limited to the
       minimum quantity necessary to achieve the desired effect.
IOAS, US: New content. Previously a recommendation. IOAS guidance on
acceptable chemical substances will need to be developed for accreditation
purposes.

BETP, Philippine: To be consistent that organic products are indeed without
chemicals, let us change the word "chemical substances" (is this allowed) under
7.7.3 for organic fiber processing....

7.7.4. All substances used meet the criteria for textile processing substances in Section
       C and must be on the standards setting body‘s list of permitted substances.
SA, UK: ‗Section C‘ and ‗standards setting body‘s list of permitted substances‘ are
highlighted. See comments under Section C.

IOAS, US: See general comment on C.

7.7.5. Recycling of wet treatment baths is allowed only when it leads to environmental
       or economic advantages.
ICS, US: [advanges] Linking any requirement or restriction that is potentially solely
for economic advantages is dangerous – suggest deletion of this or appropriate
revision.

IOAS, US: Economic and environmental advantages may be in opposition. The
standard states "or". Is it acceptable that economic advantage takes precedence
over environmental?

FAO, Italy: [to environmental or economic advantages] This indication may betoo
broad: should precedence be given to environmnetal advantages over economic
ones?

7.7.6. The use of treatment baths that have been in contact with non organic fiber
       products is allowed only when not using them leads to environmental or
       economic disadvantages. In this case the standard must require that provisions
       be taken in order to avoid mixing of conventional raw materials with the organic
       ones.
ICS, US: [ disadvanges] This could lead to inadvertent contamination of the organic
fibers with residues from conventional products.

IOAS, US: Contamination of the organic fibre product by substances contained in
the non organic product e.g. pesticide residues is not addressed and could lead to
a contaminated organic product. This would be contrary to consumer expectations.

7.7.7. Any allowance of sodium hydroxide for mercerizing must be accompanied by
        requirements for recycling and establish a recovery rate.
SA, UK: Why only for NaOH? Seems inconsistent.
Grolink: Why keeping this detail, sodium hydroxide is not the worst chemical used in
textile processing

7.7.8. Only printing methods based on water or natural oils are permitted.
7.7.9. Fiber processing must comply with sections 7.1, 7.5 and 7.6.
Grolink: 7.5 is clearly written for food processing

                                                                             109
 7.7.10.    Labeling of textiles shall comply with the requirements of Chapter 8
        ―Labeling.‖
   ARGENCERT, Argentina: Is it necessary to repeat this here?

   Grolink: Delete - Take away – there are no other references to the labeling
   chapter for any other kind of production.

Mandatory practices
 7.7.11.    An environmental plan for improving the environmental performance of the
      production unit must be in place and complied with.
 IOAS, US: Does not preclude the use of non biodegradable, bio-accumulating
 and/or heavy metal input products.

 Grolink: This is stricter then for other kind of production. Are there reasons for
 that?

 7.7.12.     Color residues shall be recycled or disposed of in a safe way.

 Prohibited practices
 BB, US: This is actually more restrictive than what is proposed for food!

  7.7.13.    Use of chlorine and perborate for bleaching.
  7.7.14.    The use of aromatic solvents.
  SA, UK: Are these all? Seems a very limited list of prohibited practices.
8. Labelling
ARGENCERT, Argentina: Labels for products in transition is not mentioned
anywhere in the Benchmark Stds.

Principles applied
Organic agriculture should ensure fairness at all levels and to all parties, including –
consumers.
Appropriate labeling of organically produced products provides transparency,
develops consumers` trust and helps to define and identify organic quality.
FAO, Italy: Consideration could be given to labelling also substances used for
organic production. It could, for example, be suggested that substances allowed to
be used in organic production bear some indication that they are suitable for organic
production.

The objective is to ensure that organic products are clearly identified, to provide
relevant information in order for consumers to make informed, conscious choices and
to avoid misleading them.
RLF, South Africa: The objectives are to ensure that organic products are clearly
identified, to provide relevant information in order for consumers to make informed,
conscious choices and to avoid misleading them.

Standards must require that:
 8.1. Any item labeled as ―product of organic agriculture‖, or an equivalent protected
       term, fully complies with the applicable organic standards.
 Fibl/BBV, Switzerland: : 8.1, new proposal: Any item labeled as ―organic‖, or any
 equivalent term suggesting to the purchaser that the products complies with the


                                                                                 110
standards for organic production shall fully comply with the applicable organic
standards.

Grolink: Delete - This standard can be interpreted in different ways. it can be seen as a
circle argument or it can be interpreted as it is not in the power of the operator or the
certification body to control the statement ―product of organic agriculture‖ and therefor
the standard can not be enforced. There is not such a protected term in many part of the
world

8.2.  Labels contain information that ensures traceability in the organic product chain
      and full disclosure of ingredients and whether they are organic.
KRAV, Sweden: It is allowed to make exceptions for herbs and spices.
Reason: spices & herbs are used in very small amounts. Information that ensures
traceability for all of them makes the information on the label to large.

IOAS, US:_ IOAS guidance to be developed for accreditation purposes with regard
to how full traceability could be accomplished

Grolink: Traceability by who, consumers, processor, etc? Not possible to ensure
traceability by consumers through label otherwise the label will have so many
details.
Change to - Labels contain information and full disclosure of ingredients and
additives whether they are organic or not.
8.3. Where non-organic products and ingredients are used they must be clearly
       identified as such.
ARGENCERT, Argentina: Labelling should require identification of which ingredients
ARE organic, not those that are NOT. This is according to the regular international
standards wording that avoids the negative implications of labelling a product ―not
organic‖.

Grolink: Delete - What is ―products‖ here? Content covered in 8.2

8.4. Processed products are categorized into three groups (defined below) and
     labeled accordingly:
BB, US: Contradicted by the section on Ingredients

FAO, Italy: It could be noted that the EC proposal of new regulation eliminates the
category of products containing a 70 to 95 % of organic ingredients. (Proposal for a
Council Regulation on organic production and labelling of organic products
(COM(2005)0671 - C6-0032/2006 - 2005/0278(CNS))

       a. 95 to 100% of the ingredients (by weight) are organic. These products
          may be labeled as ―organic‖.
       b. Less than 95% but more than 70% of the ingredients (by weight) are
          organic. These products cannot be labeled as ―organic‖, but phrases such
          as ―made with organic ingredients‖ can be used, provided the proportion
          of organic ingredients is clearly stated.
          Fibl/BBV, Switzerland: e: Delete 8.4b
       c. Less than 70% of the ingredients (by weight) are organic. These products
          cannot be labeled as ―organic‖, but individual ingredients may be called
          ―organic‖ in the ingredients list.


                                                                             111
        KRAV, Sweden: Followed with ‗and phrases such as ―the meat in this
        product is produced according to organic standards‖ are allowed. ‘ Reason:
        proper information regarding organic ingredients shall be allowed.

        Notes on calculating percentages:
         Water and salt are not included in the percentage calculations of organic
           ingredients.
        FAO, Italy: Consideration could be given to the possibility of excluding,
        together with water and salt, other substances that are added to food
        products but cannot be obtained by organic methods (such as vitamins,
        minerals and other substances).

          For textiles the percentages refer to the total weight of the fibers and do
           not include the weight of the non-textile accessories such as buttons and
           zippers.
         Any reference to GMOs on labels must be limited to stating that the
           production and processing methods themselves have not used GMOs.
        Grolink: Delete - The last bullet can be taken away, it is not really needed in
        a benchmark standard. If kept it has to be a standard of itself and not a note
        on percentages.

Mandatory practices
 8.5. Including on the label
        the identity of the person or company legally responsible for the product
        the identity of the control body responsible for the organic certification.
        the origin of the raw material.
 OTA US: Requiring ―origin‖ of the raw material is both vague and extremely difficult if
 not impossible for many processed products, especially if they are multi-ingredient and
 there are many suppliers. It gets even trickier when processed products are used as
 ingredients. We suggest that the requirement that a means of contacting the
 manufacturer should suffice, or if absolutely necessary, the location where the final
 product is manufactured.

 COG, Canada: There are also inconsistencies where this new IBS is more prescriptive
 than the old. Also 8.5 mandatory practices for labelling – ―Include on the label the origin
 of the raw material‖ – what does this mean? It sounds simple but what is actually
 wanted here?

 RSTWG, Sweden: Deleting ‗the origin of the raw material. ‘
 The requirement for labelling of the origin of raw material is to day not a problem for
 the operators in our countries but with a bigger trade and more processing this will
 likely be a hindrance of the development. We are in favour of a voluntary labelling
 of origin. Delete the last bulletpoint.

 JR-UoM, US: [2 New items]
       Correct use of the term ―organic‖
       A list of all ingredients

 KRAV, Sweden: Followed with ‗when possible. ‘Reason: It is difficult to have this
 requirement as a must, as it is costly to change labels every time the origin of the
 raw material changes.

                                                                                112
 IOAS, US: New content: The origin of the raw material was not previously a
 requirement.

Grolink: Delete last bullet point - Certification body is better then control body. The
origin of the raw material is a huge change of the IBS and makes it much stricter and
more complicated. Let this be voluntary
Prohibited practices
  8.6. Labeling products as ―GMO-free‖.
  IOAS, US: IOAS guidance to be developed for accreditation purposes as the
  standard now lacks the current clarification that conformance with organic
  standards does not permit a product to be labelled as "gmo free" -but that an
  organic product which has had a gmo free verification should be permitted to be so
  labelled.

 Grolink: Delete - This is also a stricter requirement. Addressed in 8.5

9. Social Justice
In general: Paragraph 9 on Social Justice provides a good guideline on what a standard
should cover in terms of social accountability.

Principles applied
Organic agriculture builds on relationships that ensure fairness with regard to the common
environment and life opportunities of employees and workers.

The objective is to achieve a social environment of fairness, safety, equity, respect
and justice for all participants of organic product chains; ensuring equal opportunities,
avoiding discrimination and addressing situations of risk and real social costs.
RLF, South Africa: ‗in organic product‘ replaces ‗of organic products‘.
ARGENCERT, Argentina: The last sentence of the Objective is not clear. Which are
the situations of risk and real social costs?

Standards must require that:
 9.1. In countries with no social legislation, organic operations have a social policy set
        in place that is at least compliant with International Labor Organization and other
        relevant international law.
 IOAS, US: IOAS guidance will need to be developed for accreditation purposes.
 The standard does not address countries which might have social legislation which
 is not compliant with the ILO. Relevant international law is a meaningless phrase
 unless the law is specified.

 FAO, Italy: [new expression] In countries with no or weak? social legislation, organic
 operations have a social policy in place that is at least compliant with the standards of
 the Convention of the International Labor Organization and other relevant international
 law standards.

 Living Planet, Ukrania: Listing specific legislation and / or normative documents, such
 as EU Directives and International Labor Organization (e.g., clause 9.1 of the present
 Draft);

 Grolink: What about a not enforced social legislation? Change to organic operations
 have a social policy set in place that is at least compliant with International Labor


                                                                                 113
 Organization and other relevant international law in countries where the equivalent
 legislation is not enforced.

 9.2.   Employees and workers have the freedom to associate, the right to organize and
        the right to bargain collectively.
 9.3. All employees and workers – regardless of any criteria, e.g. gender, sexual
        preference, race or creed – enjoy equal opportunities and non-discriminating
        treatment.
 9.4. Employees and workers are guaranteed basic human rights and fair working
        conditions.
 Fibl/BBV, Switzerland: : Not regarding whether a national social legislation is in force,
 the base line in any standard should be the ILO Convention. To make reference to
 ‗other relevant international law‘ is not helpful for the standard setting body, since
 standard setters in general do not want to make a replica of existing official
 ordinances/law.

 9.2-9.4. these three paragraphs are extracts of the ILO convention. It can be somewhat
 irritating, to have these three explicitly highlighted here and in 9.1. referring to a general
 compliance with all ILO Convention paragraphs. The same is true by explicitely exluding
 prohibited practises in 9.5.-9.7.: these paragraphs as well are part of the ILO
 convention.

 Grolink: 9.2 - 9.4 can be part of the social policy mentioned above. If it is the standard
 can be removed and put in the mandatory practice.

Mandatory practices
None specified.

Prohibited practices
 9.5. Any production based on the violation of basic human rights and clear cases of
       social injustice.
 9.6. Any type of forced or involuntary labor.
 9.7. Child labor without guaranteeing the child‘s integral well-being.
 ICS, US: [integral well-being] What does ―integral well being‖ mean?

 IOAS, US:_ IOAS guidance to be developed for accreditation purposes as the
 standard requires further elaboration as to the meaning of "integral well-being" and
 how it might be assessed.

 FAO, Italy: Should there be stronger language on child labour? Should it be
 allowed at all?Section C - Criteria for the Evaluation of Substances Used in
 Organic Production and Processing
 OFRC, China: I didn't find the appendix for the materials allowed using in organic
 growing and processing too. The aim of organic production and processing can't be
 seen in this draft, which I think is very important for organic movement.

 AOEL, Germany: We see it positive to find a new way of dealing with the technical
 annexes. Especially the substance lists need more flexible handling in dynamic
 growing markets. Also the different cultural backgrounds and the very different
 stages of development in organic farming and processing is asking for more
 flexibility in the area of substance lists.


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We propose to introduce a similar tool as Codex Alimentarius has developed. The
codex guidelines include so called ―indicative lists‖. This means lists which are
demonstrating a world wide consensus on substances used for organic production.
But indicative lists are not closed lists. The Codex allows each country to add
substances, if they have evaluated this substances in accordance to the given
criteria‘s, to their national list. This approachcould easily be adopted to the given
IBS by using the actual substance list as the ―Indicative list‖. Further on a standard
has to be set which enables companies and labeling organization to evaluate
further substances for their on lists by using the given IBS criteria‘s? The positive
evolutions should be reported to the SC. If the ACB want they can use the
―indicative lists‖ as basis for compliance.

The IBS has strong and clear evaluation criteria in place! In the new draft the
presented criteria are a step backwards. In the new concept the evaluation criteria
has a much higher importance for the whole standard system! Therefore we ask for
a further development of evaluation criteria and not for less clear and weakened
once.
Clear criteria and an open, transparent process are necessary for a permitted
substance list to be valid.

BBV, Switzerland: Annexes to be maintained as indicative and commonly agreed
lists
BbV acknowledges the need to find a new way of dealing with the technical
annexes. Especially the substance lists need more flexible handling in dynamically
growing markets considering the different cultural backgrounds and the very
different stages of development in organic farming and processing.
On the other hand it is important to maintain the current positive lists for inputs in
crop production and in processing to allow for a common understanding and
interpretation of the criteria.
BbV propose to introduce a similar approach as Codex Alimentarius by including so
called ―indicative lists‖. Such lists demonstrate a world wide consensus on
substances used in organic production but these are not closed lists. The Codex
allows each country to add substances to their national list, if they have evaluated
these substances in accordance to the given criteria. This approach could be easily
adapted to the current IBS by using the actual substance list as the ―indicative list‖
and by clarifying that standard setting organizations may add further substances on
the basis of the IFOAM criteria.

Fibl, Switzerland: Annexes to be maintained as indicative and commonly agreed
lists
FiBL acknowledges the need to find a new way of dealing with the technical
annexes. Especially the substance lists need more flexible handling in dynamically
growing markets considering the different cultural backgrounds and the very
different stages of development in organic farming and processing. On the other
hand it is important to maintain the current positive lists for inputs in crop production
and in processing to allow for a common understanding and interpretation of the
criteria. FiBL propose to introduce a similar approach as Codex Alimentarius by
including so called ―indicative lists‖. Such lists demonstrate a world wide consensus
on substances used in organic production but these are not closed lists. The Codex
allows each country to add substances to their national list, if they have evaluated
these substances in accordance to the given criteria. This approach could be easily
adapted to the current IBS by using the actual substance list as the ―indicative list‖

                                                                                 115
and by clarifying that standard setting organizations may add further substances on
the basis of the IFOAM criteria.

Fibl/BBV, Switzerland: In general OKAY.
It is not clear how the criteria will be interpreted in individual standards, thus it is not
clear which substances will be allowed. However, the absence of certain
substances from organic farming is essential to draw a distinct line between organic
and non-organic, and to safeguard the integrity of organic farming. It would be
better if the present lists of substances would be retained, at least in the form of
―substances such as…‖

LOS: No positive lists: IFOAM has played a crucial role in establishing a line
between conventional and organic agriculture, by setting up positive lists in the
1980ties. I agree, that positive lists must be set-up in a way, to allow producers in
other climatic regions than those of Northern Hemisphere, to adequately manage
there production. I very much disagree with the concept to drop the positive listing
requirements for synthetic pesticides. There is no need, to open up organic
agriculture to new fungicide formulas of the big agrochemical players. There have
been cases, like for example the phosphoric acid discussion, where IFOAM
members had conflicting ideas and where it was healthy, to have an open
discussion trigged by the necessity to change the IFOAM Basic Standards. To drop
the positive listing requirement, means, to create a culture of hidden issues, never
discussed within the IFOAM membership, but somehow left to the non-transparent
process of the practical case to case application in the accreditation process. I think
it is not wise, to drop the idea of the leadership in the organic agriculture movement
of IFOAM. IFOAM should continue to work on a common global consensus on the
substances permitted to be used as pesticides or as synthesis nitrogenous
fertilizers in organic production. Some may say, that they perceive positive lists as
an obstacle to progress. This is an intellectually challenging argument, since
nobody whishes to hinder progress, but this idea is better placed in a system of
integrated agriculture. Organic agriculture, I think, should be more conservative,
just to rather act on the safe side.

OTA US: This section is generally fine—consistent with the NOP National List
criteria. Consider adding that the list of substances may be either open or closed,
so long as all permitted substances can be shown to meet the applicable criteria.

SACL, UK: This section will prove very difficult to inspect to as there are many
opportunities for wide interpretation of words like ‗ consistent‘, ‗essential‘, ‗sufficient‘
etc. More defined guidance is needed.

SA, UK: – these criteria are broadly similar to the 2005 IBS and as such are more
or less adequate for an authority (like IFOAM) to own and use and apply with
integrity and consistency. However, ALL of the criteria are open to wide
interpretation (interpretive words highlighted in yellow below) which means that
every organisation will come up with their own and widely differing evaluations to
suit their own purposes and interests. The result will be as many individual lists as
there are organisations. There will be no consistency, just chaos. The movement
will be set back 20 years, or more likely, the IBS will disappear into obscurity as
being irrelevant, and one of IFOAM‘s key assets will have been thrown away. This
is a disastrous approach.


                                                                                    116
  Agrior. Israel:
 The criteria in good, but cannot stand alone. IBS must contain positive lists. The
  lists of allowed inputs are one of most important features of the standard.
 The exceptional allowance for chemically synthesized substances is very
  dangerous. It must be clearly defined that in no circumstances, such substances
  can come in direct contact with organic product, nor spread any derivates that
  might be detected and identified as chemical residue in produce.

 OMRI, US: IFOAM offered no specific explanation as to why the criteria were
 revised and why the Appendices were removed. While OMRI acknowledges that
 the current criteria can be further improved, the proposed criteria appear to be a
 step backwards. Rather than being a benchmark based on various existing
 standards, they do not appear to match the criteria used in any currently recognized
 standard. The criteria in the current IBS specify data that need to be considered in
 evaluating substances. The proposed criteria are vague, imprecise, and lack any
 points of reference. Rather than drawing a clear distinction between organic and
 non-organic agriculture, the diluted criteria and absence of permitted substances
 lists blurs the distinction between organic and non-organic agriculture. A positive list
 of permitted substances—such as is in the current IBS—is the clearest benchmark.
 Clear criteria and an open, transparent process are necessary for a permitted
 substance list to be valid.

 The criteria for pest control contradict the standards and practices. On the one
 hand, the criteria appear to be so restrictive that no pesticide could be applied
 directly to crops. In the absence of a list of agreed upon substances used for pest
 control, one could also subjectively rule out many if not most substances that are in
 Appendix 3 of the 2005 IBS if an absolute standard of each of the criteria were
 applied.
 If synthetic pesticides are limited to pheromones and pesticides in traps, a number
 of items currently appearing on Appendix 3 of the 2005 IFOAM Basic Standards
 would be banned. The synthetic pesticides applied directly to crops under the
 current IBS including copper salts, sulfur, chloride of lime, light mineral oils, calcium
 hydroxide, carbon dioxide, potassium permanganate, lime sulfur, potassium
 bicarbonate, and soap. Application of the above-mentioned criteria would rule these
 out. On the other hand, the fact that there is nothing in section 4.4 to prohibit any
 practice, the use of any pesticide could be considered acceptable. OMRI
 recommends that IFOAM maintain a positive, indicative list of commonly agreed
 upon materials to resolve this lack of clarity and inconsistency.

 Replace the criteria in Section C with the Criteria that appear in the 2005
 IFOAM Basic Standards Appendix 1.
 Create Section C, Table 1, ―Fertilizers and Soil Conditioners‖ from the 2005
 IFOAM Basic Standards Appendix 2.
 Create Section C, Table 2 ―Crop Protectants and Growth Regulators‖ from the
 2005 IFOAM Basic Standards Appendix 3.
 Create Section C, Table 3 ―List of Approved Additives and Processing Aids‖
 from the 2005 IFOAM Basic Standards Appendix 4, Table 1.
 Create Section C, Table 3 ―Cleaners and Disinfectants In Direct Contact With
 Food‖ from the
 2005 IFOAM Basic Standards Appendix 4, Table 2.
                                                                            117
Introduction
Substances used in organic production, processing and handling must be consistent
with the Principles of Organic Agriculture. The Principle of Care states that precaution
and responsibility are the key concerns in management, development and
technology choices in organic agriculture, processing and handling. Standard setting
bodies shall use the following as minimum criteria, which are based upon a
precautionary approach, when evaluating substances for inclusion in their standards.
Changes in introduction according to Grolink.

General Criteria
All substances used in organic production and processing must meet all of the
following general criteria and be evaluated as a whole in order to protect the integrity
of organic production and processing:
Grolink – Change to: All substances used in organic production and processing must
meet all of the following general criteria and be evaluated as a whole before
allowance of use is granted use of the substance is consistent with principles of
organic agriculture as outlined in the IBS.
 SA, UK: [consistent], no comment. Lots of questions from this commeter point at
 the grammar and word in entirety.

 ARGENCERT, Argentina: This is an example of the use of the same acronym for
 the Standards and the Benchmark; the Basic Stdrds. are still in use; will the
 requirements change when the Benchmark become in use,?

 i) the substance is necessary/essential for its intended use.
 SA, UK: [necessary/essential], no comment.

 ii) approved alternatives are not available in sufficient quantity and/or quality
 SA, UK: [sufficient] , no comment.

 ARGENCERT, Argentina: If the prohibition of the use of synthetic products has not
 been clearly specified as a general philosophical requirement in the introductory
 chapter; should it not be mentioned here?

 iii) manufacture, use and disposal of the substance does not result in, or contribute
      to, harmful effects on the environment.
 SA, UK: [harmful effects], no comment.

 iv) they have the lowest negative impact on human or animal health and quality of
     life;
 SA, UK: [lowest negative impact], no comment.

 v) the consumer shall not be deceived concerning the nature and quality of the
    substance,
 SA, UK: [deceived], no comment.

 vi)   the substance is not known to be incompatible with consumer expectations in
       the region where the standard is applied.
                                                                                 118
 SA, UK: [not known to be incompatible] , no comment.

 ARGENCERT, Argentina: Fish meal in animal feeding is accepted by the Irish
 consumer but not by those in London. The standard applied in Ireland will not be
 accepted in London and there will be a conflict between standards.

 vii) consideration may be given to social and economic impacts of sourcing and
       manufacturing the substance
 SA, UK: [consideration ] , no comment.
 ARGENCERT, Argentina:
 a) exceptional circumstances should be explained similarly as it is in the fourth
 sentence of point
 b).The last two sentences of point a) are very well phrased. Also the last sentence
 of point a)
 c) Growth Regulation is not a normally accepted practice in organic agriculture;
 mentioning them in the Benchmark has a negative connotation.
 d) second sentence: If synthetic products are to be permitted in exceptional cases,
 their use have to be framed by conditions as specified for textiles in the last
 sentences of this point c).

 Grolink: We don‘t understand intent of this criterion (vii)

In addition, the following criteria must be applied in the evaluation process:
    a) if the substance is used for fertilization and/or soil conditioning purposes:
        it is essential for obtaining or maintaining the fertility of the soil or to fulfill
          specific nutritional requirements of crops, or specific soil-conditioning and
          rotation purposes which cannot be satisfied by other relevant parts of the
          IBS.
       SA, UK: [essential] , no comment.
       Grolink: Change to - it is essential for obtaining or maintaining the fertility of
       the soil or to fulfill specific nutritional requirements of crops, or specific soil-
       conditioning and rotation purposes which cannot be satisfied by other
       agronomic measures.
        the ingredients are of plant, animal, microbial, or mineral origin and may
          have undergone the following processes: physical (e.g., mechanical,
          thermal), enzymatic, microbial (e.g., composting, fermentation);
               In execptional circumstances chemically synthesized substances
                 may be considered.
       SA, UK: [execptional circumstances] , no comment.

       JR-UoM,US: This is a huge loophole and must be deleted

       KRAV, Sweden: There should be measures by the standard setting body to
       ensure that use of chemically synthesized substances are only used in
       exceptional cases and not on a regular basis. The need should be evaluated
       by the certifier and the practice should stop when other measures are
       applicable.

       WSDA, US: Why? When and where are synthetic fertilizers ―necessary?‖

                                                                                    119
      ICS, US: [fermentation] thermal processes render many minerals immediately
      soluble! This process should not be allowed, especially for fertilization.
      Delete ‗themal‘

        use does not have a harmful impact on the balance of the soil ecosystem
          or the physical characteristics of the soil, or water and air quality.
       SA, UK: [harmful] , no comment.
        use may be restricted to specific conditions, specific regions or specific
          commodities.
       SA, UK: [restricted] , no comment..
b) if the substance is used for plant protection, growth regulation or weed control:
        it must be essential for the control of a harmful organism or a particular
          disease for which other biological, physical, or plant breeding alternatives
          and/or other management practices consistent with this IBS are not
          effective.
       SA, UK: [essential] , no comment.
        account must be taken of the potential harmful impact on the environment,
          the ecology (in particular non-target organisms) and the health of
          consumers, livestock, aquatic animals and bees.
       SA, UK: [account must be taken] , no comment.

       GCSAR, Syria: account must be taken of the potential harmful impact on the
       environment, the ecology (in particular non-target organisms) and the health of
       consumers, livestock, aquatic animals and bees.

       KRAV, Sweden: The persistance of the substance shall also be taken into
       account.

        substances must be of plant, animal, microbial, or mineral origin and may
          undergo the following processes: physical (e.g. mechanical, thermal),
          enzymatic, microbial (e.g. composting, digestion);
        however, if in exceptional circumstances, a chemically synthesized
          substance (such as a pheromone) is used in traps and dispensers, then it
          maybe considered for addition to lists; but only if the substance is not
          available in sufficient quantities in its natural form, and provided that the
          conditions for use do not directly or indirectly result in the presence of
          residues of the substance in the edible plant parts;
       SA, UK: [exceptional circumstances] , no comment..

         use may be restricted to specific conditions, specific regions or specific
            commodities;
c) if the substance is used as an additive and/or processing aid in the preparation or
preservation of the product:
       – it must otherwise be impossible to produce or preserve the product
       SA, UK: [impossible], no comment.

                                                                                 120
 the substance is found in nature, and may have undergone
   mechanical/physical      processes   (e.g.   extraction,     precipitation),
   biological/enzymatic    processes   and    microbial    processes      (e.g.
   fermentation).
RLF, South Africa: ‗the substance must be found in nature,‘ replaces ‗the
substance is found in nature,‘.

        In execptional circumstances chemically synthesized substances
         may be considered.
SA, UK: [exceptional circumstances] , no comment.

JR-MoU & NODPA, US: Deleting this.

KRAV, Sweden: There should be measures by the standard setting body to
ensure that use of chemically synthesized substances are only used in
exceptional cases and not on a regular basis. The need should be evaluated
by the certifier and the practice should stop when other measures are
applicable.

OIA, Argentina: The term exceptional circumstances to allow the used of
chemical substances, can not be accepted.

 use of the substance does not compromise the authenticity of the product
   or detract from its overall quality.
ICS, US: [added] --- it must not create new charcateristics in the final product
that would not exiust otherwise.

 In the case of textile processing, the relevant criteria above are applied,
   and in addition
      The substance may be allowed only if it is biodegradable, generally
         recognized as safe and hypoalerginic
SA, UK: [biodegradable] By what criteria? There are several.

RLF, South Africa: ‗hypoalergenic‘ replaces ‗hypoalerginic‘

         The substance shall be prohibited if it is carcinogenic, mutagenic,
          teratogenic. or toxic
      SA, UK: By what criteria? There are several.
      JR-UoM, US: teratogenic [‗genetically engineered, an endrocine
      disruptor‘]

         Use of pigments or mordents containing heavy metals in excess of a
          specified amount defined by the standard are not allowed.
      SA, UK: [specified amount defined by the standard]. This makes a
      circular reference: 7.7.4 refers to here, which refers back to the
      standard. In other words, any amount can be specified.

                                                                        121
             RLF, South Africa. Use of pigments or mordants containing heavy
             metals in excess of a specified amount defined by the standard are not
             allowed.

             Grolink: Change to - A specified maximum amount or rate shall be set
             by the standard setter for use of pigments or mordents containing heavy
             metals

                Additives and processing aids including sizes and lubricants must be
                 either organic or biodegradable.
              The use of non-biodegradable, bio-accumulating input products and
                 heavy metals shall be prohibited.
       SA, UK: [non-biodegradable, bio-accumulating], [and heavy metals]. ‗Non-
       biodegradable, bio-accumulating‘ repeats previous criteria. ‗Heavy metals‘
       contradicts previous criteria.

       JR-UoM, US: This is a standard, not a criterion for evaluating inputs.

       NASAA, Australia: SECTION D
       Annexes
       Construct (import) existing annexes

BB, US:
[Delete] Introduction
Substances used in organic production, processing and handling must be consistent
with the Principles of Organic Agriculture. The Principle of Care states that precaution
and responsibility are the key concerns in management, development and
technology choices in organic agriculture, processing and handling. Standard setting
bodies must use the following criteria, which are based upon a precautionary
approach, when evaluating substances for inclusion in their standards.

‗Principle of care‘ highlighted. The principle of care also requires that decisions be
made in a transparent way and that all stakeholders are involved.

General Criteria
All substances used in organic production and processing must meet all of the
following general criteria and be evaluated as a whole in order to protect the integrity
of organic production and processing:
use of the substance is consistent with principles of organic agriculture as outlined in
the IBS.

‗principles of organic agriculture‘ and ‗outlined in the IBS‘ are highlighted. The
respective comments comes as follows:
     Begs the question.
     How are these different from the IFOAM Principles of Organic Agriculture?
        The Principles are normative and separate from the standards.

the substance is necessary/essential for its intended use.
approved alternatives are not available in sufficient quantity and/or quality
                                                                                  122
manufacture, use and disposal of the substance does not result in, or contribute to,
harmful effects on the environment.
‗necessary/essential‘ is highlighted.
Subjective: Who determines?

they have the lowest negative impact on human or animal health and quality of life;
the consumer shall not be deceived concerning the nature and quality of the
substance,
the substance is not known to be incompatible with consumer expectations in the
region where the standard is applied.

      Lowest negative impact:As determined by who?
      Where the Standard is aplicable: With respect to market access, it needs to be
       compatible with consumer expectations where the product is consumed.


consideration may be given to social and economic impacts of sourcing and
manufacturing the substance

In addition, the following criteria must be applied in the evaluation process:
if the substance is used for fertilization and/or soil conditioning purposes:
it is essential for obtaining or maintaining the fertility of the soil or to fulfill specific
nutritional requirements of crops, or specific soil-conditioning and rotation purposes
which cannot be satisfied by other relevant parts of the IBS.
the ingredients are of plant, animal, microbial, or mineral origin and may have
undergone the following processes: physical (e.g., mechanical, thermal), enzymatic,
microbial (e.g., composting, fermentation);
In execptional circumstances chemically synthesized substances may be considered.
use does not have a harmful impact on the balance of the soil ecosystem or the
physical characteristics of the soil, or water and air quality.

Exceptioanal circumstance is highlighted: Typo. Again, who determiines?

use may be restricted to specific conditions, specific regions or specific commodities.
if the substance is used for plant protection, growth regulation or weed control:
it must be essential for the control of a harmful organism or a particular disease for
which other biological, physical, or plant breeding alternatives and/or other
management practices consistent with this IBS are not effective.
account must be taken of the potential harmful impact on the environment, the
ecology (in particular non-target organisms) and the health of consumers, livestock,
aquatic animals and bees.
substances must be of plant, animal, microbial, or mineral origin and may undergo
the following processes: physical (e.g. mechanical, thermal), enzymatic, microbial
(e.g. composting, digestion);
however, if in exceptional circumstances, a chemically synthesized substance (such
as a pheromone) is used in traps and dispensers, then it maybe considered for
addition to lists; but only if the substance is not available in sufficient quantities in its
natural form, and provided that the conditions for use do not directly or indirectly
result in the presence of residues of the substance in the edible plant parts;
use may be restricted to specific conditions, specific regions or specific commodities;
if the substance is used as an additive and/or processing aid in the preparation or
preservation of the product:

                                                                                     123
–      it must otherwise be impossible to produce or preserve the product
the substance is found in nature, and may have undergone mechanical/physical
processes (e.g. extraction, precipitation), biological/enzymatic processes and
microbial processes (e.g. fermentation).
In execptional circumstances chemically synthesized substances may be considered.
use of the substance does not compromise the authenticity of the product or detract
from its overall quality.
In the case of textile processing, the relevant criteria above are applied, and in
addition
The substance may be allowed only if it is biodegradable, generally recognized as
safe and hypoalerginic
The substance shall be prohibited if it is carcinogenic, mutagenic, teratogenic, or
toxic
Use of pigments or mordents containing heavy metals in excess of a specified
amount defined by the standard are not allowed.
Additives and processing aids including sizes and lubricants must be either organic
or biodegradable.
The use of non-biodegradable, bio-accumulating input products and heavy metals
shall be prohibited.

[Insert] General Principles
Organic production and processing systems are based on the use of natural,
biological, renewable, and regenerative resources. Organic agriculture maintains soil
fertility primarily through the recycling of organic matter. Nutrient availability is
primarily dependent on the activity of soil organisms. Pests, diseases, and weeds are
managed primarily through cultural practices. Organic livestock are nourished
primarily through organically produced feed and forage, and are kept in living
conditions that allow for natural behavior and avoidance of stress. Organic foods and
other products are made from organically produced ingredients that are processed
primarily by biological, mechanical, and physical means.
Input Lists
The following Appendices contain lists of the inputs, food additives, processing aids,
and other substances that are allowed for use in organic production, handling, and
processing. The IFOAM Basic Standards are limited (closed) to inputs that comply
with these lists. These lists include broad categories and are not comprehensive or
detailed. Compliant standards can only contain additional inputs that appear in these
categories. Standards may also restrict the use of certain inputs based on the
consideration of factors such as contamination, risk of nutritional imbalances,
importation of inputs from outside the farm, and depletion of natural resources.

Revision Procedure for Appendices
Any IFOAM member can request that IFOAM add, delete, or change the status of an
input under the IBS. Requests from non-members may also be considered at
IFOAM‘s discretion. IFOAM requires a dossier for any revision made to IBS
Appendices 2, 3, and 4. The applicant who submits a dossier to add a substance or
remove restrictions must address all of the appropriate criteria described below. An
applicant who requests an input to be deleted or further restricted may address only
the evaluation criteria where an input fails to meet a specific criterion.

IFOAM reviews the dossier and makes one of following decisions:



                                                                              124
 Insufficient information. The dossier is returned to the applicant with a request to
 provide more information.

 Clarification of existing standards. The applicant is informed that the input is
 already covered (allowed, restricted, or prohibited) by the IBS.

 Reference to Experts. IFOAM requires the opinion of recognized experts before it
 can make a decision. IFOAM refers the dossier to one or several experts for
 evaluation. If the experts require more information, the IFOAM requests this
 information and distributes it to the experts. The experts provide a recommendation
 to the Standards Committee. The SC informs the applicant of the experts‘ comments
 and recommendations, and offers the applicant the opportunity to respond. IFOAM
 then makes a decision based on the information contained in the dossier, the
 recommendation of experts, and response of the applicant.

 Recommendation for Change of Relevant Appendix. IFOAM informs the applicant
 that the change is recommended by the IFOAM to be included into the IBS. The input
 then follows the procedure established to revise the IBS.

 Rejection of the Dossier. IFOAM reserves the right to reject any dossier that fails to
 document that the substance is compatible with the evaluation criteria. This may be
 because the dossier is incomplete, because the substance fails to meet the
 evaluation criteria below, or because the dossier makes false or misleading
 statements. IFOAM informs the applicant of the decision and the reason(s) why the
 input is not considered to be appropriate for inclusion in or deletion from the IBS.

 Final decisions and recommendations shall be published in IFOAM internal
 newsletter and home page.

 Production Input Criteria
 Inputs used in organic production are consistent with the principles of organic farming
 outlined in
 IBS and are evaluated against criteria based upon the Precautionary Principle:

        ‗When an activity raises threats of harm to human health or the environment,
        precautionary measures should be taken even if some cause and effect
        relationships are not fully established scientifically. In this context the
        proponent of an activity, rather than the public, should bear the burden of
        proof.

‗The process of applying the Precautionary Principle must be open, informed and
  democratic and must include potentially affected parties. It must also involve an
  examination of the full range of alternatives, including no action.‘

 The criteria used to evaluate organic production inputs are based on the
 following principles:

 Necessity and alternatives: Any input used is necessary for sustainable production, is
 essential to maintain the quantity and quality of the product, and is the best available
 technology.
 Source and manufacturing process: Organic production is based on the use of
 natural, biological, and renewable resources.

                                                                                 125
Environment: Organic production and processing is sustainable for the environment.
Human health: Organic techniques promote human health and food safety.
Quality: Organic methods improve or maintain product quality.
Social, Economic, and Ethical: Inputs used in organic production meet consumer
perceptions and expectations without resistance or opposition. Organic production is
socially just and economically sustainable, and organic methods respect cultural
diversity and protect animal welfare.

Dossiers for a given substance must address these criteria based on the data
requirements and decision rules stated in the criteria below, and meet the criteria to
be added to the Appendices.
Crop and Livestock Criteria
1. Necessity and Alternatives
All dossiers shall document the necessity of the substance, its essential nature in
organic production systems, and the availability of alternative methods, practices,
and inputs.

1.1 The input is necessary to produce crops or livestock in sufficient quantity and of
    superior suitable quality; to cycle nutrients; to enhance biological activity; to
    provide a balanced animal diet; to protect crops and livestock from pests,
    parasites, and diseases; to regulate growth; and to maintain and improve soil
    quality.
1.2 A given substance shall be evaluated with reference to other available inputs or
    practices that may be used as alternatives to the substance.
1.3 Every input shall be evaluated in the context in which the product will be used
    (e.g. crop, volume, frequency of application, specific purpose).

2. Source and Manufacturing Process
All dossiers shall document sources and manufacturing processes.

2.1 Biological substances require a description of the source organism(s), a verifiable
   statement that they are not genetically engineered as defined by IFOAM, and the
   processes required to breed, culture, produce, multiply, extract, or otherwise
   prepare the substance for use. Naturally occurring plants, animals, fungi, bacteria,
   other organisms are generally allowed. Substances that undergo physical
   transformations, such as by mechanical or thermal processing, or biological
   methods, such composting, fermentation, and enzymatic digestion are also
   generally allowed. Limitations and prohibitions may be set based on consideration
   of the other criteria. Substances that are modified by chemical reaction are
   considered synthetic and therefore subject to protocol 2.3 below.

2.2 Natural non-renewable resources—such as mined minerals—require a
    description of the deposit or occurrence in nature. Non-renewable resources are
    generally restricted or limited in their use. They may be used as a supplement to
    renewable biological resources, provided they are extracted by physical and
    mechanical means, and are not rendered synthetic by chemical reaction. Inputs
    with high levels of natural environmental contaminants, such as heavy metals,
    radioactive isotopes, and salinity, may be prohibited or further restricted.

2.3 Synthetic substances from non-renewable resources are generally prohibited.
    Synthetic nature-identical products that are not available in sufficient quantities


                                                                                  126
   and qualities in their natural form may be allowed., provided that all other criteria
   are satisfied.

2.4 Inputs that are extracted, recovered, or manufactured by means that are
    environmentally destructive may be restricted or prohibited.
3. Environment
All dossiers shall document the substance‘s environmental impact.

3.1 The environmental impact of a substance includes, but is not limited to, the
    following parameters: Acute toxicity, persistence, degradability, areas of
    concentration; biological, chemical, and physical interactions with the
    environment, including known synergistic effects with other inputs used in organic
    production.
3.2 Effect of substance on the agro-ecosystem, including soil health; the effects of
    the substance on soil organisms; soil fertility and structure; crops and livestock.
3.3 Substances with high salt indexes, measured toxicity to non-target organisms,
    and persistent adverse effects may be prohibited or restricted in their use.
3.4 Inputs used for crop production shall be considered for their impact on livestock
    and wildlife.
 4. Human Health
All dossiers shall document the impacts of the substance on human health.

4.1 Documentation about human health includes, but is not limited to: acute and
    chronic toxicity; half-lives, degradants, and metabolites. Substances reported to
    have adverse effects may be prohibited or restricted in their use to reduce
    potential risks to human health.
4.2.Dossiers shall document any human who might be exposed by all possible
    pathways at every stage: workers and farmers who extract, manufacture, apply,
    or otherwise use the substance; neighbors who may be exposed through release
    into the environment; and consumers exposed by ingestion of food-borne
    residues.
5. Quality
All dossiers shall document the substance‘s effect on product quality.

1.1 Quality includes—but is not limited to—nutrition, flavour, taste, storage, and
    appearance of the raw product.

6. Social, Economic, and Ethical Considerations
All dossiers shall document the substance‘s social, economic, and cultural
    implications.

6.1 Social and economic implications include, but are not limited to, the impact of the
    substance on the communities where they are made and used, whether the use
    of the substance favors any economic structure and scale, the historical use of
    the substance in traditional foods.
6.2 Consumer perceptions of the compatibility of inputs shall be taken into account.
    Inputs should not meet resistance or opposition of consumers of organic products.
    An input might be reasonably considered by consumers to be incompatible with
    organic production in situations where there is scientific uncertainty about the
    impact of the substance on the environment or human health. Inputs should
    respect the general opinion of consumers about what is natural and organic– e.g.
    genetic engineering is neither natural nor organic.

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6.3 Inputs used for animal feed and livestock production shall be evaluated for the
   impact on animal health, welfare, and behaviour. Medications must either alleviate
   or prevent animal suffering. Animal inputs that cause suffering, or have a negative
   influence on the natural behaviour or physical functioning of animals kept at the
   farm may be prohibited or restricted.

Processing and Handling Criteria
Introduction
These criteria apply to the evaluation of food additives and food processing aids.
Substances used for technical, sensory, and dietary purposes are subject to these
criteria. The criteria may also apply to substances in contact with food. For food
processing, an input, non-organic ingredient, additive, or processing aid shall be
essential to maintain or improve human health, environmental safety, animal welfare,
product quality, production efficiency, consumer acceptance, ecological protection,
biodiversity, or landscape. Carriers and preservatives used in the preparation of
additives and processing aids must also be taken into consideration. The following
aspects and criteria should be used to evaluate additives and processing aids in
organic food products. All of the criteria below shall be fully and positively
documented in a dossier and review for an input to be allowed in organic processing.
1. Necessity and Alternatives
All dossiers shall document the necessity of the additive, processing aid, or carrier,
its essential nature in organic processing and for the proposed application, and the
availability of alternative methods, practices, and inputs.

Each substance shall be evaluated with respect to its specific uses and applications, and
shall be added to the list only when it is demonstrated to be absolutely essential and
necessary for the production of a specific food that is consistent with organic principles
stated in the IBS.


1.1. All dossiers shall take into consideration the technical feasibility of the following
    alternatives:
   a.   Whole foods that are organically produced according to the IBS.
   b.   Foods that are organically produced and processed according to the IBS.
   c.   Purified products of raw materials of non-agricultural origin, e.g. salt.
   d.   Purified products of raw materials of an agricultural origin that have not been
        organically produced and processed according to the IBS but appear on
        Appendix 4.

1.2 If an ingredient is required to manufacture a processed food product to
   independently established minimum technical specifications recognized by
   consumers, and no organic substitute is available, then a non-organic ingredient
   can be deemed essential.
1.3 A given additive, processing aid, or carrier shall be evaluated with reference to
   other available ingredients or techniques that may be used as alternatives to the
   substance.
1.4 A substance is considered essential if a processed food product requires that
   substance in order to meet established standards of identity, governmental
   regulations, or widely accepted consumer expectations.

2. Source and Manufacturing Process
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All dossiers shall document the substance‘s sources and manufacturing processes.

2.1 Additives and processing aids from biological sources, such as fermentation
     cultures, enzymes, flavours, and gums must be derived from naturally occurring
     organisms by the use of biological, mechanical, and physical methods. Non-
     organic forms are allowed in organic products only if there are no organic
     sources.
2.2 Natural non-renewable resources—such as salt and mined minerals—must be
    obtained by physical and mechanical means, and are not rendered synthetic by
    chemical reaction. Dossiers must document and meet Food Chemical Codex
    specifications for natural contaminants, such as heavy metals, radioactive
    isotopes, and salinity, and may be prohibited or restricted based on unacceptable
    levels of contamination.
2.3 Synthetic nature-identical products that are not available in sufficient quantities
    and qualities in their natural form may be allowed provided all other criteria are
    satisfied.
2.4 Synthetic substances from non-renewable resources are generally prohibited as
    additives and processing aids.

3. Environment
All dossiers shall document the substance‘s environmental impact.

3.1 Documentation for environmental impact:
      The release of any harmful waste stream or by-products from both
      manufacturing and use in processing. Food additives and processing aids that
      result in toxic by-products or polluting waste may be restricted or prohibited.
      This includes persistence, degradation, and areas of concentration.

4. Human Health
    All dossiers shall document the impacts of the substance on human health.

4.1 Documentation about human health includes, but is not limited to: acute and
   chronic toxicity; allergenicity; half-lives, degradants, and metabolites. Substances
   reported to have adverse effects may be prohibited or restricted in their use to
   reduce potential risks to human health.
4.2.Dossiers shall document any human who might be exposed by all possible
   pathways: workers and farmers who manufacture, apply, or otherwise use the
   substance; neighbors who may be exposed through release into the environment;
   and consumers exposed by ingestion of food-borne residues.
4.3. IFOAM will consider only processing aids and additives evaluated by the Joint
   FAO/WHO Expert Committee on Food Additives (JECFA) of the Codex
   Alimentarius.2
   a. A food additive shall have an Acceptable Daily Intake (ADI) level that is either
       ‗not specified‘ or ‗not limited‘ to qualify for use without limitation.
   b. A food additive with any other status shall either be prohibited or have specific
       use restrictions to limit dietary exposure.
   c. Evaluation of food additives shall also take into account known allergenicity
       and immunological responses.




2
    http://apps3.fao.org/jecfa/additive_specs/foodad-q.jsp
                                                                                129
4.4. Information about the practical daily intake of the substance by several groups of
human should be taken into account. It should be demonstrated that no group has a
normal intake which is higher than the accepted ADI.

5. Quality (in processed products)
5.1 All dossiers shall document the substance‘s effect on product overall quality,
    including but not limited to, nutrition, flavour, taste, storage, and appearance.
5.2 Additives and processing aids shall not detract from the nutritional quality of the
    product.
5.3 A substance shall not be used solely or primarily as a preservative; to create,
recreate, or improve characteristics such as flavors, colors, or textures; or to restore
or improve nutritive value lost during processing, except where the replacement of
nutrients is required by law.
5.4 Non-organic ingredients, additive, or processing aid used to process organic
products shall not compromise the authenticity or overall quality of the product or
deceive the consumer of the product‘s value.
5.5 Each additive shall be evaluated with respect to its specific uses and applications
without preference for any specific techniques or equipment, and shall be added to
the list only when it is demonstrated to be absolutely essential and necessary for the
formulation and production of a specific food that is consistent with organic principles
stated in the IBS.
6. Social, Economic, and Ethical Considerations
6.1 All dossiers shall document the substance‘s social, economic, cultural,
implications.
6.3 Social, economic, implications include, but are not limited to, adverse impacts on
communities caused by the manufacture and use of the substance, whether certain
economic structures or scales are favoured by the use of the processing aid; and the
historical use of the additive or processing aid in traditional foods.
6.4 Consumer perceptions of the compatibility of additives and processing aids shall
be taken into account. Any additives and processing aids shall respect consumer
preferences and be accepted by organic consumers. An input might be reasonably
considered by consumers to be incompatible with organic production in situations
where there is scientific uncertainty about the impact of the substance on the
environment or human health. Inputs should respect the general opinion of
consumers about what is natural and organic– e.g. genetic engineering is neither
natural nor organic.


EVALUATION CRITERIA FOR MATERIALS USED IN ORGANIC FIBER
PROCESSING.

In addition to the above applicable criteria, the following additional considerations
apply to substances used to process and handle fiber:

Substances may be allowed in organic textile processing only if they are
biodegradable, generally recognized as safe, and hypoallergenic.

Substances shall be prohibited in organic textile processing if they are carcinogenic,
mutagenic, teratogenic, toxic, or produced by genetically modified organisms or
ionizing radiation.

Table 1

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Fertilizers and Soil Conditioners

Substances description, compositional requirements with conditions for use

I.        Plant and Animal Origin
         Farmyard manure, slurry and urine
         Guano
         Source separated human excrement from separated sources which are
          monitored for contamination (Not to be directly applied on edible parts)
         vermicastings
         blood meal, meat meal, bone, bone meal
         hoof and horn meal, feather meal, fish and fish products, wool, fur, hair, dairy
          products
         biodegradable processing by-products, plant or animal origin, e.g. by-products
          of food, feed, oilseed, brewery, distillery or textile processing.
         crop and vegetable residues, mulch, green manure, straw
         wood, bark, sawdust, wood shavings, wood ash, wood charcoal
         seaweed and seaweed products
         peat (prohibited for soil conditioning) (Excluding synthetic additives; permitted
          for inclusion in potting mixes.)
         plant preparations and extracts
         compost made from ingredients listed in this appendix, spent mushroom
          waste, humus from worms and insects, urban composts from separated
          sources which are monitored for contamination

II.       Mineral Origin
         basic slag
         calcareous and magnesium amendments
         limestone, gypsum, marl, maerl, chalk, sugar beet lime, calcium chloride,
         magnesium rock, kieserite and Epsom salt (magnesium sulfate)
         mineral potassium (e.g. sulfate of potash, muriate of potash, kainite, sylvanite,
          patentkali) (Shall be obtained by physical procedures but not enriched by
          chemical processes)
         natural phosphates
         pulverized rock, stone meal
         clay (e.g. bentonite, perlite, vermiculite, zeolite)
         sodium chloride
         trace elements
         sulfur

III.    Microbiological
biodegradable processing by-products of microbial origin, e.g. by-products of brewery
or distillery processing.
microbiological preparations based on naturally occurring organisms

IV.       Others
         biodynamic preparations

Table 2

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Crop Protectants and Growth Regulators

Substances Description, compositional requirements and conditions for use

I.        Plant and Animal Origin
         algal preparations
         animal preparations and oils
         beeswax
         chitin nematicides (natural origin)
         coffee grounds
         corn gluten meal (weed control)
         dairy products (e.g. milk, casein)
         gelatine
         lecithin
         natural acids (e.g. vinegar)
         neem (Azadirachta indica)
         plant oils
         plant preparations
         plant based repellents
         propolis
         pyrethrum (Chrysanthemum cinerariaefolium), (The synergist Piperonyl
          butoxide is prohibited. Where certification bodies have previously permitted its
          use, it shall be prohibited after 2005)
         quassia (Quassia amara)
         rotenone (Derris elliptica, Lonchocarpus spp. Thephrosia spp.)
         ryania (Ryania speciosa)
         sabadilla
         tobacco tea (pure nicotine is forbidden)

II.       Mineral Origin
         chloride of lime
         clay (e.g. bentonite, perlite, vermiculite, zeolite)
         copper salts (e.g. sulfate, hydroxide, oxychloride, octanoate) (Max 8 kg/ha per
          year (on a rolling average basis))
         diatomaceous earth
         light mineral oils (paraffin)
         lime sulfur (Calcium polysulfide)
         Potassium bicarbonate
         potassium permanganate
         quicklime
         silicates (e.g. sodium silicates, quartz)
         sodium bicarbonate
         sulfur

III. Microorganisms
      fungal preparations
      bacterial preparations (e.g. Bacillus thuringiensis)
      release of parasites, predators and sterilized insects
      viral preparations (e.g. granulosis virus)
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    IV. Others
         biodynamic preparations
         calcium hydroxide
         calcium lignosulfonate
         carbon dioxide
         ethyl alcohol
         homeopathic and Ayurvedic preparations
         iron phosphates (for use as molluscicide)
         seasalt and salty water
         soda
         soft soap
         sulfur dioxide

    V.     Traps, Barriers, Repellents
          physical Methods (e.g. chromatic traps, mechanical traps,)
          mulches, nets
          pheromones – in traps and dispensers only

    Table 3

    List of Approved Additives and Processing Aids

    Where the substances listed in this annex can be found in nature, natural sources
    are preferred. Substances of certified organic origin are preferred.
3
 Int‟l   Product                             Additive Pro.       Limitation / Note
Numberin                                              Aid
g System
INS 170          calcium carbonate           X         X
INS 181          tannin                                X         only for wine
INS 184          tannic acid                           X         filtration aid for wine
INS 220          sulfur dioxide              X                   only for wine
INS 224          potassium metabisulphite    X                   only for wine
INS 270          lactic acid                 X         X
INS 290          carbon dioxide              X         X
INS 296          l-malic acid                X         X
INS 300          ascorbic acid               X
INS 306          tocopherols, mixed natural X
                 concentrates
INS 322          lecithin                    X         X
INS 330          citric acid                 X         X
INS 331          sodium citrates             X

    3
        Food additives may contain carriers which shall be evaluated
                                                                                      133
INS 332   potassium citrates       X
INS 333   calcium citrates         X
INS 334   tartaric acid            X   X   only for wine
INS 335   sodium tartrate          X   X
INS 336   potassium tartrate       X   X
INS 341   mono calcium phosphate   X       only for ―raising flour‖
INS 342   ammonium phosphate       X       restricted to 0.3 gm/l in wine
INS 400   alginic acid             X
INS 401   sodium alginate          X
INS 402   potassium alginate       X
INS 406   agar                     X
INS 407   carrageenan              X
INS 410   locust bean gum          X
INS 412   guar gum                 X
INS 413   tragacanth gum           X
INS 414   arabic gum               X       only for milk products, fat
                                           products, confectionary,
                                           sweets, eggs.
INS 415   xanthan gum              X       only fat, fruit and vegetable
                                           products and cakes and
                                           biscuits
INS 440   pectin                   X       unmodified
INS 500   sodium carbonates        X   X
INS 501   potassium carbonates     X   X
INS 503   ammonium carbonates      X       only for cereal products,
                                           confectionery, cakes and
                                           biscuits
INS 504   magnesium carbonates     X
INS 508   potassium chloride       X
INS 509   calcium chloride         X   X
INS 511   magnesium chloride       X   X   only for soybean products
INS 513   sulfuric acid                X   pH adjustment of water during
                                           sugar processing
INS 516   calcium sulfate          X       for soybean products,
                                           confectionery and in bakers'
                                           yeast
INS 517   ammonium sulfate         X       only for wine, restricted to 0.3
                                           mg/l


                                                               134
INS 524   sodium hydroxide              X       X         for sugar processing and for
                                                          the surface treatment of
                                                          traditional bakery products.
INS 526   calcium hydroxide             X       X         food additive for maize tortilla
                                                          flour. processing aid for sugar
INS 551   silicon dioxide                       X         for wine, fruit and vegetable
          (amorphous)                                     processing
INS 553   talc                                  X
INS 901   beeswax                               X
INS 903   carnauba wax                          X
INS 938   argon                         X
INS 941   nitrogen                      X       X
INS 948   oxygen                        X       X
          activated carbon                      X
          bentonite                             X         only for fruit and vegetable
                                                          products
          casein                                X         only for wine
          diatomaceous earth                    X         only for sweeteners and wine
          egg white albumen                     X         only for wine
          ethanol                               X
          gelatin                               X         only for wine, fruit and
                                                          vegetable
          isinglass                             X         only for wine
          kaolin                                X
          perlite                               X
          preparations of bark                  X         only for sugar



Table 4
For use as food contact cleaners and disinfectants:
            Acetic acid
            Alcohol, ethyl (ethanol)
            Alcohol, isopropyl (isopropanol)
            Calcium hydroxide (slaked lime)
            Calcium hypochlorite
            Calcium oxide (quicklime)
            Chloride of lime (calcium oxychloride, calcium chloride, and calcium
            hydroxide)

                                                                              135
              Chlorine dioxide
              Citric acid
              Formic acid
              Hydrogen peroxide
              Lactic acid
              Natural essences of plants
              Oxalic acid
              Ozone
              Peracetic acid
              Phosphoric acid (dairy equipment only)
              Plant extracts
              Potassium soap
              Sodium carbonate
              Sodium hydroxide (caustic soda)
              Sodium hypochlorite (e.g. as liquid bleach)
              Sodium soap
Flavoring Agents
    Organic flavoring extracts (including volatile oils)
    Volatile (essential) oils produced by means of solvents such as oil, water,
      ethanol, carbon dioxide and mechanical and physical processes
    Natural smoke flavor
    Natural flavoring preparations are only to be approved based on the IFOAM
      Procedure to Evaluate Additives and Processing Aids (Appendix 1)

Preparations of Micro-organisms and Enzymes for use in food processing (see
6.2.4.)
These may be used as ingredient or processing aids with approval based on the
IFOAM Procedure to Evaluate Additives and Processing Aids for Organic Food
Products.
    Organic certified micro-organisms
    Preparations of micro-organisms
    Enzymes and enzyme preparations

IOAS, US: It is understood that CBs will need to put all their existing permitted
substances through this criteria or at least be able to justify inputs against it in order
have the required positive list. It would be helpful if the current IBS appendices could
be "grandfathered" in and deemed compliant with the criteria.
 iii speaks of "approved" alternatives - this will work for additions to the list but not
  for the initial list itself.
 the criteria are probably too detailed for a dossier format and the sheer number of
  inputs which will have to be put through this process around the world is likely to be
  in the hundreds, if not thousands. If they are not put in such a format, then how will
  they be assessed.?


                                                                                  136
 there will need to be a team of assessors working with ACB input lists to ensure
  they meet the requirements - who will do this work and how can it be paid for? It will
  likely add days or weeks onto the evaluation process.
 The criteria indicates that if there is one suitable product available then no others
  should be approved unless there is a problem with quantity or quality.
 in undefined "exceptional" circumstances, synthetic chemical fertilisers will be
  permitted. This is completely contrary to consumer (and most organic producer)
  expectations of organic production.. Banning a natural product on the grounds of
  solubility (chilean nitrate) and then permitting synthetic fertilisers which have
  hitherto been prohibited due to their solubility is inconsistent. Please note - the
  IOAS is not advocating that chilean nitrate be permitted - but cannot see any
  justification for the use of synthetic fertilisers.




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