Watershed? Former organic farmer to oversee California pesticide regulations

In what would have been unimaginable even two years ago, a former organic farmer who once headed California's largest organic certification organization was appointed by Gov. Jerry Brown as head of the state's Department of Pesticide Regulation.

Brian Leahy was assistant director in the California Department of Conservation. He now enters a department that has long been viewed as accommodative to pesticide interests. 

I first came across DPR when I wrote about a powerful soil fumigant known as methyl bromide in my book Organic Inc. Looking over publicly available documents, it was clear that the department interpreted its own toxicity findings in a liberal manner in order to let the spraying of this neurotoxin continue. Only subsequent law suits forced it to retreat and revise its fumigation protocal. 

But as methyl bromide was phased out under a UN treaty, one of the substances proposed to replace it -- methyl iodide -- was even more toxic. California DPR approved the cancer-causing substance in December 2010 against the concerns of its own scientists and those on an independent panel, prompting a ferocious uproar by environmental and consumer groups. 

Whether Leahy's appointment by Brown proves a game-changer on the future of methyl iodide remains to be seen. But it's clear that with the growth of organic farming in the state, what was unimaginable has now come to pass. And California -- at least when it comes to pesticide regulation -- is highly influential nationally. 

So it will be very interesting to see how this all plays out.

Leahy, by the way, served as executive director of California Certified Organic Farmers (CCOF) from 2000 to 2004. His appointment requires state senate confirmation. 

- Samuel Fromartz

Organic fertilizer fraud -- an in-depth look

I have a story posted over at Grist this week, California Schemin', on fraud in the organic fertilizer market. The issue has not gotten a lot of attention because, unlike pesticide residues, it doesn't end up on your food. But the scope of the fraud was truly mind-boggling. This story was in the works for months and delayed by internal staff changes at Grist. I was happy it finally saw the light of day. 

Here's the intro:

It's no secret that the organic food industry has seen explosive growth, taking only a mild drubbing through the recession and then continuing its ascent. At the heart of that growth has been trust -- consumers are willing to shell out more bucks for organic because the food's been grown without synthetic chemicals, with that claim verified from farm to market.

Yet two major cases of federal fraud have been filed in the past six months, rocking the California farming world and alleging that probably millions of pounds of produce sold as organic over several years weren't worthy of the label.

So why haven't you heard about this? Because the shady practices came from a side of the farming world that few shoppers think about: the fertilizer industry. And the real dupes weren't consumers but organic farmers.

15 Steps to Avoid Toxic Chemicals -- As Highlighted by the President's Cancer Panel

The President's Cancer Panel made quite a stir this week when it released a report (pdf) on environmental cancer risk. It said what many health researchers, doctors and advocates have been saying for a long time -- that we face increased health risks from exposure to chemicals, only a fraction of which have been tested. It also advocated buying organic food without using the word (it said food grown without pesticides instead).

Though it got little attention, here is what the panel recommended to avoid exposure to toxic chemicals:

1. Choose foods, house and garden products, play spaces, toys, medicines and medical tests that will minimize children's exposure to toxics.
2. Reduce exposure to occupational chemicals by removing shoes before entering the home and washing clothes separate from other family laundry.
3. Filter home tap or well water to reduce exposure to known carcinogens and endocrine-disrupting chemicals. Use filtered tap water rather than commercial bottled water.
4. Store and carry water in stainless steel, glass or BPA- and phthalate-free containers.
5. Microwave food and beverages in ceramic or glass -- not plastic -- containers.
6. Choose food grown without pesticides or chemical fertilizers and wash conventionally grown produce to remove residues.
7. Eat meat produced without antibiotics and added growth hormones.
8. Avoid or minimize consumption of processed, charred, and well-done meats.
9. Wear a headset when using a cell phone and keep calls brief.
10. Check home radon levels.
11. Reduce or eliminate exposure to second-hand smoke.
12. Discuss the need for tests or procedures that involve radiation exposure with your doctor.
13. Create a record of all imaging or nuclear medicine tests received and if known, the estimated radiation dose for each test.
14. Avoid overexposure to UV-rays by wearing protective clothing and sunscreens and avoiding the sun when it's most intense.
15. Become an advocate by strongly supporting environmental cancer research and measures to remove toxins from the environment.

Behind the Organic Pasture Rule at the USDA

After one of the most contentious issues in the organic food world was put to rest last week, I happened to be feeding a few goats in Massachusetts. I pulled some grass from a nearby field and walked over to the animals. They came right up to me and started eating the fresh forage from my hand. There was hay nearby but the green stuff clearly won the taste test.

Over at the USDA, it took more than a decade of complaints and advisory statements, reams of documents, a dairy symposium, five listening sessions, at least two comment periods, the overhaul of the USDA's National Organic Program, the new Obama administration, and vigorous lobbying by small dairy farmer groups to arrive at the same conclusion as these goats -- ruminants such as cows prefer grass and they should be required to graze a minimum amount of pasture on an organic farm.

Why was this so contentious? Because cows don't need to be on pasture to produce milk. In many conventional dairies, cows are housed indoors. In fact, if they eat more grain rations and expend less energy walking to pasture they actually produce more milk, not less. That efficient factory-like reality led large-scale organic dairy operations to minimize pasture, maximize milk production and thus undercut all those other farmers who wanted to let cows express their natural behavior and eat grass. And these large-scale farms could do so because organic regulations, until now, only required vague "access to pasture," not a bright line minimum standard for grazing that all farms must meet.

Now, with the new pasture rule released last week, the bright line is there. The regulation states that cows must be out on pasture throughout the grazing season, though not less than 120 days. They must  also get a minimum of 30% of their nutrition from fresh grass (as measured by dry weight, since grass contains far more water than grain). This standard was arrived at by consensus by organic dairy farmers around the nation nearly five years ago. It will take full effect a year from now.

The National Organic Standards Board (NOSB), an advisory panel which recommends all regulatory changes to the Secretary of Agriculture, had at first recommended that the 120 day/30% minimum be for "guidance" only. But in an especially detailed and well-reasoned document explaining the regulation (pdf), the USDA said, "public comments showed strong backing for a regulatory change" -- not simply guidance.

The agency enacted the bright line standard to avoid confusion among certifiers who had interpreted the "access to pasture" prescription quite differently. (Some required grazing while others clearly did not). Secondly, and perhaps more crucially, the USDA made the change "to satisfy consumer expectations that ruminant livestock animals graze on pastures during the grazing season."

Evidence of those consumer expectations appeared after the first proposed rule, released in April 2006, when more than 80,500 commented. Of those, just 28 were opposed to any changes in the pasture requirement and "there was a consistent theme of opposition to confining animals and feedlot feeding," the agency noted.

Consumers, farmers, retailers and public advocates spoke. And, in this case, the USDA listened -- it just took awhile.

That voice is especially important because the National Organic Program was designed by Congress as a "marketing program." (It is officially agnostic on whether organic foods or organic production practices are better or healthier). If the market, defined by the 30% or so of Americans who occasionally buy organic products, think that organic practices are failing to live up to their expectations, the agriculture secretary has reason to "satisfy consumer expectations" and change the program. That was clearly the case in the pasture dispute, where consumers felt large-scale feedlot organic farms were manipulating organic practices with a loophole.

As another example, the agency pointed out that antibiotics are clearly prohibited from organic production. Consumers point to the absence of antibiotics as well as synthetic growth hormones in production as reasons to buy organic dairy products, livestock, meat and poultry. Yet the agency felt compelled "to further clarify the prohibition on the use of antibiotics." 

The reason? "In administering this program we have found antibiotics in certified organic feed," the agency said. The document continues:

Whether used for therapeutic or subtherapeutic reasons or to increase feed efficiency or rate of gain, all antibiotics are prohibited...  It is the producer’s responsibility, to obtain assurances from feed suppliers that the feed products supplied are free of antibiotics.

But the intent of meeting consumer expectations might not only apply to pasture or livestock practices. If consumers have an expectation that organic food should be free of genetically modified crops, then the agency should ensure against GM contamination. (Genetically modified crops are banned from organic agriculture). In fact, this issue may arise sooner rather than later if genetically modified alfalfa is approved by the USDA. Organic farmers plant alfalfa in their fields, so those crops could be subject to pollen contamination from genetically modified alfalfa. That prospect has led to yet another consumer campaign for protections and more law suits are likely on the horizon if the GM crops are approved.

Despite clear consumer preference, there were objections to the new pasture standard.

First, those who opposed it said the standard said it would raise costs dramatically by increasing the amount of land needed for grazing. (This is a familiar argument of anti-organic camp -- that organic production requires more land). But the USDA said: "We received other studies challenging (this) assertion ... These studies discuss a prevalent misconception that grazing systems require more acres for the same amount of output." 

It also found ample organic land for grazing, especially in the West, where many objections to the pasture standard originated. (The bigger issue for large operations is moving cows from pasture to the milking parlor -- a nearby feedlot is far easier to manage). 

A notable objection had been lodged by Straus Family Creamery, a pioneering organic dairy in California which found the ruling overly prescriptive. But in the final rule, the USDA stated that the 120 day minimum did not have to be continuous -- it could be met with breaks over any defined 365 day period. But it also made clear that if the 120-minimum could not be met, the farm shouldn't be organic.

...if the location is consistently too rainy or the temperature and humidity are too high or low to safely graze animals throughout a 120-day minimum grazing season and still comply with all applicable parts of this regulation, the animal cannot be raised in such location for organic production.

In the end, Straus found the final rule acceptable. “The final rule allows for a grazing season that considers regional variation in climate, soil conditions, and regional water quality regulations,” said Albert Straus. “We’re very grateful to all of the consumers who urged the USDA to account for such regional variations in the final rule. It’s exciting to see the National Organic Program continue to get stronger."

As with many past examples in the organic food arena, a diverse and often conflicted number of constituents came together to urge passage of this rule -- including various farmer groups, consumer organizations, processors, retailers, certifiers, environmental advocates and others. That lesson should be kept in mind for the future.

Further background on the rule change can be found at:

• The NOP web site
• Cornucopia Institute
• Northeast Organic Dairy Producers Alliance

- Samuel Fromartz

USDA Launches Local Foods Blitz, Bans Fried Foods and Donuts in Cafeteria for a Day

I don't usually get calls from the USDA, let alone the deputy secretary, but there Kathleen Merrigan was on the phone from her car and it wasn't a prank. 

She wanted to talk about the Know Your Farmer, Know Your Food campaign that the USDA launched this week, which centers on building buzz around local and regional food systems and "spurring economic opportunity." Merrigan is chairing the initiative, which comes not a moment too soon.

The USDA has finally recognized how important and vital local and regional food systems are -- and is tapping into the vibrant activity already underway by making an effort to open up its doors and purse strings. 

Among other things, the USDA is 

• loosening rules on interstate meat commerce, to help smaller processors, and making grants on rural economic initiatives.
• making it easier for institutions like schools to buy locally.
• offering grants to improve community food security, to be announced Wednesday.
• emphasizing direct marketing, with the launch of the White House farmers' market, and farmers' markets grants on Thursday.
• pushing the idea that "ag is back" with a new web portal launching Friday and a Facebook web chat with Merrigan.

This sounds like a lot of hoopla -- you can review the press materials at the USDA links above -- but I did get a chance to ask a few questions, most notably, "What is this about?"

Merrigan said she has been quietly heading a task force since May to push local and regional agricultural initiatives. Representatives from various department programs are meeting biweekly to discuss how best to achieve that goal. Like Obama, Merrigan and her team seem impatient about getting things done.

"The secretary told me he wanted me to take on the local and regional food challenge -- it was a top priority of my job aside from the USDA budget," Merrigan said. "And, I'll always be involved in organic."

Given the size of the USDA - 114,000 employees - Merrigan felt it wasn't imperative to create new programs but to increase outreach to existing ones (and perhaps, though unstated, light a fire within the agency on this new priority). The effort also involves tweaking existing regulations and programs to make these goals easier to achieve.

The initiative even extends to the USDA cafeteria, where your intrepid blogger has actually eaten (I recommend the House Cafeteria up on the Hill instead). In any case, the USDA is offering dishes with locally grown products all week long.

Merrigan said the cafeteria is also banning donuts and fried foods on Wednesday and putting a sign on the soda machine "have you considered water, juice or milk?" Sounds almost radical.

"Maybe this will be my last act as deputy," she quipped.

But if staff groan about food police, at least they get to see a celebrity on hand: White House Chef Sam Kass will be doing a cooking demo in the USDA cafeteria on Wednesday. 

On Thursday, the action shifts to farmers markets, when the one down the street from the White House opens. Merrigan will be on hand. The USDA will also announce a series of farmers' market promotion grants, and research monies aimed at local food systems in the northeast. 

Finally, on Friday, it is trying its hand at internet democracy and launching a web site that includes outreach to citizens for their ideas. Not sure how this effort at crowd-sourcing will work out, given what happened when the White House tried it. But I gotta say, this is a sea change from the last team in charge. 

- Samuel Fromartz

Alaskan Salmon and the Birth of a SeaSA

This summer, I had the opportunity to travel to Alaska to check out the Copper River salmon fishery and I'm happy to say I came back with more than a story. 

There, I met a fisherman Bill Webber, pictured above, who sells direct to customers. The proposition made sense when I saw fisherman got only $1.85 per pound for Copper River sockeye salmon. This was the same stuff -- or actually a better grade of fish -- than I was buying at Whole Foods for at least $15 a pound this summer. The middlemen can move a lot of fish, but it also creates opportunity for fishermen who want to sell direct to people like me who want a really fresh fish.

I also learned that Alaska has extremely stiff fishing regulations that extend to boat ownership. They require commercial fishermen to be on their boats, preventing one fisherman from owning a fleet of boats in the same fishery. The hundreds of boats in Cordova, Alaska, where I was visiting, were all small businesses protected from industry concentration. (When I mentioned that to a farmer, she said that would do wonders for agriculture).

These fishermen also depend on distant markets, because a few boats could probably feed the entire town for a year -- easily. In fact, without distant markets, there wouldn't be a town since there's hardly anything else going on aside from fishing. Okay, maybe moose hunting.

So I decided to buy fish direct from Alaska, to support the fishermen and the remarkably sustainable fishery up there. 

I told my friends here in DC and we decided to buy seven fish -- 64 pounds total. Last Monday, on Labor Day, Bill went out gillnetting for Coho salmon, which run around 9 pounds each. On Tuesday, he put the chilled fish on an Alaska Airlines jet. On Wednesday, I picked the box up at DC's airport -- just in time to get snarled in traffic because Obama was giving his health-care speech on Capitol Hill, around the corner from my house. Forgot the streets would be on lockdown.

Anyway, I finally made it home, then spent the next two hours filleting the fish listening to Obama on the radio (and cheering him on).

The fish were a big hit. As one friend said in an email, "We love our Salmon! It is not only tastier but the texture is very much better than the supermarket or fish market equivalent." We also had a lot of carcasses, which some people passed on. Too bad. There was a lot of meat on them, which one friend made into a fume (stock) and then risotto. Another friend salted the carcass and kept it in the frig.

I think I'm going to pick the meat off the bones and make salmon burgers, then make fume with the bones, leeks, and fennel. I'm using the tail portion of the fish for gravlax. We've already had grilled salmon and salmon aoili sandwiches on ciabatta rolls.

Now, I know, some will say, you're flying fish from Alaska? But if you're going to eat fish, I think the most important thing is the sustainability of the fishery -- and on that score, Alaska is a leader. Plus, this was a first step. I will be looking at nearby sources, too, in the future. But for me, the health of the fishery is more important than the locale when it comes to fish.

With shipping, we ended paying less than retail (though I did cramp my shoulder from all the filleting). Still, it was worth it.

If you missed it, check out the short video I shot on Bill's boat.

- Samuel Fromartz

Have Your Say: Organic Grazing Rule Comment Due Dec. 23

By Samuel Fromartz

If you've finished your holiday shopping and want to get your activist juices flowing, consider this for a minute: a crucial deadline is coming on Tuesday for comment on regulations for grazing organic livestock.

Grazing? Regulations? Before you click away, consider that organic dairy farmers have been fighting for at least 8 years to get a regulation in place that insures products like organic milk, remain organic. And that is important for a lot of people who drink organic milk -- the best-selling product in the organic market.

Here's the gist. We think of organic animals out on pasture, munching grass on an organic farm. But in the past, organic regulations required only that cows have "access to pasture" which was less than the words suggest. Some big operations flouted the rules, keeping their cows confined rather than out munching good, fresh grass. Access was a gate that was sometimes open, but mostly closed.

OK -- so after years of fighting, regulation writing, comment periods in which dairy farmers descended on Washington and asked for tougher regulations, the USDA's National Organic Program actually came up with one.

Parts of it are quite good, requiring at least 120 days on pasture and 30% nutrition from fresh grass. Farmers applauded. I called it a "big win for organic integrity" in a couple of media interviews.

I still view it that way -- but it needs some basic changes, ones which if they aren't made will actually have the effect of knocking the majority of organic livestock farmers out of the business.

How so?

Well, first off, the proposed regulation would require that cows be outside all year long. The common practice of putting them in a barn or a livestock pen in the winter when no grass is growing has been written off in favor of keeping them on land called "sacrificial pasture" during the non-grazing season.

That means that when the ground is frozen or covered in snow, the animals will be corralled onto a piece of pasture that is then sacrificed. The word is well chosen because the ground will be trodden, manure will accumulate and a good section of pasture will be lost probably for good due to soil compaction.

In rainy regions, like northern California or the Pacific Northwest, the situation may well be worse. Cows will be kept in muddy fields, causing manure runoff into streams, and potentially endangering the health and welfare of the animals.

"There's no recognition of regional or climate variations," Albert Straus, the owner of Straus Organic Dairy in Marin County, California, said. "If this goes through, there is a good chance we will no longer be organic."

He noted that keeping the animals out on pasture year-round contradicts state environmental regulations meant to prevent manure run-off during the winter rainy season.

In the northeast, the sentiment is much the same.  "Very few farmers use something like sacrificial pasture during the non-grazing season because they just don't have the land base, or the right soil type," said Ed Maltby, executive director the Northeast Organic Dairy Farmers Alliance, who was a vocal proponent for a new pasture regulation.

Instead, in places like Vermont and Maine, many organic dairy farmers bring their animals into barns for the coldest winter months, or keep them in barn yards where manure can be removed and fresh hay bedding provided. Then, when the grass is growing again in the spring, the cows are put out in fields.

In short, while many proponents were overjoyed that the USDA finally acted on getting a new pasture regulation, "it was way too perscriptive," said Jim Riddle, a longtime trainer of organic certifiers who served as chairman on the National Organic Standards Board that recommended new pasture regulations.

"To require an animal to graze during the grazing season does not require the level of detail in this proposed rule," he said.

There are many other issues with the regulation, but I will mention just one more -- a requirement that does away with grain finishing of organic livestock. Now, although I'm a proponent of grass-fed beef, a requirement that limits does away with grain finishing of organic beef animals would quash the organic meat market. (It does so by requiring 30% nutritional intake from pasture during the finishing period as well.) 

The result would be to block a lot of farmers from raising organic livestock and further shift the market to overseas producers in Australia and Uruguay who export organic meat to the U.S. market. (Yes, even with the growth and awareness of local foods).

Why do some U.S. organic farmers finish their animals on grain? Because they want to receive the premium they get with a "choice" USDA label, which requires the fat marbling that comes with grain finishing. They can avoid that if they raise grass fed animals and sell them direct to the public, but as much as I applaud that nascent movement, it is a minute portion of the market. Many Americans still want marbled beef, even if they are looking for the organic label.

"If the regulation stands, a lot of livestock farmers tell me they're going to get out of organic," said Dave Carter, another former NOSB chairman and executive director of the American Bison Association.

But it isn't just an economic issue. Riddle said that animals can be raised responsibly and organically and still be finished 120 days on grain. "An organic animal finished on grain is significantly different than a conventional animal finished on a CAFO," he said, because of organic requirements that ban antibiotics, hormones, and ensure environmental and humane animal treatment.

The National Organic Coalition came up with a compromise that allows grain finishing for 120 days but also requires the animals have access to pasture. At first glance, this imperfect compromise makes sense.

The main point -- the new regulation is a good one: it requires that animals graze. But it should be rewritten to be less prescriptive, so that farmers can actually meet its requirements and it achieves its broader goal; that is, getting animals out on grass but also protectng their health and the environment during the non-grazing season.

A number of organizations have the means for commenting to the USDA (with proposed language). Here are a few:

- Northeast Organic Dairy Farmers Alliance
- National Organic Coalition
- Organic Farming Reseach Foundation
- Organic Consumers Association
- Cornucopia Institute

But remember, comment is due Tuesday, so read this and act.

Image link: NODPA

Organic Pasture Rule, Part II

There was an early sense of relief at the USDA's newly proposed organic pasture rule, but the devil, as they say, is in the details. I've been hearing questions about the rule and its mandates that fall outside the much-debated 120-day, 30% forage minimum. I haven't digested the criticism or concern yet, so if you have, post a comment. I hope to write on this further as the issues gel.
- Samuel Fromartz

RFK Jr at EPA?

(Note: fixed headline... thanks for pointing out Barbara...)

Politico is reporting that "President-elect Barack Obama is strongly considering Robert F. KennedyJr. to head the Environmental Protection Agency, a Cabinet post, Democratic officials told Politico."

Even David Roberts over at Grist.org was taken aback because of Kennedy's activist history, but, hey, maybe that's what the EPA needs. Last time I heard JFK Jr a couple of years back he was suing factory farm pork producers in North Carolina, just one in the long list of actions he's taken.
- Samuel Fromartz

Organic Pasture Rule Gets Media Ink

Bloomberg's Cindy Skrzycki had a good explanatory column on the organic pasture rule in the Washington Post, noting my "big win" comment she first read here. But she quoted others who questioned the USDA's motives, like Ronnie Cummins over at the Organic Consumers Association. The USDA has lost credibility in the past on decisions in the organic sector, so it will be interesting to see if this attempt to close the grazing loophole will restore its stature at all.

I also wonder if presidential politics played a role at all in the timing of the decision -- that is, in trying to get the rule through before a new administration comes in. The Bush administration is actually quite busy weakening regulations across the board so this might be that rare, under-the-radar instance of an actual tightening, reflecting a broad industry and consumer consensus. Still, they might have wanted to get it done before the new guys arrived and started meddling again ... just a guess.
- Samuel Fromartz

Organic Animals Must Graze, USDA Rules

Resolving a longstanding dispute, the USDA published a proposed pasture regulation that sets new grazing requirements for organic livestock and bans confined feedlots from the industry.

Dairy farmers had been pushing for this rule for at least three years, though variations had been proposed since at least 2000. According to the USDA's document on the regulation, published in the Federal Register, more than 85,000 people sent in letters in support of a stricter pasture requirement (pdf).

Advocates say the USDA actually got the new pasture regulation right. In a press release from the National Organic Coalition, Kathie Arnold, a New York State organic dairy farmer, said: “This draft rule provides specific language needed for enforcement of one of the central tenets of organically produced livestock—that organic livestock spend a considerable part of their lives in their natural pasture habitat and receive a significant portion of their food from fresh, green, growing pasture.”

Previously, the USDA required organic livestock to have "access to pasture," a term that was so loosely interpreted that  several prominent organic CAFOs (concentrated animal feeding operations) arose in the industry, housing thousands of cows with little or no grazing on pasture. The pasture loophole undermined the purpose and intent of organic livestock agriculture.

Now, "Dry lots and feedlots are prohibited," the proposed regulation says.

Animals must graze throughout the growing season, which in some regions may be for the entire year. The bare minimum nationally would be 120 days. In the document, the USDA explains:

In the United States, growing seasons range from 121 days to 365 days, depending on location. By using the growing season as the minimum time period for grazing, the regulations ensure that ruminants raised in areas with longer grazing periods are not denied the opportunity to graze for more than the minimum of 120 days.

In addition 30% of a cow's nutritional needs must be met by pasture, which means they must be eating fresh grass.

If this rule is adopted, as expected, after the 60 day comment period, it will undo the disturbing rise of organic CAFOs and require that organic livestock graze on pasture, as consumers and farmers overwhelmingly expect.

In short, the regulation looks like a big win for organic integrity.

- Samuel Fromartz

Time To Boot HFCS out of Organic

In my mind, the words organic and high fructose corn syrup (HFCS) are oxymorons. How could you have such a product? Well, among most of those I talk to in the organic world, you can't.

A recent comment by the FDA seems to seal the matter further, since the agency deemed the substance "non-natural." Why is that an important distinction in the world of organic foods? Because unnatural food ingredients cannot be organic. Indeed, so called "synthetic" food ingredients cannot be used in organic food production unless they are specifically given an exemption on a regulatory list, and then, they cannot account for more than 5 percent of the ingredients in an organic product.

So what's the status of organic HFCS? Well a Santa Cruz-based company (and OTA member) sells an organic version of HFCS, which is produced by an Austrian ingredient company. Now organic HFCS may actually be allowed under EC rules, but given the "non-natural" distinction at the FDA, at the very least, it should not be allowed under US organic rules without an exemption. And I'd love to see the response to that application!