I said:

>> I'd guess that handing the standards to a judge and
>> mentioning the "Equal Protection" clause of the 14th
>> amendment... and the "due process" requirement of the
>> 5th amendment...

James Kilty said:

> will you translate this for a non-US person?

The two amendments to the US Constitution I cited assure
"fair and equal treatment under the law" to all citizens,
and assure those with claims of unequal treatment "due
process" in the form of review, oversight, censure, whatever.
Its the old "level playing field" concept.  Its not just a
good idea, its the law of the land.  (I think we copied the
basic idea from British common law, didn't we?  Something
about the King's Court giving a fair hearing to all?)

The organic standards as currently worded appear to amount
to nothing less than a wholesale granting of very significant
economic advantages to a very small group of producers
without recourse.  The retail price delta between "organic"
and non-organic food can be considerable.  (The actual net
profits in organic food are not much better in many cases,
but an organic farmer will never be left "stuck" with a
crop, and will gross a much higher price per unit, so
all he must do is control his costs.)

In my view, there are a significant number of specific
examples that, if briefly explained, would show that the
proposed USDA standards for organic honey (as currently
worded) make very generalized assumptions about specific
types of land uses, and assume, perhaps incorrectly in many
cases, that certain land uses in and of themselves render
the land unfit for "organic" foraging.

I'm not saying that the assumptions made are not accurate
or reasonable "in general", but to flatly exclude anyone
with a "golf course" near their hives from certifying as
organic is silly.  I agree that many golf courses are
sprayed with so many chemicals that they allow extended
playing time after dusk because the turf actually glows
in the dark, but this does not imply that all of them are.
I guess the extreme case would be a beekeeper with a miniature
golf course near his hives.  (The "turf" in miniature golf
is indoor-outdoor carpeting, which is vacuumed rather than
sprayed.)  "Golf courses" are just one example of "labels"
for land use.  It is merely a simple and clear example.

As a result, the proposed standards simply pre-select
"winners" and "losers" in the marketplace, while doing
nothing tangible to assure that even a single drop of
the resulting "organic honey" is even uncontaminated,
let alone "organic".

So, if you keep bees in the middle of nowhere, you can
consider "going organic".  If you don't, you can't.
Never mind the facts of the matter, never mind the
specifics.  And if you live in the middle of nowhere,
you are trusted to exclude yourself from the program
if you know of "non-organic" activities within the
range of your bees.  (Yeah right, and every single
bottle of "Pure Sourwood Honey" sold really contains
100% Sourwood honey, uh huh, sure.)

I think that the wording will be clarified over time
as a result of specific "appeals", but why should
mere beekeepers have to spend the time and money to
point out such glaring problems to the "experts"?

> I like the idea that bees might be selective in what they
> bring back to the hive (and perhaps plants are selective in
> what they put into nectar).

But bees are not "selective" at all!  There are constant
reports of bees mistaking grain dust for pollen, sawdust
for pollen, roof tar for propolis, etc.

   Heck, just this week I got a "swarm call" from
   the owner of a store and gas station who was
   sure he had a swarm in one of his waste cans
   by the door.  This was one of the square types,
   with four openings covered by a "roof" of sorts,
   and the bees were certainly coming and going.
   The bees had stumbled upon the "empty" soft-drink
   cans in the garbage, each can having a small amount
   of very high-sugar "nectar" in it.  I collected my
   fee not by removing a swarm, but by fabricating
   "swinging doors" for the trashcans from cardboard
   boxes and the beekeeper's universal tool, duct tape.
   The owner promised to order new can tops with
   proper "push to open" doors, and patted me on the
   back when I showed him two bees approach the can,
   circle, land, get confused, and leave again.
   (Its nice when a guy smiles while writing you a
   check for your "bee removal" fee.)

> Is there an international comparison of pesticide contaminants
> in honey in different countries with different agricultural and
> non-agricultural land use practices?

I dunno, but I doubt it.  Beekeepers tend to be like fly
fishermen.  Neither wants to reveal his "good spots" to anyone.

> Is there any study of changes over, say 40 years, in the mineral
> content of honey, given the drastic degradation in nutritional
> standards in fruit and veg over this time.

Again, I dunno.  I was not even aware that there was a "drastic"
degradation in fruit and veggies.  Offhand, I'd guess that it
would be difficult to compare data collected using the techniques
of 40 years ago to data collected with modern techniques. Not
exactly "apples to apples", even if one were actually comparing
apples to apples.

                jim (Who claims that all honey is "organic"
                 by definition, unless it tests as
                 contaminated, in which case it would
                 no longer be fit to be sold at all.)

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