John Mitchell Wrote:

>Bob, is there a way to submit comments to the USDA via email or through a
>Web site?

Yes, you may submit comments through the National Organic Program (NOP) web
site at:
http://www.ams.usda.gov/nop/

I cannot find the word "honey" anywhere in the proposed rule. When the
federal rule is adopted, California will have to fall in line with it.  The
California Organic Foods Act also seems to be mute on the subject.  You can
find this at: http://www.cdfa.ca.gov/inspection/fve/organic_act/index.html.

I will try to find out what the major certifying agency is doing.  A quick
web search found one private agency in Oregon that apparently certifies
organic honey. Organic certification is currently done by 49 state and
private organizations. They can all have different rules because there is no
national standard.  If the NOP does not address organic standards for honey,
I am not quite sure what that means.  It may mean that the local certifying
agencies can write their own standards, as long as they are not inconsistent
with the NOP.

BTW, antibiotics are not going to be allowed in livestock production under
the proposed rule.  I think this has to do with E. coli and resistant
bacteria concerns.  Beekeepers could certainly argue that treating for AFB
is different.

Bob Roach