In a message dated 4/3/00 6:01:14 AM, [log in to unmask] writes:

<< 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. >>

   Thanks Bob. The USDA site allows a search of the comments presented so
far. A search under "honey" for submitted comments only turned up the
following. I thought it would be a valuable contribution to the discussion of
organic honey here. The comments are from a honey packer from California who
certifies organic honey under Oregon state programs.

   "I have just learned that the revised proposed rule concerning the
National
Organic Program contains no standards for organically gathered honey. My
company currently uses certified organic honey as an ingredient and packs
certified organic honey for resale.
   The standards that our third party certifier uses for honey are very
strict, and pertinent to concerns about honey gathering. They disallow the
use of synthetic strips to treat for mites, killing off the hive at the
end of each season, and use of oil base paints. They require a four mile
radius free from industry or conventional crops. My husband and I
personally visited the bee yards and honey operation of our major source
of organic honey. It is so remote, we are thoroughly confident in the
certifiability of that honey production. There are few locations that
qualify for such strict standards, but they do exist - in Mexico and
Hawaii and Canada and Africa.
    If an organic distiction can be made for honey, then we believe that the
AMS should leave room for us to do so in the new rules. Please investigate
the honey standards that have been used by Oregon Tilth www.tilth.org,
Quality Assurance International 858-792-3531, and OCIA www.ocia.org, and
incorporate them into your new NOP rules."

   Interestingly, the proposed organic regulations here would also codify
certain moral behaviors that have nothing to do with health or the
environment (killing off the hive at the end of each season).
   And for the subscribers to "The Forgotten Pollinators" theory of
competition, (I'm devil's advocating for a position I don't embrace) consider
this: requiring certified apiaries to be located miles from conventional
agricultural land would encourage organic honey producers to establish
production apiaries in true wilderness areas, which, ironically, could put
substantial pressure on native pollinator populations in areas with the least
carrying capacity, at least in the U.S, Mexico and Canada.
   I could not locate any standards for Oregon Tilth on their Web page.
Oregon state (OCIA) has moderately detailed regulations, which include this:
   "Extracting facility should be very clean and inspected annually by
federal food
inspectors."
   I am not aware of too many hobbyists—or even sideliners—who have their
extracting facilities inspected annually by a federal food inspector. It
seems that organic honey certification, under this set of rules, would
exclude all but the largest, most well-capitalized, producers who could
afford a facility to meet federal standards, to produce "organic honey."
  Being a hobbiest/sideliner, this dampens my enthusiasm for an organic
certification program. Even worse, for customers who are willing to pay 5-10%
premium for a superior honey product, they may choose to spend that money on
a faraway packer's organic certification at the grocery shelf, rather than a
hobbyist's locally produced honey at the roadside stand.
  Of course, I understand that there is a point of view expressed from time
to time that some hobbyists are reckless or ignorant in their use of
medicines/pesticides, and that hobbyists are more prone to using
unregistered, or even illegal, treatments. From that point of view (devil's
advocating again), organic certification—by excluding hobbyists—might allow
the consumer to make a truly informed buying decision about the health and
safety of a honey product.