On that note, instead of ADDING organic field testing to the existing system of record-keeping and record-checking - which costs upwards of $2,000 up-front per-farm - field testing should REPLACE record-keeping and record-checking, and thereby bring down the cost of organic certification.
Lastly, there is still the outstanding issue of "royalties" being collected by USDA-accredited certifiers. How can we expect companies that oversee the USDA National Organic Program to be objective if they stand to collect 1-3% of a farmer's GROSS revenue from each transaction they certify? Organic field testing must be carried out by independent inspectors, not by certifiers which have a vested interest in pushing more product to market.
TK: Field testing would create a higher standard, no doubt. For me, I would have hoped that USDA would publish all the testing information gathered in a single public database. Any information about organic testing will only obtained with great effort, it appears. This part of the rule explains:
AMS does not intend to integrate results into a single dataset, as was requested by some commenters. To minimize the reporting burden for certifying agents, this final rule does not require that certifying agents submit copies of test results to the Administrator; however, certifying agents continue to be required to report certain test results that are found in excess of federal regulatory tolerances or action levels for pesticide residues or environmental contaminants to the appropriate health agency under the section 205.670(g).
This final rule does not require reporting of testing data to the Administrator since this action is not intended as a data collection mechanism to draw conclusions about residues in organic products in general. AMS will verify compliance of certifying agents with this rule under the existing requirements for accreditation as discussed in the response to comments on Reporting Requirements. The NOP also notes that this final rule does not amend the existing requirement that results of all analyses and tests performed under section 205.670 be made available for public access, unless the testing is part of an ongoing compliance investigation. The public may access sampling results obtained by certifying agents under the existing regulations.