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No Standardization Without Representation (Part 2)

Tim’s clarion call has turned out to be prescient, as the sustainability issue is being co-opted by people who choose to define sustainability in a manner that comports with their ideological predispositions, rather than engaging in vigorous debate on what principles should guide an understanding of sustainability. Specifically, these people have basically proclaimed that only organic agriculture is sustainable. This is a proposition that is, to put it mildly, highly debatable.

What has happened is that the American National Standards Institute (ANSI) coordinates the development and use of voluntary standards. An organization called the Leonardo Academy, which declares itself to be “The Sustainability Experts,” is an ANSI-accredited standards developer. Sometimes the Leonardo Academy provides “ANSI process administration” for standards being developed by other organizations.

In this case, Scientific Certification Systems, “in consultation with numerous stakeholders,” has authored a draft standard with the rubber stamp of the Leonardo Academy. In this context, there has been an ongoing process that has resulted in this draft standard.

As soon as the draft was published, the outcry began. A group of 30 agricultural organizations sent a letter:

January 31, 2008

Mr. Michael Arny, President
Leonardo Academy
1526 Chandler Street,
Madison, Wisconsin 53711

Dear Mr. Arny,

We are writing in follow-up to our conversation on January 17th with Anne Caldas of American National Standards Institute (ANSI) to express our concern about the process used to establish the proposed American National Standards Institute Draft Standard for Sustainable Agriculture for Trial Use. We understand the Leonardo Academy’s desire to generate and harmonize sustainability standards. It is unfortunate, however, that this standard with its important implications for American agriculture was processed in this manner. We are concerned that the ANSI process has not been followed and that this may have already led to irremediable defects in terms of ANSI’s ability to receive approval. Stakeholder concerns and the controversial nature of the standard make procedural issues of utmost importance.

  • It equates organic practices with best agricultural practices, a conclusion that would be soundly rejected by many in the scientific community and an issue that will provoke intense debate between the organic and conventional agricultural communities.
  • It rejects the use of biotechnology, perpetuating scientifically unsound and overly precautionary approaches that have been rejected by many governments, including our own, and which have provoked significant trade concerns.
  • It requires that producers follow organic processes rather than achieving specific results that can be objectively and metrically validated as sustainable, making it unsuitable for the very sectors of agriculture that would be impacted.
  • It requires agriculture to engage in discussions of carbon emission standards that are well beyond the technological knowledge and capability of most of the participants likely to be engaged in this standards process. Carbon emissions standards are the proper focus of climate change discussions and regulatory guidance processes, which have just begun.
  • It applies to biofuels, which are also the subject of many other standard setting efforts, including the International Standards Organization (ISO) and the Roundtable on Sustainable Biofuels. Food and agriculture stakeholders are also participating in other initiatives including legislative discussions. We believe that the ANSI process is not being followed and we would like to highlight several concerns.
  • The draft standard for trial use was not notified to “materially affected stakeholders” prior to its adoption for trial use by the Leonardo Academy.
  • The draft standard has not since been notified effectively to materially affected stakeholders both domestically and internationally.
  • The standard’s stated purpose is to define sustainable agriculture. However, the draft standard as written clearly pertains to “sustainable organic agriculture” only and does not meet the definition of “sustainable agriculture” as defined in law by the 1990 Farm Bill. Therefore, had it been notified as a standard for “sustainable agriculture”, it would have been misleading and inaccurate.
  • Because the Leonardo Academy has demonstrated that it has little knowledge of or experience with the broad range of stakeholders that will be affected by this standard, we are concerned that the process it is following will not accurately reflect the balance or scope required by its rules and by ANSI’s.
  • We are concerned that the Leonardo process will not garner sufficient input to ensure that this standard is credible, particularly since Leonardo has not established a group composed of government experts.

We encourage the Leonardo Academy to narrow the scope of this standard to organic agriculture and work with other ongoing standard setting efforts. We believe that the inevitable years of intense debate on irresolvable conflicts that this standards process will provoke can and should be avoided.

American Farm Bureau

American Seed Trade Association

American Soybean Association

American Sugar Alliance

Animal Health Institute

Biotechnology Industry Association

California Association of Wheat Growers

California Citrus Quality Council

California Dried Plum Board

California Grain and Feed Association

California Grape & Tree Fruit League

California Pear Growers

California Seed Association

California Warehouse Association

California Tree Fruit Agreement

Croplife America

Cotton Incorporated

Del Monte Foods

Florida Fruit and Vegetable Association

Grocery Manufacturers Association

Lodi-Woodbridge Winegrape Commission

National Association of Wheat Growers

National Cattlemen’s Beef Association

National Corn Growers Association

National Cotton Council

National Oilseed Processors Association

National Sorghum Producers

North American Millers’ Association


United Soybean Board

U.S. Rice Producers Association

United States Soy Export Council

USA Rice Federation

cc Mr. Joseph Bhatia, Presiden
Ms. Anne Caldas, Director
Procedures and Standards Administration
Accreditation Services
American National Standards Institute
25 West 43 Street, 4th Floor
NY, NY 10036

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