By MISCHA POPOFF

For the Capital Press

I am at a loss to understand what exactly it is about the USDA National Organic Program's certified-organic label that makes Steve Brown believe it clarifies what's in organic wines ("Labels clarify what's in organic wine" Capital Press, Dec. 21).

By the USDA's own admittance, there is basically no testing to ensure prohibited substances are not being used on organic farms or in processing facilities. In fact, "the number of results reported to the NOP in 2011 represents a sampling rate of less than 1 percent of certified operations." Things go rapidly downhill from there because it turns out that "the majority of results reported to the NOP in 2011 were received from certifying agents which are headquartered outside the United States, where periodic residue testing is a requirement under international organic standards," according to the Nov. 9 Federal Register.

The inescapable conclusion is that there is basically no scientific analysis being carried out under the NOP to ensure the American certified-organic label has any meaning whatsoever. There is, in short, little or no guarantee that prohibited substances are not being used.

Miles McEvoy, the deputy administrator of the NOP, and his assistant Jim Brownlee can correct me if I'm wrong, but with less than 1 percent of operations being tested, results are, sadly, in line with results in Canada: positive for prohibited substances a whopping 24 percent of the time. With this in mind, it would seem that the NOP's four categories of organic wine which are outlined in Brown's story are essentially meaningless.

McEvoy should be commended for his proposal that all agencies accredited by the USDA should begin sampling and testing "from a minimum of 5 percent of the operations it certifies." This is the same percentage of applicants that Miles tested back when he was with the Washington State Department of Agriculture's organic program, and it represents a step in the right direction.

But when, pray tell, will this step be taken? McEvoy's been promising this for three years now, according to the March 19, 2010, New York Times. What's he waiting for? Another election?

What's more, sampling and testing from 100 percent of operations would be an even better idea. After all, this is a multibillion dollar industry which makes marketing claims that are, with only rare exception, easily proved or disproved through basic testing. And besides, organic field testing will cost less than 10 percent of what the current system of record-keeping and record-checking costs.

On this point of the cost of organic field testing, the same USDA report quoted from above indicates incorrectly that the cost of organic testing will be in the neighborhood of $491.57 per sample. But whoever came up with this figure failed to take into consideration bulk discounts from labs and reduced, bulk-rate shipping and packaging. As an organic inspector, I have obtained the same multi-residue analysis referred to in this report for just $125 per test from federally accredited labs in both the United States and Canada -- about 75 percent off the USDA's estimate.

There is also the fact that organic inspectors already visit every single USDA-certified organic farm and processor in the world at least once a year. As such, there is no need to pay these inspectors any additional money for the collecting of samples. Just make it part of an inspector's job description, and cut down on some of the paperwork to make time for the collection of a sample during the existing visual-field-inspection portion of the current inspection process.

I am at a loss to understand why some people continue to tout the alleged benefits of the USDA's National Organic Program when the USDA itself admits the existence of huge shortcomings when it comes to verifying the validity of USDA NOP-certified-organic food and drink. Surely your readers would be better served if a healthy dose of skepticism was to enter your outlet's reportage on the organic sector.

Who knows? You might even end up being the catalyst for change at the USDA, and usher in the type of organic testing the American Consumers Union called for way back in 1997. Isn't it about time?

Mischa Popoff of Osoyoos, British Columbia, is an organic farmer and inspector and the author of "Is it Organic? The inside story of the organic industry."