Submission Number: 00021
Received: 10/15/2010 2:08:14 PM
Commenter: Gary Fish
Organization: Maine Board of Pesticides Control
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
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Regarding the proposed revisions to the Green Guides section 260.9 Free-of and Non-Toxic Claims:
I am concerned that you have not addressed to overwhelming number of organic and natural food claims that say they are pesticide free, toxic pesticide free, persistent pesticide free, synthetic pesticide free and so on. None of these claims are accurate, unless the food has been tested for pesticide residues. Most organic produce tested by the USDA Pesticide Data Program shows pesticide residues on crops that are identified or labeled as organic or natural. Some of those residues are a result of the use of "organic" pesticides or other products approved for use by the USDA-NOP regulations, including synthetic pesticides.
These claims are almost always specious. Please consider regulating these claims because USDA does not do it.