Title: Grace Gershuny Papers
Inclusive Dates: 1977-2015 (bulk 1984-2010)

Creator:

• Gershuny, Grace, 1950-

Call Number: Mss 1227

Quantity: 5.2 cubic feet (5 records center cartons and 1 half-archives box) and 90.0 megabytes
Repository:

Wisconsin Historical Society, Division of Library, Archives, and Museum Collections

Archival Locations:

Wisconsin Historical Society (Map)

COLLECTION MAY BE STORED OFF-SITE: see catalog entry to request materials and for additional information.

Abstract:

Papers, circa 1985-2010, of Grace Gershuny, organic farmer, writer, educator, administrator, and consultant. Gershuny served as a staff member with the USDA National Organic Program (NOP) and was a main writer for several sections of the organic rule standards. She was involved with other organic and sustainable agriculture organizations, including the Organic Crop Improvement Association (OCIA), Organic Foods Production Association of North America (OFPANA), Organic Trade Association (OTA), Rodale Institute, and other national organizations. Gershuny's work as an editor, author, and teacher is also documented in the papers.

Note:

Forms part of the Organic and Sustainable Agriculture Collection.
The Wisconsin Historical Society Library holds Gershuny's memoir, Organic Revolutionary: A Memoir of the Movement for Real Food, Planetary Healing, and Human Liberation.

Language: English

URL to cite for this finding aid: http://digital.library.wisc.edu/1711.dl/wiarchives.uw-whs-mss01227

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Grace Gershuny was born in New York State in 1950. She graduated in 1971 from Queens College of the City University of New York with a B.A. in mass communications. After a couple of years living in an urban commune in Montreal, she settled in Vermont in 1973. She became involved with the Natural Organic Farmers Association (NOFA, later renamed the Northeast Organic Farming Association) when she started vegetable gardening, and in 1975 helped organize the Northeast Kingdom Farmers Market in Newport, Vermont. In 1977 she started to work on a certification program for NOFA and helped to write its organic standards. By 1979 she was a state coordinator for its certification program. She also testified for NOFA before hearings called by Secretary of Agriculture Bob Bergland, and presented her vision of a model Vermont town she called "Newville" and discussed its projected regional food system.

In 1980 Gershuny returned to graduate school at the University of Vermont and earned a M.A. in extension education in 1982. The first edition of her book on soil management, The Soul of Soil, was published the following year. A second edition, revised with Joe Smillie and Susan Boyer, was published in 1986, and was followed by two subsequent editions. Another book, Start with the Soil, came out in 1993. Gershuny also served as the editor of Organic Farmer: The Digest of Sustainable Agriculture, a quarterly publication for the sustainable agriculture community, from 1989 to 1994.

A self-styled "organicrat," Gershuny was also involved in the establishment of both the Organic Crop Improvement Association (OCIA or "the Organic CIA"), a national certification program with regional chapters, and was a founding member of the Organic Foods Production Association of North America (OFPANA), an organic industry group that was established at a June 1984 meeting sponsored by the International Federation of Organic Agriculture Movements (IFOAM). It incorporated the following year, approved by-laws for the organization, and created guidelines for certification organizations. It was later renamed the Organic Trade Association (OTA). Another offshoot of OFPANA was the Organic Farmers Association Council (OFAC), a group of farmer-led member organizations.

In 1985, Gershuny operated Gaia Associates, a business focused on ecological agriculture consulting and organic certification. Little Bear Trading Company (LBTC) was a major client, and Gershuny made a tour certifying farms across the country for Little Bear in 1988.

Gershuny and Joseph Smillie, a farmer based in Quebec, Canada, also worked together on devising the organic certification standards ("Guidelines for the Organic Industry") for the Organic Foods Production Association of North America (OFPANA, later known as the Organic Trade Association (OTA)). The Guidelines in turn influenced other organic certification standards. Philosophical disagreement arose between those such as Gershuny and Smillie, who viewed organic agriculture as a systems-based approach and felt that organic production standards should be grounded in overall ecological effects on the soil and the farm ("agronomic responsibility") and those who favored an "origin of materials" approach, or the absence of synthetics. The latter approach became the basis of the OFPANA/OTA standards, and was to influence the development of the national organic standards.

In September 1994, Gershuny began working for the National Organic Program, which was authorized by the 1990 Organic Foods Production Act (OFPA). She started by working on a definition of "organic" and drafted a set of principles ("Prologue: Moving Towards Sustainability") as the basis for the regulations governing organic food. Gershuny also served as the main writer for portions of the 1997 proposed rule for organic standards, including the production and handling standards and preamble, the National List and preamble, and certification regulations. Gershuny also served on the Crops Committee for the National Organic Standards Board (NOSB) in 1997.

Gershuny has written about her experiences in the organic food movement, and the third edition of her book Organic Revolutionary: A Memoir of the Movement for Real Food, Planetary Healing, and Human Liberation came out in 2020. She has taught at Green Mountain College and the Institute for Social Ecology (ISE) at Goddard College and has served on the ISE board. For further information, see her website.

The Grace Gershuny papers document the rule-making process of the National Organic Program (NOP) from the perspective of a staff member who had extensive prior experience in organic agriculture as a farmer, farm inspector, editor, writer, and founding member of early organic farming organizations. As the main writer on a number of sections of the proposed organic rule, Gershuny produced numerous drafts, which she and other NOP staff members revised, with input from the Office of General Counsel (OGC), comments from organic industry organizations, and the general public. The drafts, particularly the electronic files, frequently also include outlines, memos, discussion papers, and recommendations.

Public comments to the NOSB and Gershuny's writings document her perspective on organic agriculture and the tensions inherent in standards setting and public perception and expectations.

The papers are arranged in four series: BIOGRAPHICAL, NATIONAL ORGANIC PROGRAM (NOP), ORGANIC FOODS PRODUCTION ASSOCIATION OF NORTH AMERICA (OFPANA) / ORGANIC TRADE ASSOCIATION (OTA), and SUBJECT FILE.

The BIOGRAPHICAL series includes limited personal correspondence such as holiday letters where Gershuny recaps her work experiences, résumés, teaching files from Goddard College and the Institute of Social Ecology, and files related to her book, The Soul of Soil.

The NATIONAL ORGANIC PROGRAM (NOP) series includes Gershuny's handwritten journals from her tenure at the NOP, with frequent entries including meeting notes, to-do lists, and problems, goals, and challenges she identified.

The June 1997 draft of the first proposed rule was grounded in the definitions established in the Prologue document that Gershuny had worked on at the beginning of her tenure at the NOP, and the system of organic farming and handling (SOFAH) that it laid out. Subsequent changes imposed by the Office of Management and Budget (OMB) were reflected in the proposed rule as published in the Federal Register in December 1997. The manuscript portion of the papers includes annotated copies of section drafts, and largely follow Gershuny's original folder titles, while the electronic files retain Gershuny's file naming conventions for these section drafts. Researchers may also find the files regarding the Office of General Counsel (OGC) and Office of Management and Budget (OMB) of interest, as Gershuny discusses in her memoir, Organic Revolutionary, for their role in the rule making process. Also included at the end of this series is a folder of writings and presentations that Gershuny made regarding her role at the NOP and how she negotiated relations with others in the organic community who were outside of the federal bureaucracy. The folder of news clippings also documents how the original proposed rule was received by various stakeholders.

The ORGANIC FOODS PRODUCTION ASSOCIATION OF NORTH AMERICA (OFPANA) / ORGANIC TRADE ASSOCIATION (OTA) series, while smaller in scope than the NOP series, provides points of comparison for another standards setting process, as well as general files for organizations with which Gershuny was involved.

The SUBJECT FILE series documents Gershuny's role with the Codex organic standard, as well as her role representing the NOP on the Council on Sustainable Development of the United States Department of Agriculture (USDA), as well as other USDA projects related to sustainable agriculture. Also in this series are the files for Gershuny's inspection work operating as Gaia Associates/Gaia Services, her tenure as the editor of Organic Farmer magazine, her volunteer work with the Jamaica Organic Growers Association (JOGA), and a small amount of material dealing with Gershuny's work with organic farmers' associations in Vermont.

Organic and Sustainable Agriculture Publications, 1988-2000 (M2022-042)
Grace Gershuny Papers, 1976-2007. University of Massachusetts Amherst Libraries, Special Collections and University Archives (MS793)
Grace Gershuny/NOFA collection, 1980-2012. Vermont Historical Society, Barre, Vermont (MSA 817)

Acquisition Information

Presented by Grace Gershuny, St. Johnsbury, Vermont, April 23, 2021. Accession Number: M2022-041

Processing Information

Processed by Julia Wong, August 2023.

Organic farming -- Standards -- United States.Agricultural laws and legislation -- United States.Manuscript collection.National Organic Program (U.S.)

Mss 1227	Series: Biographical
Electronic   Folder	Correspondence, 1989-1999
Electronic   Folder	Résumés, 1991-1999
	Teaching
Electronic   Folder	Goddard College, 1992-1999
Electronic   Folder	Farm Bureau discussion forum, 1995
Electronic   Folder	Institute for Social Ecology (ISE), 1992-1999
	Writing
Electronic   Folder	Soul of Soil files, 1991-1995
Electronic   Folder	Press release, 3rd edition, 1995 April
	Series: National Organic Program (NOP)	⇧
Box   1   Folder   1-2	General background, 1992-2000
Box   1   Folder   3-4	Accreditation fees, 1994-1995
Electronic   Folder	Activity reports, 1994-1997
Box   1   Folder   5	Assignments, job description, 1996-2000
Electronic   Folder	Performance standards review, 1995-1999
Box   1   Folder   6-7	Civil rights impact analysis, 1997-1999
	Correspondence, memos
Box   1   Folder   8	1992-1999, undated
Electronic   Folder	1994-1996
Box   1   Folder   9	Current thinking, 1998 February-December
	Genetically engineered organisms (GEOs)
Box   1   Folder   10	1997-1998
Electronic   Folder	1997
Box   1   Folder   11	Inspectors, 1994-1995
Box   1   Folder   12-15	Manuals, 1996-1997
Electronic   Folder	Miscellaneous, 1998-1999
Box   1   Folder   16	NOP Journals, 1994 September-1999 April Note: Meeting and scheduling notes, reflections.
	National Organic Standards Board (NOSB)
Box   1   Folder   17-18	Committee work, 2005, 2010 Note: Discussion documents, draft guidance, comments, recommendations, notes.
Box   1   Folder   19	Accreditation Committee, 1992-1993, 1998
Box   1   Folder   20	Processing, Interdisciplinary Committees, 1998-1999
Box   1   Folder   21-22	NOSB documents, 1994, 1996-1998 Note: Materials, synthetics.
Box   1   Folder   23	Testimony, position papers, 1992-1993
	Office of the General Counsel (OGC) discussions Note: Drafts, OGC mark-up, responses.
	Accreditation
Electronic   Folder	1994-1996
Box   1   Folder   24-25	1995-1997
Box   1   Folder   26-29	Certification, 1996 September-1997 April
Box   1   Folder   30	Conflict of interest, 1996 September 19, undated
	Definitions
Electronic   Folder	1995-1996
Box   1   Folder   31	1996 November-December-1997 April, undated
Box   1   Folder   32	Livestock, 1996 December-1997 January
	National List (NL)
Box   1   Folder   33-34	1996 September-December-1997, undated
Electronic   Folder	Preamble, 1996
Box   1   Folder   35-36	Production and handling standards, preamble, 1996 December
Box   1   Folder   37-39	Office of Management and Budget (OMB) changes, background documents, memos, 1997
Electronic   Folder	Organic certifiers, 1994-1995
Box   2   Folder   1	Pesticide residue monitoring, 1989-1995
	Proposed rule
Box   2   Folder   2	Consumer and environmental misconceptions, 1995, 1998
	Drafts
Electronic   Folder	1995 June-1996 June
Electronic   Folder	1995 October-1996 April
Box   2   Folder   3-5	1997 January-February
Box   2   Folder   6-11	1997 June
Electronic   Folder	1995-1997
Box   2   Folder   12	Fact sheets, Q&A, 1997 December
Box   2   Folder   13	Internal correspondence, 1997
	News clippings
Electronic   Folder	1995-1998
Box   2   Folder   14	1997 December-1998 June Note: See also The Natural Farmer, Spring 1998, for a special supplement on The National Organic Program in M2022-042.
Box   2   Folder   15	OFPA, checklist, 1996-1997
	Public comments, discussion
Box   2   Folder   16-17	1995-1998 Note: Includes comment analysis.
Electronic   Folder	1997-1999
Box   2   Folder   18	Certifiers, 1998 Note: Includes Farm Verified Organic (FVO), California Certified Organic Farmers (CCOF), Northeast Organic Farming Association of Vermont (NOFA-VT), Organic Trade Association (OTA).
Box   2   Folder   19	Demeter Association Inc., 1998 April 28 Note: Public comments received binder. Second set of comments submitted by Demeter.
Box   2   Folder   20	Environmental Protection Agency (EPA), 1998 April 30 Note: Public comments received binder.
Box   2   Folder   21	Farm Verified Organic (FVO), 1998 March 12, April 20 Note: Public comments received binder.
Box   2   Folder   22	Horizon Organic Dairy, 1998 April 28 Note: Public comments received binder.
Box   2   Folder   23	Humane Society of the United States (HSUS), 1998 April 30 Note: Public comments received binder.
Box   2   Folder   24	Industry comments, 1998 Note: Subparts: Big 3, form letters, definitions (A); Livestock (B); Pesticide residues, UREC, compliance (C); Soil, manure, miscellaneous crops (D); Structure, admin, labels, certification, accreditation (E); Processing + handling (F)
Box   2   Folder   25	Lehman, Dale, 1998 April 23 Note: Public comments received binder.
Box   2   Folder   26	Mayor, James O., 1998 April 23 Note: Public comments received binder.
Box   2   Folder   27	Muir, Jim and Jenni, 1998 April 29 Note: Public comments received binder.
Box   2   Folder   28	National Broiler Council (NBC), Newark Natural Foods and Community Cooperative, 1998 April 27 Note: Public comments received binder.
Box   2   Folder   29	Northeast Organic Farming Association of New Jersey (NOFA-NJ), 1998 April 29 Note: Public comments received binder.
Box   2   Folder   30	Northeast Organic Farming Association of New York (NOFA-NY), 1998 April 27
	Organic Materials Review Institute (OMRI)
Box   2   Folder   31	Drafts, 1998 January-February
Box   2   Folder   32-33	Comment, 1998 May 13 Note: Public comments received binder.
Box   2   Folder   34-35	Organic Trade Association (OTA), 1998
Box   2   Folder   36-37	Comments, 1998, 1998 April 30 Note: 1998 comments include annotations and color-coded responses.
Box   2   Folder   38-40	Drafts, 1998 March Note: March 9, 1998 draft in Public comments received binder.
Box   2   Folder   41	Pavich Family Farms, 1998 April 27 Note: Public comments received binder.
Box   2   Folder   42	Seaweed standards, 1999-2000
Box   2   Folder   43	Texas Department of Agriculture (TDA), 1998 April 23
	Wallace Institute
Box   2   Folder   44	Analysis of National Organic Program, "Beyond the 'Big Three': A comprehensive analysis of the proposed National Organic Program," docket #TMD-94-00-2: annotated copy, 1998 April 30
Box   2   Folder   45-46	Comments, 1998 May Note: Public comments received binder.
Box   2   Folder   47	World Resources Institute (WRI), 1998 April 28 Note: Public comments received binder.
Box   2   Folder   48	Summary charts (matrix), 1995-1997
	Public information
Electronic   Folder	1995-1998
Box   2   Folder   49	1997 August-December
Box   2   Folder   50-51	Reference documents, 1990, 1996-1998 Note: OFPA, NOSB contact lists.
	Regulations drafts Note: Drafts, OGC mark-ups, responses.
Box   3   Folder   1	Accreditation, 1997, undated
Box   3   Folder   2-3	Definitions, 1999 September, undated
Box   3   Folder   4	Enforcement, 1997 December
	National List (NL) standards, preamble
Box   3   Folder   5-7	1995-1997, undated
Electronic   Folder	1996-1997
Box   3   Folder   8-12	Production and handling standards, 1997, 1999 May-November, undated
Box   3   Folder   13-14	Revisions, 1998-1999
Electronic   Folder	1999 regulations, 1998-1999
Box   3   Folder   15-17	Subpart B: Organic Production and Handling, 1997
Electronic   Folder	undated
Box   3   Folder   18	Subpart F: Administrative, 1996-1997
Box   3   Folder   19	Sustainable agriculture principles, 1991-1995
Box   3   Folder   20	User fees, 1995-1998
Box   3   Folder   21	Writings, drafts, presentations, 1994-2003 Note: Includes presentations on Gershuny's role in the NOP.
	Series: Organic Foods Production Association of North America (OFPANA)/Organic Trade Association (OTA)	⇧
	Subseries: Organic Foods Production Association of North America (OFPANA)
Box   3   Folder   22-30	Chronological files, 1984-1992 Note: By-laws, articles of incorporation, membership and Board of Directors meeting minutes, press releases, memos, and correspondence.
	Board of Directors
Box   3   Folder   31	Meeting notes, 1985-1986
Box   3   Folder   32	Board of Directors retreat (June 3-6, 1989), 1989
Box   3   Folder   33	Evaluation protocol, 1985-1987 Note: OFPANA Guidelines for Organic Certification Programs.
	Guidelines for the Certification of Organic Food Note: Bound copy.
Box   3   Folder   34	Drafts, 1985 July-October Note: Includes "Work Copy": annotated.
Box   3   Folder   35	Draft comments, 1985-1986 March
Box   3   Folder   36	Guidelines for the Organic Food Industry, 1986, revised 1988 January
Box   3   Folder   37	Guidelines revision, 1991
Electronic   Folder	Crop production guidelines revision, 1991-1992
Box   3   Folder   38	Membership directory, 1992 Note: First edition.
Box   3   Folder   39	Natural Foods Merchandiser inserts, 1987 October, 1988 November Note: OFPANA history.
Box   3   Folder   40	Organic certification reciprocity, accreditation, 1989
Box   3   Folder   41-42	Organic definition, 1989-1995
Box   4   Folder   1	Organic Farmers' Association Council (OFAC) organizing, 1989, 1993-1994 Note: First Convening Assembly, Leavenworth, Kansas, December 2-3, 1989.
Box   4   Folder   2	Position paper #1: "Laboratory Testing and the Production and Marketing of Certified Organic Foods," 1986 December
Box   4   Folder   3-4	Technical Committee, 1987-1991
	Subseries: Organic Trade Association (OTA)	⇧
Box   4   Folder   5-7	Comments to National Organic Standards Board (NOSB), 2006-2009 Note: Includes Gershuny's public comment on "Definitions of Organic and Synthetic: Historical Perspective and a Modest Proposal," November 2007.
Box   4   Folder   8-9	Global Organic Textile Standard (GOTS) Technical Committee, 2005-2009
Box   4   Folder   10	GOTS training, 2008
Box   4   Folder   11	NOP label, 2007-2008
Box   4   Folder   12-13	Group Certification Task Force, 2007-2008
Box   4   Folder   14	Materials Task Force, 2005
Box   4   Folder   15	Harvey case, 2005-2006
Box   4   Folder   16-17	Synthetic definition, comment to NOSB, 2005-2009
Box   4   Folder   18	NOSB meeting resource booklet, 2015 Fall
Box   4   Folder   19	Organic Foods Production Act (OFPA) amendments, 2007 Farm Bill, 2005-2006
Box   4   Folder   20	Pasture Rule Comment Task Force, 2005-2008
	Personal Care Task Force (PCTF)
Box   4   Folder   21	NSF personal care standards, 2008
Box   4   Folder   22-23	White Paper Task Force, 2008-2009
Box   4   Folder   24	Policy scope, 2004-2008
	Series: Subject File	⇧
Electronic   Folder	Agenda 21 Policy Committee, 1993
Box   4   Folder   25	Agriculture Growers Research certification program, 1990
Box   4   Folder   26	Agriculture policy, national legislation, 1986-1990
Box   4   Folder   27	American Organic Standards (AOS) comments, 1999 June, September
Box   4   Folder   28	Animal and Plant Health Inspection Service (APHIS), 2008-2009
	Codex
Box   4   Folder   29-33	Organically produced foods: drafts, 1991-1997 Note: Section 1-8, Annexes.
Box   4   Folder   34	Biotechnology, 1994-1995
	Food security
Box   4   Folder   35	1994-1999
Electronic   Folder	Audit program documents, 2003-2004
	Gaia Associates/Gaia Services
Box   4   Folder   36	Little Bear Trading Company (LBTC), 1987-1990
Box   4   Folder   37	Farm and plant inspection reports, 1989 April-November
Box   4   Folder   38	Grower lists, 1988-1989
Box   4   Folder   39	Independent Accreditation Steering Committee (IASC), 1998 September-November Note: Independent accreditation system proposal.
Box   4   Folder   40-42	Independent Organic Inspectors (IOI) inspector training, 1993-1994
Box   4   Folder   43	Independent Organic Inspectors Association (IOIA) membership directories, 1992, 2007
Box   4   Folder   44-45	IFOAM group certification dialogue, 2007
Box   5   Folder   1-2	IFOAM group certification dialogue, 2007-2008
	Jamaica
Electronic   Folder	Correspondence, memos, 1992-1994
Electronic   Folder	Jamaica Organic Growers Association (JOGA), 1992-1994
Electronic   Folder	Volunteers in Overseas Cooperative Assistance (VOCA) report, 1993-1994
	Materials evaluation model, Lynn Coody
Box   5   Folder   3	Annotated copy, 1990 July 15
Box   5   Folder   4-6	Materials Working Group, 2005-2008
Box   5   Folder   7-10	National Conference on Organic Sustainable Agriculture Policies, Center for Science in the Public Interest (CSPI), 1989-1992
Box   5   Folder   11	Natural Organic Farmers Association of Vermont/Northeast Organic Farming Association of Vermont (NOFA-VT), 1997-1998
Box   5   Folder   12	Organically Grown Week (September 10-16, 1990) press kit, 1990 Note: Committee for Sustainable Agriculture (CSA)
	Organic Crop Improvement Association (OCIA)
Box   5   Folder   13	OCIA information packet, 1984 May Note: Includes article draft on OCIA for The Natural Farmer.
Box   5   Folder   14	"Shenanigans," 1985-2004
Box   5   Folder   15	Les Agriculteurs-écologistes de l'Estrie (OCIA-Estrie/OCIA-Quebec), 1984-1985 Note: History of certification, Glacial Ridge case, organic integrity.
Box   5   Folder   16-20	Vermont Organic Crop Improvement Association (OCIA-VT), 1984-1991 Note: OCIA-VT became Vermont Organic Farmers Association (VOFA). Includes meeting minutes, correspondence.
Box   6   Folder   1	OCIA-VT growers, 1984-1985
	Organic Farmer magazine
Electronic   Folder	Correspondence, 1990-1992
	Editorial committee/advisory board
Box   5   Folder   21-22	1990-1993
Electronic   Folder	1992-1993
Electronic   Folder	Editorials, 1992
Box   5   Folder   23	Organic Foods Production Act (OFPA): final, 1990
Box   5   Folder   24	Legal comment, 1993-1994
Box   5   Folder   25	Organic Farmers Association Council (OFAC) input, 1990, 1993
Box   5   Folder   26	Position papers, testimony, 1989-1993 Note: Includes OFPANA Guide to the U.S. Organic Foods Production Act of 1990 / prepared by Stuart Fishman, 1990.
Box   5   Folder   27	Organic Materials Review Institute (OMRI), 1996-1997
	Organic standards
Box   5   Folder   28	Canada, Europe, 1977-1992
Box   5   Folder   29	FVO, 1991
Box   5   Folder   30	OCIA, 1991-1992
Box   5   Folder   31	OGBA, 1989, 1991
Box   5   Folder   32	OSFVP, 1991
Box   5   Folder   33	Soul of Soil, 3rd edition press release, 1995 April
	State organic programs
Box   5   Folder   34	Texas, 1987-1988
Box   5   Folder   35-37	Other states, 1979-1992
	United States Department of Agriculture (USDA)
Electronic   Folder	Council on Sustainable Development, 1997-1999
Electronic   Folder	National Commission on Small Farms, 1998 December
Electronic   Folder	National Town Meeting on a Sustainable America, 1998-1999
Box   5   Folder   38-39	Sustainable Agriculture Working Group, 1995-1996
Box   5   Folder   40	Report drafts, 1995-1996
	Task Group on Information, Research, and Technical Assistance
Box   5   Folder   41	1995
Electronic   Folder	1995-1996