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.
