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To begin with, the USDA employs numerous proxy groups to enforce its standards on organics, instead of overseeing it directly. This is partly because, as Oldham explained, there were organic certifiers in place before the USDA had official standards. These groups, like the Texas Department of Agriculture, which monitors SOS From Texas’ cotton growth, were assimilated into the USDA’s program once it came into existence. Other organizations, like trade unions or risk-management firms, popped up after the national program’s birth and became approved to certify under USDA standards.
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