Support Strong Rules for Organic
Comment NOW to USDA -- Comment
period closes December 23, 2008
The USDA National Organic
Program (NOP) released the long anticipated proposed rules tightening the
pasture requirements for organic livestock on Friday October 24, 2008.
This is a strong proposal that guarantees that organic milk production
meets consumer expectations.
The proposal needs to be
improved to remove overly prescriptive language that will cause problems
for the health and safety of animals, might have negative impacts on the
environment, and place extensive record keeping burdens on farmers. This
can be done while preserving the requirement that organic ruminants be on
pasture as much as possible during the grazing season.
Please submit your comments ASAP -
see below for detailed instructions
See the NOC website, www.nationalorganiccoalition.org
for more detailed information and a suggested re-write of rule language.
Suggested key points for comment:
the requirement for a minimum 30% dry matter intake (DMI) from pasture,
averaged over the full growing season, with the growing season ranging
from 121 -365 days, but substitute "grazing season" for
"growing season," to take into account the reality of the
grazing seasons in different areas.
that ruminants are managed on pasture only during the grazing season,
(not year round) to take into account different farming conditions, to
protect pastures from damage, and to protect the health and safety of the
livestock during adverse weather conditions.
NOP must provide needed exemptions for ruminants from
pasture and outdoor access during periods of inclement weather and to
protect soil and water quality.
the definition of "inclement weather" so that any condition
that causes physical harm to animals is a valid reason for limiting
pasture and outdoor access.
lots and feed lots, where animals are confined and there is little or no
vegetation, should be explicitly banned for ruminants. However, clean
well-managed feeding pads (barn yards) are essential facilities needed
for exercise and outdoor access during the non-grazing season, and as a
supplement to pasture during the grazing season.
the definition of "sacrificial pasture" to indicate this can be
used during the non-grazing season to provide outside access, and make
use of this practice optional, as the practice may be detrimental to the
environment, including to soil and water quality, and to animal health
when operations do not have well drained land that is accessible for
livestock or during winter weather or excessive rain conditions.
the proposed record keeping requirements for livestock operations so that
farmers can document their pasture feed rations in various ways that are
acceptable to certifiers.
must drop proposed language regarding replacement dairy animals. As
proposed, it will allow certain farms to buy non-organic animals, and
require others to buy or raise only organic young stock. The NOP must
move quickly to publish a Proposed Origin of Livestock Rule that has one
criterion for dairy replacement animals for all operations: "Once an
operation has been certified for organic production, all dairy animals
born or brought onto the operation shall be under organic management from
the last third of gestation."
grain finishing of beef slaughter stock, such that these animals may be
exempt from the 30% pasture DMI requirement during the finishing period,
not to exceed 120 days, but must not be denied access to pasture during
"bee" and "fish used for food" from the definition of
"livestock" until proposed standards are issued for those
Please also demand that USDA NOP
enforce the current regulation in regards to pasture while the proposed
rule goes through the process of becoming a Final Rule
in effect and with implementation by 2010, we urge NOP to enforce the new
regulation and work with producers and certifiers to educate them on the
requirements of the new rules. With these changes, a final rule can be
written that can safeguard the long-term integrity of organic farming.
How to submit
Give your name,
farm name (if appropriate), location and the reason for sending comments
(consumer, producer, advocate etc.).
There are three ways to
1) Mail. Written
comments must be received (not postmarked) by Dec. 23, 2008. They
must be identified with, "Docket Number AMS-TM-06-0198; TM-05-14"
at the heading of the document. Mail written comments to:
Richard H. Mathews, Chief,
Standards Development and Review Branch,
National Organic Program, Transportation and Marketing Programs
USDA-AMS-TMP-NOP, 1400 Independence Ave., SW.
Room 4008- So., Ag Stop 0268
Washington, DC 20250.
Visit the Regulations web portal: www.regulations.gov.
Use the search terms "organic pasture." Comments must be
submitted online by Dec. 23, 2008. Do not leave it to the last moment
to submit comments to the site as it tends to get overloaded at the end
of comment periods.
3) Send to NOC Mail,
fax or email your comments to Ed Maltby by 12/19/08 and he will
forward them to the NOP. By mail: Ed Maltby, NODPA Executive Director, 30
Keets Rd, Deerfield, MA 01342. Fax: 866-554-9483. Email: [log in to unmask]