19
Nov
Tell the Secretary of Agriculture to Restore Fairness to Organic Dairy
(Beyond Pesticides, November 19, 2018)Â The Organic Foods Production Act (OFPA) requires organic milk and dairy products labeled as organic to come from dairy cows continuously managed as organic from the last third of gestation. Because of the short supply of organic dairy breeder stock when the law was passed in 1990, a one-time conversion of conventional dairy cows to organic was allowed, as long as they are managed organically.
Unfortunately, the National Organic Program (NOP) allowed two interpretations of this provision, turning the provision into a loophole that has allowed some large dairy operations to circumvent the last third of gestation requirement altogether, and bringing conventionally managed animals into their operations on a continuous basis.
In 2015, USDA proposed an Origin of Livestock rule to clarify that section of the law and ensure consistent enforcement of the standards, but appears to have no plans to finalize the rule. In its October 2018 meeting, the National Organic Standards Board (NOSB) recognized the unfairness that allows large organic dairies to profit at the expense of smaller dairies who follow the spirit of the law. In a rare demonstration of unity, the NOSB unanimously passed this resolution:
It has come to the attention of the National Organic Standards Board (NOSB) that the continued state of varying interpretations and practices around the Origin of Livestock standards is creating market instability for organic producers. The 2015 USDA Origin of Livestock Proposed Rule was based on six recommendations from the NOSB between 1994 and 2006. The proposed rule responds to findings from the July 2013 USDA Office of Inspector General (OIG) audit report on organic milk operations stating that certifying agents were interpreting the origin of livestock requirements differently. Rulemaking is necessary to ensure consistent interpretation and enforcement of the standards for origin of livestock and provide industry with additional clarity of application of the organic dairy standards. In early 2017 the Origin of Livestock Proposed Rule was removed from the Unified Agenda of Regulatory and Deregulatory Actions. Support for this rule has been expressed through public comment by the majority of organic stakeholders. Strong federal oversight is essential for creating a fair and level playing field for all certified organic operations.Â
Therefore, be it resolved by unanimous vote, the National Organic Standards Board—as USDA’s Federal Advisory Board on organic issues and representing organic farmers, ranchers, processors, retailers and consumers—urges the Secretary to directly issue a final rule for Origin of Livestock that incorporates public comments submitted in response to the Proposed Rule (Docket Number AMS-NOP-11-0009).
Letter to Secretary Perdue [address in Salsa], AMS Administrator Bruce Summers [email protected], and NOP Deputy Administrator Jenny Tucker [email protected]
The Organic Foods Production Act (OFPA) requires organic milk and dairy products labeled as organic to come from dairy cows continuously managed as organic from the last third of gestation. Because of the short supply of organic dairy breeder stock when the law was passed in 1990, a one-time conversion of conventional dairy cows to organic was allowed, as long as they are managed organically.
Unfortunately, certifiers allowed two interpretations of this provision, turning the provision into a loophole that has allowed some large dairy operations to circumvent the last third of gestation requirement altogether, and bringing conventionally managed animals into their operations on a continuous basis.
In 2015, USDA proposed an Origin of Livestock rule to clarify that section of the law and ensure consistent enforcement of the standards, but appears to have no plans to finalize the rule. In its October 2018 meeting, the National Organic Standards Board (NOSB) recognized the unfairness that allows large organic dairies to profit at the expense of smaller dairies who follow the spirit of the law. In a rare demonstration of unity, the NOSB unanimously passed this resolution:
It has come to the attention of the National Organic Standards Board (NOSB) that the continued state of varying interpretations and practices around the Origin of Livestock standards is creating market instability for organic producers. The 2015 USDA Origin of Livestock Proposed Rule was based on six recommendations from the NOSB between 1994 and 2006. The proposed rule responds to findings from the July 2013 USDA Office of Inspector General (OIG) audit report on organic milk operations stating that certifying agents were interpreting the origin of livestock requirements differently. Rulemaking is necessary to ensure consistent interpretation and enforcement of the standards for origin of livestock and provide industry with additional clarity of application of the organic dairy standards. In early 2017 the Origin of Livestock Proposed Rule was removed from the Unified Agenda of Regulatory and Deregulatory Actions. Support for this rule has been expressed through public comment by the majority of organic stakeholders. Strong federal oversight is essential for creating a fair and level playing field for all certified organic operations.
Therefore, be it resolved by unanimous vote, the National Organic Standards Board—as USDA’s Federal Advisory Board on organic issues and representing organic farmers, ranchers, processors, retailers and consumers—urges the Secretary to directly issue a final rule for Origin of Livestock that incorporates public comments submitted in response to the Proposed Rule (Docket Number AMS-NOP-11-0009).
Please adopt a final rule for Origin of Organic Livestock that creates consistency across production and incorporates the public comments that the agency received.
Thank you.
Sincerely,
Since it is the PUBLIC who purchases organic milk products in ever increasing amounts, we need to be assured that our comments and suggestions be included in the final rule relating to organic livestock. No loopholes are acceptable. People have come to TRUST that Organic really means ORGANIC. Please be sure that the rule represents the WHOLE TRUTH, not some half truth. We do NOT like to be lied to.
November 19th, 2018 at 5:25 pmPlease urge the Secretary of Agriculture to issue a final rule for Origin of Organic Livestock, as urged by the NOSB.
January 20th, 2019 at 4:18 am