29
Apr
Protect Organic Family Farmers Who Safeguard the Earth and Our Health
(Beyond Pesticides, April 29, 2019) It Is Time to Stop the Attack on Organic and Protect the Family Farmers Who Safeguard the Earth and Our Health.
Listening to and talking with dairy farmers at the National Organic Standards Board meeting in Seattle last week, it is clear that organic consumers and farmers everywhere need to rise up to protect the standards of organic. This is the only way we can ensure a livable future—clean air, water, air, and a reversal of the climate crisis and the insect apocalypse. While there are numerous problems with the current administration’s attack on organic across the board—and we are focused on the range of problems, dairy is a good place where we must join together before more organic family farmers literally go out of business. Organic dairy is the first place families look to protect their children.
As a result of abuses in government management of organic, we are seeing an attack on organic that can be corrected with the adoption of proposed rules that have been waiting to be adopted—the Origin of Livestock and the Access to Pasture rules. Without these rules, former Wisconsin dairy farmer, Jim Goodman, wrote in the Washington Post last December:
When six dairy farms in Texas feed their thousands of cows a diet of organic grain and stored forage, with no discernible access to a blade of grass, they end up producing more milk than all 453 organic dairy farms in Wisconsin combined. Then they ship it north, undercutting our price. We can’t make ends meet and are forced out of the business. We played by the rules, but we no longer have a level playing field.
The Real Organic Project has explained the situation as follows:
The crux of the problem with the current rule for origin of dairy livestock is that there exists a two-track system for conversion of conventional dairy animals to organic. One track is that a whole herd can be converted to organic over a 12-month period, but thereafter no animals can be transitioned from conventional to organic on that farm. The other track is that for herds that did not use the one-time conversion, producers can continuously transition dairy animals into organic over time, using a 12-month conversion period for each animal transitioned.
A further complication is that some NOP accredited certifying organizations allow farms to continuously transition dairy cows from conventional to organic and other certifying organizations do not allow that.
Numerous public comments over the years of rulemaking have pointed out that this two-track system creates an uneven playing field for organic dairy producers. The National Organic Program proposed rule of April 28, 2015 would have fixed that problem by removing the option for an open-ended conversion of conventionally raised dairy animals to organic, as called for by an overwhelming majority of public comments. USDA has never finalized that proposed rule on the origin of livestock, putting family farmers in jeopardy. Furthermore, the Western Organic Dairy Producers Association has called for the elimination of the one-time transition of dairy herds from conventional to organic, maintaining that there are now enough organic dairy animals in the organic market to grow the organic dairy industry.
According to the Organic Farmers Association, consistent enforcement of the access to pasture rule, including identification of high risk dairy operations such as those with more than 1000 milking and dry cows, is needed to meet USDA’s Farm Bill and Legislative Principles priority to “Protect the integrity of the USDA organic certified seal and deliver efficient, effective oversight of organic production practices to ensure organic products meet consistent standards for all producers, domestic and foreign.”
Letter to Members of Congress
It is way past time for the U.S. Department of Agriculture to protect organic family farmers and consumers with rules to protect organic integrity –the Origin of Livestock and the Access to Pasture rules. Without consistent enforcement of these rules, former Wisconsin dairy farmer, Jim Goodman, wrote in the Washington Post, last December:
When six dairy farms in Texas feed their thousands of cows a diet of organic grain and stored forage, with no discernible access to a blade of grass, they end up producing more milk than all 453 organic dairy farms in Wisconsin combined. Then they ship it north, undercutting our price. We can’t make ends meet and are forced out of the business. We played by the rules, but we no longer have a level playing field.
As explained by the Real Organic Project,
The crux of the problem with the current rule for origin of dairy livestock is that there exists a two-track system for conversion of conventional dairy animals to organic. One track is that a whole herd can be converted to organic over a 12-month period, but thereafter no animals can be transitioned from conventional to organic on that farm. The other track is that for herds that did not use the one-time conversion, producers can continuously transition dairy animals into organic over time, using a 12-month conversion period for each animal transitioned.
A further complication is that some NOP accredited certifying organizations allow farms to continuously transition dairy cows from conventional to organic and other certifying organization do not allow that.
Numerous public comments over the years of rulemaking have pointed out that this two-track system creates an uneven playing field for organic dairy producers. The National Organic Program proposed rule of April 28, 2015 would have fixed that problem by removing the option for an open-ended conversion of conventionally raised dairy animals to organic, as called for by an overwhelming majority of public comments. USDA has never finalized that proposed rule on the origin of livestock, putting family farmers in jeopardy. Furthermore, the Western Organic Dairy Producers Association has called for the elimination of the one-time transition of dairy herds from conventional to organic, maintaining that there are now enough organic dairy animals in the organic market to grow the organic dairy industry.
I agree with the Organic Farmers Association (OFA) recommendation that the National Organic Program (NOP) strengthen its enforcement of the Access to Pasture rule by immediately instructing certifying agents to identify high risk dairy operations as those with over 1000 milking and dry cows and instructing its agents that they need to meet the following requirements for the certification of high risk dairy herds:
- Certification file review staff and organic inspectors must have documented training and experience in livestock nutrition and grazing on organic dairies with over 1,000 milking and dry cows.
- A calculation matrix will be required for verification of meeting the grazing requirement which includes the following parameters: average animal weight, individual and verifiable unique identification of each animal, milk production, daily dry matter requirement, daily non-pasture dry matter consumption, acres of pasture, forage yield of pasture, and maximum distances cows walk to pasture.
- As stated in the regulation, dry matter intake “shall be calculated as an average over the entire grazing season for each type and class of animal;” thus, for example, dry matter intake of milking cows cannot be averaged with dry matter intake of dry cows.
- Certifiers must conduct two inspections during the grazing season, one announced and one unannounced.
On behalf of farmers and consumers, please urge the Secretary of Agriculture to adopt the Origin of Livestock and enforce the Access to Pasture Rule. To protect the livelihood of organic farmers and the integrity of the organic label, this is urgent.
Thank you.
Letter to U.S. Secretary of Agriculture
It is way past time for the U.S. Department of Agriculture to protect organic family farmers and consumers with rules to protect organic integrity –the Origin of Livestock and the Access to Pasture rules. Without consistent enforcement of these rules, former Wisconsin dairy farmer, Jim Goodman, wrote in the Washington Post, last December:
When six dairy farms in Texas feed their thousands of cows a diet of organic grain and stored forage, with no discernible access to a blade of grass, they end up producing more milk than all 453 organic dairy farms in Wisconsin combined. Then they ship it north, undercutting our price. We can’t make ends meet and are forced out of the business. We played by the rules, but we no longer have a level playing field.
As explained by the Real Organic Project,
The crux of the problem with the current rule for origin of dairy livestock is that there exists a two-track system for conversion of conventional dairy animals to organic. One track is that a whole herd can be converted to organic over a 12-month period, but thereafter no animals can be transitioned from conventional to organic on that farm. The other track is that for herds that did not use the one-time conversion, producers can continuously transition dairy animals into organic over time, using a 12-month conversion period for each animal transitioned.
A further complication is that some NOP accredited certifying organizations allow farms to continuously transition dairy cows from conventional to organic and other certifying organization do not allow that.
Numerous public comments over the years of rulemaking have pointed out that this two-track system creates an uneven playing field for organic dairy producers. The National Organic Program proposed rule of April 28, 2015 would have fixed that problem by removing the option for an open-ended conversion of conventionally raised dairy animals to organic, as called for by an overwhelming majority of public comments. USDA has never finalized that proposed rule on the origin of livestock, putting family farmers in jeopardy. Furthermore, the Western Organic Dairy Producers Association has called for the elimination of the one-time transition of dairy herds from conventional to organic, maintaining that there are now enough organic dairy animals in the organic market to grow the organic dairy industry.
I agree with the Organic Farmers Association (OFA) recommendation that the National Organic Program (NOP) strengthen its enforcement of the Access to Pasture rule by immediately instructing certifying agents to identify high risk dairy operations as those with over 1000 milking and dry cows and instructing its agents that they need to meet the following requirements for the certification of high risk dairy herds:
- Certification file review staff and organic inspectors must have documented training and experience in livestock nutrition and grazing on organic dairies with over 1,000 milking and dry cows.
- A calculation matrix will be required for verification of meeting the grazing requirement which includes the following parameters: average animal weight, individual and verifiable unique identification of each animal, milk production, daily dry matter requirement, daily non-pasture dry matter consumption, acres of pasture, forage yield of pasture, and maximum distances cows walk to pasture.
- As stated in the regulation, dry matter intake “shall be calculated as an average over the entire grazing season for each type and class of animal;” thus, for example, dry matter intake of milking cows cannot be averaged with dry matter intake of dry cows.
- Certifiers must conduct two inspections during the grazing season, one announced and one unannounced.
On behalf of farmers and consumers, please adopt the Origin of Livestock and enforce the Access to Pasture Rule. To protect the livelihood of organic farmers and the integrity of the organic label, this is urgent.
Thank you.
