06
Jul
Are Big Dairies Undercutting Organic Milk Producers and Organic Integrity—and What Can We Do About It?
(Beyond Pesticides, July 6, 2021) ACT NOW: Public Comment Period Ends July 12, 11:59pm (eastern). A new proposed rule on the “origin of livestock” is intended to undo nearly two decades of regulatory failure by the USDA. Organic dairy producers have suffered economic harm and many organic milk consumers have been drinking substandard milk, while the National Organic Program (NOP) failed to promulgate a Final Rule on the issue of transitioning non-organically certified dairy bovine animals to organic production. The public comment period on this rule closes on July 12, 2021 at 11:59pm (eastern).
We all have a stake in growing the organic marketplace by supporting the transition from conventional chemical-intensive practices to clearly defined sustainable and regenerative practices that support family farmers and a production system that confronts the climate crisis, biodiversity decline, and rising public health threats. We do this by supporting transition and then continually improving standards to ensure a robust and healthful organic sector. The issues challenging organic dairy production are a part of the continuous efforts of Beyond Pesticides to ensure organic integrity, while growing the organic market.
Tell NOP to adopt an origin of livestock rule that protects dairy farmers and consumers.
When the organic rules were first issued, there were no organic animals, so there had to be a way for organic dairies to get started. The National Organic Program (NOP) made an allowance for farmers to convert, over a year with organic management, a distinct conventional herd to organic milk production. This enables farmers to get started in organic dairy by converting from their existing herds. However, over the years some operations, principally large dairies, have used a lack of specificity in the rule to continually bring transitioned conventional animals onto their farms as replacement animals or for expansion. This undercuts dairy farmers who operate with integrity, raising their baby calves from birth organically, and threatens consumers who depend on the wholesomeness of organic milk.
For nearly two decades, organic dairy producers have suffered economic harm and the NOP organic seal has had its integrity questioned by certifiers, consumers, and Inspectors General as the agency has failed to adopt a Final Rule on the issue of transitioning non-organically certified dairy bovine animals to organic production. As the organic dairy industry has grown, the inconsistency of implementing this exception has increased, and compromise solutions to passing a Final Rule with the support of the organic community have found greater acceptance. There is only one way to close all the loopholes—by prohibiting organic certification of conventional livestock.
We need a Final Rule on the origin of livestock and we need it now. At the beginning of the organic dairy movement, one of the big drivers was economic justice for farmers. We have lost thousands of farmers since then. Organic production was a viable alternative for family-scale producers and it has worked. However, much of the growth in the industry has been usurped by industrial scale operations gaming the system. If it wasn’t for the factory farms there could have been thousands of additional dairies saved and converted to organic. After so many years of failing to adopt this “origin of livestock” rule, NOP needs to hear from all of us who want the best organic milk possible. In doing this, we support small and medium-sized organic dairies, which are most affected by the current state of affairs.
How to Submit Comments
Please feel free to use (copy and paste) Beyond Pesticides’ suggested comments to USDA, asking that the agency adopt a Final Rule on the origin of livestock that modernizes the organic dairy industry to protect small and medium sized dairies and consumers. You may copy and paste the following suggested comments or utilize our more detailed comments to USDA.
Suggested comments to USDA on origin of organic livestock: (copy and paste)
We need a Final Rule on the origin of organic livestock and we need it now. At the beginning of the organic dairy movement, one of the big drivers was economic justice for farmers. We have lost thousands of farmers since then. Organic production was intended as an alternative for family-scale producers and it has worked. However, much of the growth in the industry has been usurped by industrial scale operations gaming the system. If it wasn’t for the factory farms there could have been thousands of additional dairies saved and converted to organic. The resulting psychological damage to families in rural communities is almost incalculable.
In order to protect the integrity of USDA organic certification and establish a level playing field for a thriving organic dairy market, the Final Rule must:
- Prohibit organic dairy operations from acquiring transitioned animals to expand or replace animals in the organic dairy herd. USDA should prohibit the sales of transitioned animals as certified organic.
- Limit the movement of transitioned animals has economic benefits. Start-up operations should buy organically certified cows. Increased demand for animals raised as organic will create a thriving market for organic replacement animals. This will allow small-to-mid-size organic dairy operations to diversify into breeding replacements whose price will reflect the true cost of organic dairy at their scale of production.
- Clarify that a “responsibly connected” person who transitions a herd is bound by the same limit as the operation they are connected to. The intent of the rule can be most effectively accomplished by tying the transition to the responsibly connected person(s).
- Be implemented as soon as it is finalized with transitions already in process completed within 12 months. All requirements of the rule should be implemented immediately upon publication of the Final Rule, with the only exception being those dairies that have already started their transition and were already approved by a certifying agent.
- Allow one 12-month transition, and one transition only, per responsibly connected person, with no exceptions. This will prevent the rule from being abused.
Thank you for your consideration.
How to Submit a Comment to USDA Via Regulations.gov
Commenting on this proposed rule requires submitting comments through Regulations.gov. Although it takes more than a single click, submitting comments is easy by following these easy steps.
- Follow this link to the comment page at Regulations.gov. Click the button “Submit a Formal Comment.”
- In the comment section, insert your comments—write your own or you can copy and paste the suggested comments above.
- Fill in your email address. It will not be posted online.
- You may want to add a comment about why organic milk and fairness in organic dairy is important to you.
- Sign your name if you want.
- Check the box confirming that you know you are submitting comments to a public docket.
- Press the “Submit Comment” button.
