11
Oct
Organic Integrity Challenged by Proposed USDA Livestock and Poultry Standards
(Beyond Pesticides, October 11, 2022) Without continuously improving organic standards and certification, advocates maintain that there is no holistic way to combat the existential crises associated with petroleum-based pesticides and fertilizers—the multiple and growing health threats, biodiversity collapse, and the climate emergency. Have you been confused at the egg case in your grocery store where egg carton labels proclaim “cage-free,” “free-range,” and “pasture raised” organic eggs? The U.S. Department of Agriculture (USDA) is accepting comments on proposed regulations to protect the welfare of livestock and poultry on organic farms. The Organic Livestock and Poultry Standard (OLPS) is a slightly revised version of the Organic Livestock and Poultry Practices (OLPP) rule, which was promulgated after many delays in January 2017, then withdrew the rule before it became effective.
USDA acknowledges that a failure to act on OLPS undermines the organic market, saying “a market failure exists in the organic label,” and the intent of new standard is to “clarify and ensure consistent application of the USDA organic standards.” The inconsistent application of organic standards by certifiers has resulted in a plethora of add-on labels that ensure that organic livestock and poultry production meet the expectations of organic consumers.
However, the proposed OLPS lacks the specificity to meet the stated intention and if implemented, will allow the inconsistencies among certifiers to continue. In order to protect the meaning of the organic label, a few changes are needed. Since these changes are consistent with the stated intentions of USDA, they should not cause delay in implementing the OLPS. Please tell USDA to make the changes listed below.
This action requires a submission at Regulations.gov. Members of the public can copy and paste from Beyond Pesticides’ suggested comment below.
Suggested Public Comment
The proposed OLPS lacks the specificity to meet USDA’s stated intention and if implemented, will the inconsistencies among organic certifiers to continue. In order to protect the meaning of the organic label, a few changes are needed. Since these changes are consistent with the stated intentions of USDA, they should not cause delay in implementing the OLPS. Please make the following changes.
*Do not allow current producers to continue practices inconsistent with the proposed rule for 5-15 years. Three years is adequate for existing operations to provide the outdoor access required in the regulation.
*Define “outdoors” to be soil-based with maximal vegetative cover appropriate for the season, climate, geography, species of livestock, and stage of production.
*Define “access to the outdoors” for poultry to be “having sufficient exit areas that are appropriately distributed to ensure that all birds have ready access to outdoors no more than 10 feet from the house; exit areas for birds to get outside must be designed so that more than one bird at a time can get through the opening and to have a combined length of at least 12 ft per 1,000 ft2 area of the house available to the birds.”
*Do not permit estimates of stocking rates to be based on expected mortality.
*Require that artificial light supplement rather than substitute for natural light. Adopt OLPP provision that required an inspector to be able to read and write with lights turned off on a sunny day. Do not allow any birds to be raised in darkness.
*Remove the provision that allows confinement in inclement weather, including when air temperatures are under 40 degrees F or above 90 degrees F. This loophole could allow confinement for as much as half the year. The provision for confinement in “conditions under which the health, safety, or well-being of the animal could be jeopardized” is sufficient and puts the onus on the producer to demonstrate ill effects of outdoor access, and birds can judge whether they want to go outside in “inclement” weather.
*Monitoring for ammonia levels in poultry houses must be performed frequently—automated continuous monitoring is possible in large houses—and must measure ammonia at the height at which the birds are breathing.
To compromise on the above foundational issues is to undermine public trust in the organic label and the growth of the organic sector. A failure to protect public trust in the USDA organic label for livestock and poultry is to a failure for all of organic and threatens the progress being made in the organic marketplace.
Thank you.
Support strong laws for Organic Food. Dont reduce the standards for Livestock and Poultry.
October 12th, 2022 at 1:53 pmstay organic
October 12th, 2022 at 2:05 pmI Support strong laws for all Organic Foods. So please, do not reduce the standards for Livestock & Poultry. Thank you.
October 12th, 2022 at 2:39 pmSupport strong laws for Organic Food. Don’t reduce the standards for Livestock and Poultry.
October 12th, 2022 at 3:09 pm“Organic” must be defined as chemically free farmed food stuffs… To water down it’s definition is a betrayal of Americans’ great desire to protect themselves and others from undeniable health threats!!
October 12th, 2022 at 5:08 pmWe need strong laws for organic items
October 12th, 2022 at 6:48 pmAnimals are God’s creations, we need to take better care of them, and their environment.
October 12th, 2022 at 11:53 pm