Take Action on the Proposed Organic Pasture Rule

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Take Action on the Proposed Organic Pasture Rule

 

 

Take Action on the Proposed Organic Pasture Rule

 

Dear Scott,

 

 

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We apologize for the broken link in this morning's action alert on the

proposed organic pasture rules. Our alert system was experiencing

technical difficulties and many of you were unable to access the " take

action " link. Our service provider has resolved the issue, and you

should be able to take action now at http://ga3.org/campaign/PastureRule

 

We apologize for the inconvenience, and thank for your support,

The Center for Food Safety

 

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The Center for Food Safety (CFS) welcomes the USDA’s publication of

the long overdue Proposed Organic Pasture Rule that holds organic

livestock producers accountable to the high standards that consumers

expect for products labeled as certified organic. If adopted with the

changes we recommend below, the Rule would stop organic factory farms

in their tracks and level the planning field for family farmers to

compete in the organic meat and dairy market.

 

Like you, CFS favors the passage of a Rule that, in its

implementation, strongly supports the spirit and intent of organic

agriculture. Our research has shown that organic consumers expect

that livestock and dairy producers feed their animals a 100 percent

organic, genetically engineered- and antibiotic-free diet. They also

expect that they humanely treat their animals and allow them access to

the outdoors throughout their entire life span. We applaud the USDA’s

National Organic Program (NOP) for issuing a proposal that takes these

expectations into account.

 

Access to pasture for organic ruminants (cows, sheep and goats) is an

important provision in the organic rules that USDA and accredited

certifiers have required since the inception of the NOP in 2002.

However, as we witnessed with Aurora Dairy this past year, a few

renegade organic dairies have been permitted to sell their milk as

“certified organic” even though their cows have not had adequate

access to pasture. The adoption of the new proposed rule with the

modifications we recommend will not only serve to protect the

integrity of national organic standards but also to ensure the healthy

and humane treatment of animals in a manner that is environmentally

protective of farmland.

 

Join CFS in supporting strong rules for organic pasture by sending

your comments today! Comments are due by Tuesday, December 23rd.

 

 

 

 

 

Send a letter to the following decision maker(s):

AMSTM060198; TM0514

 

Below is the sample letter:

 

Docket Number AMSTM060198; TM0514

 

Dear [decision maker name automatically inserted here],

 

Richard H. Mathews, Chief, Standards Development and Review Branch,

National Organic Program, Transportation and Marketing Programs

USDAAMSTMPNOP, 1400 Independence Ave., SW. Room 4008 So., Ag Stop 0268

Washington, DC 20250.

 

Docket Number AMSTM060198; TM0514

 

I welcome the publication of a Proposed Organic Pasture Rule that

holds organic livestock producers accountable to the high standards

that consumers expect for products labeled as certified organic. I

support the passage of a Rule that, in its implementation, strongly

supports the spirit and intent of organic agriculture.

 

Specifically:

 

* I support outlawing dry lots and feedlots. I agree with the USDA's

statement that " dry lots and feedlots do not meet the requirement for

pasturing organic ruminant animals. "

 

* I support the requirement in the proposed rule for livestock to be

fed a minimum 30% dry matter intake (DMI) from pasture, with the

growing season ranging from 121 - 365 days. Recommend that " grazing

season " be substituted for " growing season, " which is specifically

defined to take into account the different grazing seasons in

different areas. The " grazing season " must be no less than 121 days

and can extend to 365 days, depending upon location and associated

local weather conditions.

 

* I support USDA's rule and position on animal confinement for grain

finishing beef which states: " exemption from pasture for finish

feeding is contrary to the expected intent of pasture-raised animals

in organic systems. There is nothing inherent in the finish feeding of

beef cattle that precludes them from being provided with pasture.

Allowing confinement feeding for beef cattle would constitute an

inconsistent application of the pasturing requirement. " I understand

that during the grazing season ruminant slaughter stock may be grain

fed or " finished " to meet consumer taste expectations and, therefore,

I support exempting them from the 30% pasture DMI requirement during

the so called finishing period, not to exceed 120 days. However, I do

not support denying these animals access to pasture during that period.

 

* I advise the reinstatement of needed exemptions for ruminants from

pasture and outdoor access during periods of inclement weather and to

protect soil and water quality. While I would like USDA to mandate as

much access to pasture as possible, we do not want livestock on

pasture if it will adversely affect their health and welfare or if it

threatens soil and water quality.

 

* I believe that organic certification has an inherent environmental

stewa rdship component that must continue to be strengthened as the

standard evolves. To that end, I support organic livestock operation

requirements to manage outdoor access areas, including pastures, in a

manner that does not put soil or water quality at risk including the

use of devices that prevent animals and waste products from entering

bodies of water.

 

* I support the proposal to encourage the use of sacrificial pasture

for use when saturated soil conditions render the pasture(s) too wet

for animals to graze. However, I recognize that some small producers

lack suitable land for sacrificial pasture, and encourage the NOP to

work with such producers to put meaningful pasture plans in place that

protect animal welfare and soil and water quality without giving undue

advantage to large producers with greater access to such land. I agree

with the NOP?s stance that drylots and feedlots are not to be

considered sacrificial pasture.

 

* I oppose the inclusion of Origin of Livestock regulations in the

rule and support the immediate publication of a proposed rule on

Origin of Livestock. The origin of organic livestock is an important

issue and one that warrants its own rulemaking process instead of

being lumped in with the narrow focus of pasture requirements. I

advocate for the rapid publication of a rule that has one criteria 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. "

 

* I oppose the inclusion of fish and bees in the definition of

livestock. While standards for these systems are important, they

should not be included in the narrow confines of a pasture rule.

 

Thank you for your consideration of these comments.

 

Sincerely,

 

Scott Munson

 

 

 

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Campaign Expiration Date:

December 24, 2008

 

 

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