Origin of Livestock – Proposed Rule
*Comment by July 27
The new origin of livestock rule released by the USDA has tightened the rules that govern how conventionally raised livestock can be brought into organic production system, but a major loophole remains. This loophole could allow significant abuses to continue to the detriment of organic family farmers, who follow the spirit and letter of the law, and their loyal organic customers seeking authentic organic food.
Conventional farmers, converting to organic farming, are allowed a one-time transition of their existing herd to organic production. After that point all animals brought into a herd are supposed to be raised organically from the last third of gestation (meaning, prior to birth). However, some industrial scale organic dairies (“factory farms”) have been flaunting this rule for years by continuously purchasing conventional heifers that have been transitioned to organic.
Factory farms, milking thousands of cows each, have been regularly bringing in conventional cattle to both grow their operations and replace animals burned out by their high production management approach. Instead of raising the new animals on organic milk and feed, these cattle are raised on medicated milk replacer that includes antibiotics, and fed GMO grains and hay treated with toxic pesticides. The intent of the proposed new rule is to prevent this practice.
The problem with the proposed rule is that USDA bureaucrats define a dairy farm as any farm milking at least one cow! The farm does not even have to be a commercially licensed dairy. Theoretically, a farm could have a single cow that they milk and this would then allow them to also raise thousands of conventionally fed dairy heifers and transition them to organic, before ultimately selling the transitioned animals to the factory dairies already exploiting consumer trust. This would allow the same flagrant abuses to keep occurring.
Cornucopia makes the following suggested changes to the rule:
- Require the farm to be a “commercial dairy,” inspected and permitted by the state, and have a relationship with a licensed milk handler shipping to a licensed dairy plant. Furthermore, the operation should be fully established, shipping milk, for no less than 180 days and that any animal sold has been producing milk themselves (no young transitioned heifers, who have never been milked, could qualify to be sold as “organic”).
- An even more powerful and simpler solution would be to ban, outright, the sale to an organic operation of any cattle that had been transitioned from conventional production to organic production.
You can comment directly using the link below and mention that you agree with The Cornucopia Institute’s suggested changes to the proposed origin of livestock rule: https://www.federalregister.gov/articles/2015/04/28/2015-09851/national-organic-program-origin-of-livestock
The public comment period is open until July 27th, 2015.
A short sample letter appears below. Please customize this to fit your voice. You can cut and paste the final version into the USDA website (noted above):
RE: Comment on Proposed Rule on Origin of Livestock (Docket Number AMS-NOP-11-0009; NOP-11-04PR) To Whom It May Concern: Thank you for the opportunity to provide public input on the National Organic Program’s Proposed Rule on the Origin of Livestock. I fully support the effort to close the loophole that has allowed the continued practice of bringing in conventional cattle onto organic farms. This loophole has been abused and allowed factory farm livestock operations to manage their herds using practices that aren’t sustainable and do not promote the health of their livestock. However, the proposed new rule appears to to see closed to prevent the ongoing abuse of the intent and spirit of organic law. Specifically, I support the following two changes:
- The rule must require that any organic dairy farm selling organic animals be a functioning “commercial dairy” that is inspected and permitted by the state in which it operates. Furthermore, this dairy farm must have a relationship with a licensed milk handler shipping to a licensed dairy plant. In addition, this operation should be fully established, shipping milk, for no less than 180 days and that any animal sold has been producing milk themselves. This means that no young transitioned heifers, who have never been milked, could qualify for sale as “organic”.
- Should the National Organic Program seek an alternative solution to the potential loophole noted above, they could choose to ban, outright, the sale to an organic operation of any cattle that had been transitioned from conventional production to organic production.
Thank you for considering my comments on this important matter. Sincerely,
Again, please act by Monday, July 27 to submit your electronic comments to https://www.federalregister.gov/articles/2015/04/28/2015-09851/national-organic-program-origin-of-livestock
Should you wish to submit comments by mail, send them to:
Scott Updike, Agricultural Marketing Specialist National Organic Program USDA-AMS-NOP, Room 2646—So., Ag Stop 0268 1400 Independence Ave. SW Washington, DC 20250-0268
Make sure that in your letter you make clear that your comments are about Docket Number AMS-NOP-11-0009; NOP-11-04PR.
Thank you for helping protect the integrity of organic agriculture and food.