USDA seeks comment by September 15th

The USDA has proposed 13 additions to the list of substances available to organic livestock farmers for treating illness. But their action is also impeding use of the full range of available options.

Let the USDA know that you want organic farmers to have access to additional humane health care tools and that they not reject the Advisory Panel’s other cautionary recommendations.

According to the proposed new rules (published in the Federal Register 7/17/06), organic livestock farmers will have access to an expanded list of materials, whose safety for organic use has been reviewed, when they need to treat their animals for illness. The USDA’s National Organic Program has proposed adding 13 new substances to the list of products that organic livestock farmers may use when needed. These materials have been added to the National List of approved substances at the suggestion of the USDA’s expert advisory panel, the National Organic Standards Board.

It has taken as long as six years for the USDA to act on some of these recommendations. Materials include substances such as bismuth subsalicyate (available to humans as the major ingredient in Pepto Bismol®), magnesium hydroxide (a naturally occurring mineral that is used as an antacid), and butorphanol, a strong painkiller.

These are not ingredients that would be added to organic meat. These are health care materials, used only when needed to prevent suffering and for documented health care necessity, under the supervision of a veterinarian.

The proposed new rule also rejects the NOSB’s recommendations to add cautionary restrictions to some of the more potent medications, for example increasing the withdrawal times beyond what the FDA currently requires of conventional farmers before meat or milk can be sold to the public. The USDA rejected these added recommendations, saying they would “create additional label claims.”

The Cornucopia Institute contends that it is a violation of organic standards for the USDA to add the materials to the list of approved substances without following the expert panel’s recommendations for additional restrictions on how they are used. And the Institute contends that the entire organic certification process equates to a legal and legitimate “additional label claim.”

In addition, the USDA also declined to approve six “over-the-counter” remedies that the NOSB had also requested be made available for use by organic farmers, including mineral oil, kaolin pectin, and activated charcoal. The USDA rejected these substances because they are not approved for use by the FDA. However, the FDA has already made it clear that these substances are of “low regulatory priority” because they are considered safe, and that the USDA has the authority to make them available under organic regulations.

In comments to the USDA, the Cornucopia Institute has called on the Secretary of aAgriculture to respect the expertise and efforts of the NOSB by acting on their recommendations more quickly in the future, by requiring the additional restrictions requested for the more potent drugs, and by approving the six benign, safe, substances that the panel reviewed and requested be allowed.

A sample letter to help you prepare your public comments can be found here.

The full text of Cornucopia’s comments can be found online at: https://www.cornucopia.org/approved_substances_comments_Final.pdf.

Comments may be sent to the USDA at the following address:

Arthur Neal, Director of Program Administration
National Organic Program, USDA-AMS-TMP-NOP
1400 Independence Ave., SW
Room 4008-So., Ag Stop 0268
Washington, DC 20250

Comments may be submitted via the Internet to:

[email protected],
or by fax to: (202) 205-7808.

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