(ALERT OVER) Act by Midnight on Monday — Protect Organic Livestock/Crack down on Factory Farms

October 15th, 2009

ACTION ALERT: Strengthen Animal Welfare in Organics

Submit your comments to the National Organic Standards Board
Due October 19, 2009 — 11:59 P.M.

Current organic standards lack strong language to address animal welfare on farms; as a result, factory farms are producing certified organic meat, eggs and milk. Some poultry operations, for example, house tens of thousands of chickens in buildings with tiny concrete porches — so small that they often accommodate less than 1% of the building’s chickens, and often accessible by one single small door in the corner of the house — and that supposedly counts as legally required “access to the outdoors.”

This is just one example of how the current organic standards do not adequately address animal welfare.

While factory farm livestock producers have profited from the weak organic rules, the majority of family-scale organic farms — ethical producers who are true to organic principles — have been faced with resulting unfair economic competition in the marketplace.

The Livestock Committee of the National Organic Standards Board (NOSB), the citizen expert panel that recommends changes to the organic standards, appropriately decided to act on the gaping inadequacy in the regulations. They developed a set of recommendations to improve animal welfare through stronger standards. They plan to offer these recommendations to the full NOSB board for a vote at their November meeting in Washington, D.C.

The Cornucopia Institute supports their initiative. We agree with the NOSB’s Livestock Committee that animal welfare is a basic principle of organic production, and that stronger regulation is needed. Industrial-scale producers — especially in dairy and poultry — have taken advantage of the vagueness of the rules for too long. Some industrial-style dairies are milking as many as 7200 cows.

But while stronger animal welfare regulations are long overdue, the recommendations as currently written contain weaknesses that could result in unnecessary loopholes for factory farm producers. Some of these weaknesses are identified below.

Since animal welfare regulations will affect all organic livestock producers, we believe that the Livestock Committee should invite and consider input from all stakeholders before sending final recommendations to the Secretary of Agriculture.

We encourage you to read the recommendations and submit comments (instructions below). In your comments, please urge the NOSB to either hold off on voting on final recommendations until all stakeholders have been invited to comment, and these comments have been reviewed, considered, and incorporated where appropriate, or to secure a commitment from USDA leadership that a draft rule will not be published until adequate input from the public has been gathered.

Needless to say, factory farm operators will fight any recommendations that will benefit animal welfare at the expense of their large-scale production model and profits. They will likely use the usual arguments — that animals are safer inside buildings where they are protected from predators, that animals are better off inside where they are sheltered from diseases and parasites carried by wildlife, that food safety is better controlled when animals are continually confined, etc. Therefore, it is important to let the NOSB know that you support stronger animal welfare regulations that are true to organic principles.

Taking Action is Easy:

Submit your comment to the National Organic Standards Board members.

Comments may be submitted via the Internet at www.regulations.gov until 11:59 p.m. EDT on October 19, 2009. The process is less complicated than it seems at first; simply follow the steps below.

1. To submit a comment, go to www.regulations.gov.
Under “Select Document Type,” choose “Notices”
Under “Enter Keyword or ID,” type in “AMS-TM-09-0060”
Click “Go.”

2. You will see one search result, titled “Notice of the Meeting of the National Organic Standards Board.  “On the right side, there is a blue link, “Submit a comment.” Click on this link.

3. You may now enter your comment. The comment box is not large enough for the full sample letter. To use our sample letter, attach this file to the comment page (save it to your computer, and on the comment page click “browse”, find the document, and click “attach”). Remember that personalized letters carry more weight than form letters, so we encourage you to write your own comment in – either by editing the sample letter or typing in the comment box. You can also email [email protected] to receive the formal comments submitted by The Cornucopia Institute.


Sample Message to the NOSB
(please cut and paste and feel free to edit)

Dear NOSB members,

I welcome and support the Livestock Committee’s initiative to strengthen the organic standards for improved animal welfare. Clear, concise and quantitative standards to support animal welfare are long overdue, and I urge the NOSB to work diligently toward stronger regulations.

While the recommendations will clearly result in improved animal welfare on organic operations, some weaknesses in the proposal should be addressed before recommendations are finalized and forwarded to the Secretary of Agriculture.

I believe that organic producers and other stakeholders should have the opportunity to review the recommendations and share input. The Livestock Committee shared their recommendations with the public on September 14, and comments are due October 19 — giving the public little over a month to review the proposal and provide input (the tight timeframe did not allow for adequate two-way communications within the community or communication with farmers without e-mail access). Moreover, while the Livestock Committee consulted with experts on animal welfare and visited several organic farm operations, the Committee did not solicit input from organic farmers and ranchers.

Since any change in the organic standards will likely affect all organic livestock producers, we request a stronger collaboration between the NOSB and all organic stakeholders. We encourage the NOSB to vote on the recommendations only after input from organic stakeholders has been requested, reviewed and incorporated where appropriate. That being said I would respectfully request that this input be solicited and incorporated on an expedited basis with a finalized proposal ready to be voted on at the next NOSB meeting.

Improvements needed in the recommendations include, but are not limited to:

1. The minority opinion that dairy cows should not be milked more than two times per day should be included into the recommendations. Milking three times per day, an integral element in high-production operations, causes unnecessary stress, health problems and substantially shortens the animal’s life. As the minority opinion pointed out, this shortened life span and unnecessary stress “are too high a price for her to pay on an organic dairy.”

2. Factors other than space requirements must be considered to ensure meaningful outdoor access, such as adequate entry/exit popholes (doors) for chickens. There are currently poultry houses that have one or two doors for tens of thousands of chickens; even if these operations were to offer the required outdoor space per bird, this would be meaningless without adequate entry/exit doors. I suggest that the Board review and consider the European organic standards’ pophole requirements: “at least 4 m per 100 m2 area of the house available to the birds.” Moreover, the current recommendations for outdoor access for poultry includes the phrase “or other exercise area,” which could be interpreted by industrial-scale producers as a concrete porch, or other inappropriate and unsatisfactory alternatives. I urge the NOSB to delete this phrase from the recommendations. The recommendation should read: “Poultry reared in houses shall have complete access to water and pasture or open-air runs subject to the species, weather, parasites, predators, and ground conditions, and shall have such access for a minimum of one third of their life.”

3. Transportation, euthanasia and slaughter requirements should be considered and incorporated. The current recommendations are silent on all three issues. Organic consumers expect animal welfare to apply to the full life span of the animal.

    • Transportation: Standards should specify acceptable conditions during transport, including stops for food, water and rest, etc.
    • Euthanasia of sick or injured birds: Certain methods of euthanasia, such as suffocation, blows to the head with blunt instruments and crushing the neck with pliers or burdizzo clamps should be prohibited.
    • Slaughter: Certain regulations for slaughterhouses should be specified, such as stunning chickens prior to slaughter (with a possible exception for on-farm slaughter).

The draft proposal being forwarded by the livestock committee is very specific, as it should be, and there might very well be other areas of emphasis that should be addressed based on producer input. A community-wide discussion of these recommendations has not yet taken place.

If advice and suggestions are solicited from all stakeholders, it may very well lead to additional revisions and additions to the recommendations that will result in stronger recommendations. Moreover, it will provide the Board with a clearer picture of what the organic community supports in terms of strengthened animal welfare standards.

Again, I applaud the NOSB Livestock Committee for taking this initiative. Thank you for considering my comments.
Name and Farm Name, if applicable


Specific Weaknesses in the Current Recommendations

Dairy cows: Cornucopia supports the minority opinion’s recommendation that organic dairy cows be milked no more than twice per day. We believe that the vast majority of organic dairy producers would agree. We concur with the minority opinion that “While an animal must be healthy to give large amounts of milk while being milked more than 2 times per day, her shortened life span and continual high stress level are too high a price for her to pay on an organic dairy.” This is an important area where we encourage the NOSB to solicit public comment before ignoring this important minority opinion.

Egg-laying hens and poultry: The current standards have been easily interpreted by some certifying agents as allowing producers to keep chickens indoors at all times. It is therefore important that the new rules are strong enough to ensure that industrial-scale henhouses really do provide meaningful outdoor access. For example, some current houses have two stories, with a single-file ramp leading to a concrete porch. If these houses set aside the required acreage as outdoor access, but do not change their buildings to increase the number of doors to grant outdoor access, the new rules will be meaningless to the chickens inside, and only a very, very small percentage will actually have legitimate access to the outdoors. We therefore suggest that the NOSB also recommend a certain amount of entry/exit popholes for the birds. This is likely not the only important detail that was left out — either by compromise amongst the livestock committee members or unintentionally. To ensure that the recommendations are as strong as possible when they are voted on, we suggest that the NOSB accept and review public comment.

Transportation and slaughter of organic animals:
There are currently no recommendations for ensuring humane transportation and slaughter of organic animals. Organic consumers expect that farm animals are treated humanely on the farm, but their expectations for humane treatment apply also to transportation and slaughter. We encourage the NOSB to include humane transportation, euthanasia and slaughter standards.

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