Draft Organic Animal Welfare Rule from the USDA

The comment period for this draft ended July 13, 2016

Better Conditions for Livestock or Giveaway to Corporate Agribusiness?

The USDA has released their long-awaited draft organic animal welfare standards. The proposals are truly a mixed bag. Some are well-taken. Others are so restrictive as to make it impossible for dairy farmers, for example, to manage their cattle in a humane and sanitary manner. Most disturbing, many proposed changes favor the corporate sector in industrial livestock production (“factory farms”) — officially legalizing confinement-style farm egg and poultry practices.

Please help Cornucopia and our allies make needed changes to these rules with powerful public feedback from farmers and consumers by July 13.

  • Submit electronic comments to the USDA hereSee below for a sample letter you can personalize for your comments.
  • Read Cornucopia’s comments on the proposed rules (comments updated July 7, 2016).
  • Read Cornucopia’s comparison of the USDA’s draft rules to recommendations from their advisory committee, the National Organic Standards Board.
  • Read the USDA’s draft rules.

Sample Letter for Your Potential Use.
Copy, Paste, and Personalize as Needed.


Paul Lewis Ph.D.
Director of Standards Division
National Organic Program
U.S. Department of Agriculture
Room 2646-So., Ag. Stop 0268
1400 Independence Ave. SW
Washington, DC 20252-0268

Re: Docket No. AMS-NOP-15-0012
National Organic Program: Organic Livestock and Poultry Practices

Dear Dr. Lewis:

As an organic stakeholder, I have a strong interest in rules on organic livestock management practices. These proposed rules will affect the livelihood of farmers, welfare of animals and, potentially, the confidence consumers have in the organic label.

I am disappointed by many parts of the proposed rule on organic livestock and poultry practices and urge you to reconsider its passage and implementation as proposed.

This draft rule sets the minimum standard for animal welfare too low for poultry. If the proposed standards are accepted as is, consumer confidence in the organic label could further erode. The integrity of the label is vitally important to farmers, business people, and those of us who buy organic food expecting authenticity. Any new rulemaking should strengthen organic regulations and make them easier to enforce. Especially with respect to poultry, this draft rule institutionalizes confinement of organic livestock.

If the current rules on livestock and poultry practices were properly enforced there would be no need for this proposed rule. As it stands, smaller-scale farms that follow both the spirit and letter of the organic standards must compete with industrial interests that often take advantage of the current lax enforcement environment. For example the provision of porches in poultry operations, instead of “outdoor access,” as required in the current regulations, is an example of this problem.

I would like to see these changes to the proposed rule:

1. Disallow porches in poultry operations and open up the doors (this can be done through a guidance document, not rulemaking). Porches are not a solution to concerns of biosecurity; well-managed flocks are healthier when they are able to exhibit their natural behavior, are not overcrowded, and given true outdoor access. Porches should never count toward outdoor or indoor space requirements (this creates a loophole resulting in less indoor space). Doors on poultry houses should be regularly spaced, on at least three sides of the building, and large enough that every bird within the house is within 10 feet of a door.

2. Provide adequate stocking densities; the stocking densities for poultry are completely insufficient in the proposed §205.241(c). Birds need a minimum of five square feet (5ft2) each outdoors and operators should prevent manure overload and desertification of outdoor areas. Birds need a minimum of one and a half square feet (1.5ft2) each indoors to perform basic natural behaviors.  The current proposed densities perpetuate the economic wrongs done to farmers already providing their poultry with strong welfare considerations.

3. Require vegetation in all outdoor areas for poultry. The proposed §205.241(c)(1) requires outdoor enrichments; vegetation is the ultimate enrichment for poultry. Vegetation also mitigates soil and water problems and disease in the birds. A minimum vegetation requirement of at least 50% coverage will also prevent producers from overstocking outdoor areas.

4. Change the harmful new dairy proposal requirements on housing. The revised 205.239(a)(4)(i) would allow cows to defecate and urinate on bedding, jeopardizing animal health and conflicting with the requirement to keep animals “clean” (an undefined term in the revised §205.239(a)(3)) and hurting the quality and sanitation of the milk they produce. The proposal that cattle must be on soil outside of the grazing season, when conditions could risk their health and environmental degradation, needs to be modified.

5. The proposal that animals cannot be confined any longer than necessary to perform a breeding (revision of §205.239(b)(7)) is unrealistic for organic dairy producers.  A 24-hour window should be provided.

I support The Cornucopia Institute’s comprehensive comments. I hope that you will consider the impact these proposed rules will have on the organic industry and particularly those livestock producers who are already meeting high ethical and regulatory standards. For the sake of confidence in the organic label, please do not allow the voices of a few large-scale producers, and their lobbyists, to overpower the needs of consumers and organic farmers like myself.


(Your Name Here)