Support Strong Rules for Organic Pasture –
Comments to USDA Due December 23, 2008!
December 16, 2008
The USDA NOP (National Organic Program) proposal for changing organic ruminant livestock rules (aka "the pasture rule") is only open for public comment until Tuesday, Dec 23rd, 2008. The long-delayed rule changes are supposed to tighten the pasture requirements for organic livestock and help ensure the integrity of the organic label.
OFRF endorses the comments published by the Federation of Organic Dairy (FOOD) Farmers and the National Organic Coalition (NOC). (Read our press release announcing our endorsement.) These changes address the overly prescriptive parts of the pasture rule and regional variations in livestock production while still keeping to the high consumer expectations of quality of and production practices for organic dairy products. We encourage all organic and transitional producers to submit comments now, especially those now operating or considering livestock production. Instructions for submitting comments are below.
Suggested Key Comment Points
- Streamline the proposed recordkeeping requirements to allow for various methods of recordkeeping that are acceptable to certifiers;
- Make several changes that address regional weather concerns in order to protect soil and water quality and the health of the animal, and to prevent damage to pastures;
- Require that at least 30% of dry matter intake be from healthy pasture during the grazing season, which shall not be less than 120 days;
- Drop the proposed language regarding replacement dairy animals; and instead publish a proposed "Origin of Livestock" rule to address that issue;
- Permit grain finishing of beef cattle for the last 120 days of life, but still require access to pasture during that time; and
- Remove “bee” and “fish used for food” from the definition of livestock.
More Information
NOC’s action alert on the proposed pasture rule
FOOD Farmer’s proposed line by line changes to the proposed pasture rule
Instructions for Submitting Comments
1) Mail written comments to the NOP. Written comments must be received (not postmarked) by Dec. 23, 2008. They must be identified with, “Docket Number AMS–TM–06–0198; TM–05–14”. Mail written comments to:
Richard H. Mathews, Chief, Standards Development and Review Branch,
National Organic Program, Transportation and Marketing Programs
USDA–AMS–TMP–NOP, 1400 Independence Ave., SW.
Room 4008– So., Ag Stop 0268
Washington, DC 20250.
2) Submit comments online. Visit the Regulations web portal: www.regulations.gov. Use the search terms “organic pasture.” Comments must be submitted online by Dec. 23, 2008. Do not leave it to the last moment to submit comments to the web portal as it tends to get overloaded at the end of comment periods.
Thanks again for your hard work and advocacy! If you have any questions, please contact Tracy Lerman, OFRF Policy Organizer at tracy@ofrf.org or (831) 426-6606.
Join the Organic Farmers Action Network today!
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