National Organic Program (NOP)-Access to Pasture (Livestock)
USDA Docket No. AMS-TM-06-0198; TM-05-14; RIN 0581-AC57
The U.S Department of Agriculture (USDA) established the National Organic Program in 2002, creating a set of strong and meaningful standards for organic food that consumers could readily identify on food labels. Organic standards cover all aspects of food production, and producers who seek to obtain organic certification annually document their adherence to these strict protocols. As a result, consumers have gained great confidence in the USDA certified organic seal as an indicator of a food product that comports with their values, and producers of these products often enjoy a premium price for their goods in the marketplace.
But recently, consumer confidence in the organic standard has been shaken by stories about organic dairies where animals were kept in CAFOs (confined animal feeding operations) with little or no vegetation. This controversy brought to light the loophole inherent in the language pertaining to organic dairy animals requiring that they be afforded “access to pasture.” The Union of Concerned Scientists (UCS) believes that the spirit and the letter of organic agriculture standards dictate that animals must be raised in a manner that works with natural systems. In the case of organic beef and dairy production, this means cows should not be confined in CAFOs but should be raised on pastures that are carefully managed to provide grass and other forage as a foundation of the animals’ diets. Outdoor areas lacking in grass or other edible vegetation are not “pasture.”
UCS strongly supports direction of the proposed USDA rule that will require that beef and dairy cows receive 30 percent of their diet of “dry matter intake”—a measure of the proportion of an animal’s food that comes from grass and other pasture vegetation—directly from pasture grazing, but urges the USDA to change the time frame during which this is required from “growing season” to “grazing season” to take into account the different grazing seasons in different parts of the country. The growing season may include periods of time when little or no vegetation is available for grazing, whereas the “grazing season” specifies the period of time when pasture is available for grazing, due to natural precipitation or irrigation. In addition, we strongly believe that cows should be managed on pasture only during the grazing season (not year round) to protect pastures from damage and to ensure the health and safety of livestock during adverse weather conditions. We also support exemptions from pasture requirements in rare instances of animal injury or illness, extreme weather, or when necessary to protect soil and water quality.
The Union of Concerned Scientists is a member of the National Organic Coalition (NOC). For more detailed information on aspects of the proposed rule not discussed here, including the proposed expansion of these rules to other species such as bees and fish, please visit the NOC website.
