Action Alert - Tell USDA to Close Loopholes in Organic Dairy
Origin of Livestock Comment Deadline = July 12
Background
When the organic rules first came out, there were no organic animals, so they had to figure out a way for organic dairies to get started. The National Organic Program made an allowance for organic farmers to convert a distinct herd to organic milk production. This enabled farmers to get started in organic dairy, by converting their existing herds.
Over the years some operations have used a lack of specificity in the rule to continually transition conventional animals in and out of organic production. This undercuts dairy farmers who operate with integrity.
Rules to close the dairy conversion loophole (‘Origin of Livestock’) have been introduced twice before but never finalized. Continued delays have negatively impacted the economic viability of organic dairy farmers – getting this rule across the finish line is an urgent priority!
Take Action
NOC is urging farms, companies, and organizations to join us in submitting comments to the U.S. Department of Agriculture to voice support for closing dairy loopholes and finalizing the Origin of Livestock rule.
With your action, we can create a more level playing field for organic dairy production. It is important that the organic community delivers a unified and consistent message about the need to close loopholes in a meaningful way.
You can help, and it takes only a few moments!
1. Review key points (below) and use NOC’s comment template to create your own unique comment to voice support for closing loopholes and ending abuse in organic dairy production. We encourage you to describe your organization or business in your written comments and how you are affected by this issue.
2. Find the Federal Register notice on the rule here.
3. Click on the green button to submit a formal comment.
The USDA wants to know if exceptions should be allowed, which would permit the continued transition of animals in and out of organic production, undermine integrity, and give bad operators a financial advantage. These are four key points you can make in your comments:
· Prohibit the sales of transitioned animals as certified organic; not being able to sell transitioned animals is a small price to pay for closing this destructive loophole.
· Clarify that a "responsibly connected person" who transitions a herd is bound by the same limit as the operation they are connected to.
· One 12-month transition is all that is allowed, and only one, per responsibly connected person—NO EXCEPTIONS!
· Implement this rule as soon as it is finalized with transitions already in process completed within 12 months. This gives everyone a chance to wrap up existing plans and close this loophole.