Action Alert - Tell USDA to prioritize a strong organic animal welfare regulation
Organic Livestock and Poultry Standards Comment Deadline has been extended until november 10
Background
The National Organic Standards Board spent more than decade developing recommendations to strengthen animal welfare in the organic standards, and the organic community strongly supported the Organic Livestock and Poultry Practices (OLPP) rule, which was implemented in the final days of the Obama administration. The Trump administration withdrew this rule, leaving the organic community without these important standards.
Many small and mid-sized organic livestock operations have voluntarily added humane certification, to differentiate themselves from organic operations that mirror industrial farming methods and do not meet humane requirements. Consumers are also confused in the marketplace, without a clear assurance that the organic label also means humane management.
A new organic animal welfare rule that is similar to OLPP has now been reintroduced with a few changes and is open for public comment. This new rule, the Organic Livestock and Poultry Standards (OLPS) rule, provides a level playing field for farmers who have invested in animal welfare, and maintains the organic label as the gold standard of high quality, humane food production. This rule needs to be prioritized and implemented as quickly as possible, with a few improvements to set clear requirements that meet the intent of what is already written. We know that general statements lead to loopholes and our few recommendations can prevent this from occurring in the future.
Take Action
NOC is urging farms, companies, and organizations to join us in submitting comments to the U.S. Department of Agriculture to voice overall support for implementation of the Organic Livestock and Poultry Standards rule, with a few improvements to promote consistency and remove loopholes.
You can help, and it takes only a few moments
Review key points (below) and use NOC’s comment template to create your own unique comment to voice support for this animal welfare regulation and consistent enforcement of the regulation. We encourage you to describe your organization or business in your written comments and how you are affected by this issue.
Find the Comment notice at: https://www.regulations.gov/commenton/AMS-NOP-21-0073-0001
Cut and paste your comment into the comment box or attach a separate document as directed. Complete the form by filling in your name and email.
You can read the full proposed rule (Docket No. AMS-NOP-21-0073-0001) at Regulations.gov.
Talking Points
I support the Organic Livestock and Poultry Standards Rule to strengthen organic animal welfare standards, create greater consistency among organic producers and certifiers, and meet consumer expectations for organic livestock products.
Timely implementation is critical. Existing poultry operations should come into compliance within 3 years of implementation of this regulation. The USDA suggestion of five years or fifteen years is far too long, both for the farmers who are already treating their livestock humanely and for consumers who want assurances that the organic label represents a high standard of animal welfare. Any operation new to organic, must meet the implemented standard immediately once the rule is implemented.
Clarifications are needed to ensure consistent implementation and meaningful outdoor access for organic poultry.
USDA should define “maximal vegetation” for outdoor areas for poultry. Methods such as rotation, reseeding, and irrigation must be used when necessary to keep the area vegetated to provide quality foraging for the birds and to prevent soil erosion.
Birds must have sufficient exits from the building so all birds can go outside and the vegetated area must be close enough to the building so the birds will see and use the outdoor areas. The vegetated areas must be within 30 feet of the doors of the building and there must be at least 12 linear feet of exit doors for every 1000 sq ft of poultry housing to ensure that birds actually go outside.
Temporary confinement for poultry should only be allowed below 32 degrees F and above 90 degrees F. The rule currently states they can be confined at temperatures less than 40 degrees F. Organic poultry can thrive outdoors in temperatures below 40 degrees. With 40 degrees as the allowance, there are many areas of the country where the birds will be confined for more than 6 months of the year.
Animals should never be kept in 24 hour/day darkness or less than full spectrum lighting. Some operations use this practice as an artificial, and inhumane, way to promote faster weight gain. The current rule should address the amount and type of light required in livestock housing.
Ammonia testing for poultry and swine should be weekly, not monthly, and the testing must be at the height where the animals are breathing the air. This requirement ensures animals are living in the 10ppm or less of ammonia that the rule requires.