I haven't read the entire proposed rule yet and I'm not as familiar with
the livestock standards as with the rest (I've been through the IOIA & CCOF
organic crop & processing inspector training, but the livestock training
wasn't available here then), so I'll leave it to others more qualified to
respond to your specific questions.
I'll just say there's a lot of controversy surrounding the rule as it's
written now and many of us are hoping it's still too soon to know just how
the final rule will read. I think there's sound reason to feel cautious
about it. This topic provoked so much commentary here on sanet that a
separate list was recently established to address organic certification
Being somewhat familiar with your operation from your regular postings on
the graze list, I think it makes a lot of sense for you to find out what
it'd take to go organic, as close as you are to it now and as smart as you
farm. I've encourage you in that direction before and I don't mean to
discourage you from it now. But I think it's only fair to point out the
possible problems when they come up, problems in this case with the
proposed rule, not necessarily with your operation.
As an example of the kind of loopholes left open in the rule as it's
presently written, let's take a look at BSE. I remember early on in the
BSE crisis hearing organic growers gloat that it hadn't been found in
organic beef and wouldn't be, because the rendered remains of sick
livestock (the vector by which BSE first entered British cattle) didn't
qualify as organic animal feed. BSE has indeed since been found in organic
livestock, evidently thanks to the 20% exception you cite above, as
explained in the post below, which appeared originally on the agrisynergy
This is an example of just one of many problematic points in the proposed
rule. I'll spare the list yet another lengthy diatribe on the new rule and
leave it for other posts to go into it point by point.
How far are you from qualifying as organic under the law as it's presently
written? What would hold you back from getting certified organic or at
least transitional, in whole or in part, now without waiting for the new
All the best,
Beth von Gunten
Ventura County, California
>Larry and Beth
>Writing from Ireland where BSE levels although very low are certainly not
>non-existent. It is also not the case that BSE has not been found on an
>organic farm - it happened in the UK.
>The history seems to have been as follows
>The UK Thatcher government "liberalised" the rendering regulations to allow
>self-policing by the renderers who decided that all disease vectors would
>be destroyed at a lower temperature than had previously been thought
>necessary. In common with most other countries at that time (pre-BSE)the UK
>allowed the feeding of dead animal protein to natural herbivores - cattle.
>This meant that scrapies infected sheep brains, cooked at the sort of
>temperatures any human carnivore uses in the kitchen, were fed to cattle.
>Some of this feed was also exported to other countries. Humans have eaten
>these infected sheep brains all over the world without apparent ill effects
>for millenia - it is presumed that we developed defences against the prion
>in this form. Cattle hadn't had the same practise so the prion could
>develope a form of scrapies-for-cattle which we now call BSE. This was
>spotted soon after the first occurrences. No one knew what had caused it.
>The British, for whom agriculture is a minority sport, decided they needed
>to research before they spent a fortune on culling cattle, removing
>infected meat from the food chain etc. The Irish government recognised that
>11% of the national economy is dependant directly or indirectly on cattle
>and killed all infected animals, burning their carcases, and traced and
>killed offspring and killed the rest of the herd. The boned meat from these
>animals was at first allowed into the food chain but this decision was
>later rescinded in the interests of the survival of the national economy.
>Despite this isolated cases continue to occur in Ireland, some being
>animals smuggled in from Northern Ireland and some being descendants of
>animals that were fed on British imported cattle feed.
>One organic farm case in the UK occurred in the offspring of a bought in
>cow, one was presumed infected by food bought under a "20% rule" at that
>time allowing some conventional feeding - I believe it has since been
>So I guess you could say that legislation/regulation allowed scrapie into
>cattle but legislation wasn't the vector.
>Since then, as we all know, BSE has moved into the human population as new
>variant CJD. Groups most at risk were teenagers with a hamburger habit and
>those who handled raw meat at a high level - particularly slaughterhouse
>workers. A particularly worrying group is the so-called "East Kent group".
>At least one of these was a vegetarian and non of the others came into the
>high risk group but all lived downstream from a slaughterhouse processing
>infected carcases and it is believed that washing water from the
>slaughterhouse may have contaminated field irrigation allowing minute
>quantities of blood onto the soil surface and thence onto leaves. This has
>not been proved but there seems a strong probability that this was the
>vector in this case.
>Because the British did not follow a herd slaughter policy it has been
>possible to demonstrate heritability in that calves from infected cows,
>never fed contaminated feed, have contracted BSE. Most cases on the
>European mainland are believed to have come from this source.
>BSE has also occurred in at least two cats fed only on canned pet food,
>demonstrating that the prion survives at the high temperatures used in meat
>Whilst it was first identified only in brain and spinal cord tissue the
>prion has now also been identified in bone.
>Personally I have not eaten, nor have I allowed my children to eat, any
>beef not from a source that is not only organic but is a herd that is
>either closed or traceable to a closed herd for several years. I feel
>happier if I have known my dinner's great grandmother.
>No animal protein of any kind is now fed to any animal - cow, sheep, pig,
>chicken, fish in Ireland.
>What happens to scrapie infected sheep and BSE-related disease carrying elk
>and caribou at your side of the atlantic?
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