Submit comments on or before December 14, 1998 to: Eileen S. Stommes,
Deputy Administrator, USDA-AMS-TM-NOP, Room 4007-S, AG Stop 0275, P.O.
Box 96456, Washington, D.C. 20090-6456; fax: (202)690-4632; e-mail:
NOPIssue Papers@usda.gov.
ISSUE PAPER 1-- LIVESTOCK CONFINEMENT IN ORGANIC PRODUCTION SYSTEMS
Commenters expressed concern that allowing restriction of available space
for movement or access to outside "if necessary" creates a loophole for
factory farming of livestock.
Option 1--Retain the Current Language but Elaborate on Its Intent
Option 2--Establish Animal Space Requirements in Animal Feeding
Operations
Option 3--Establish Requirements for Access to Pasture.
Option 4--Explore Feasibility of Allowing Livestock Products Labeled as
Organic To Include Additional Label Claims, Such as Pasture-Raised,
Free-Range or Never Confined in a Feedlot
Should the rule ban confined animal feeding operations? Would
requiring access to pasture satisfy commenters, including those who
oppose factory farming? What economic impact would these options have on
organic livestock producers? How would additional labeling claims affect
the marketing of organic livestock products?
Would annual or semi-annual organic certification site visits be
sufficient to ensure that routine, continuous confinement is not
occurring? How should certifiers determine that confinement is being
employed in accordance with the regulations?
How should access to pasture be defined? Should a species-by-species
approach be taken? When permitted by regulation, should the duration and
frequency of confinement be resolved on a case-by-case basis between
certifier and producer?
ISSUE PAPER 2.--THE USE OF ANTIBIOTICS AND PARASITICIDES IN ORGANIC
LIVESTOCK PRODUCTION The proper role for antibiotics and parasiticides
needs to be determined. NOSB recommendations prohibit the use of
antibiotics and parasiticides except under certain clearly delineated
animal health conditions.
Option 1--Prohibit all use of antibiotics and parasiticides.
Option 2--Prohibit the Use of All Animal Medications, Other Than
Vaccinations, Including Antibiotics and Parasiticides.
Option 3--Allow the Therapeutic Use of Antibiotics and the Non-Routine
use of Parasiticides Under Specific Animal Health Conditions.
What economic impact would the prohibition of all medication,
including antibiotics and parasiticides, have on organic livestock
producers?
Under what conditions, if any, could an animal for slaughter receive
a synthetic internal parasiticide? An external parasiticide? What about
breeding stock or dairy animals?
Should we make provisions for the use of synthetic parasiticides
where other measures has proven ineffective?
Would annual or semi-annual organic certification site visits be
sufficient to ensure that preventative measures are being carried out and
that antibiotics and parasiticides are being administered in accordance
with the Act and its regulations? When permitted by regulation, should
the use of antibiotics and parasiticides be resolved on a case-by-case
basis between certifier and producer?
ISSUE PAPER 3. TERMINATION OF CERTIFICATION BY PRIVATE CERTIFIERS
Commenters expressed concern that the certification termination process
is unduly bureaucratic and would complicate local certifiers' efforts to
ensure the integrity of the organic label, yet due process of law must be
afforded before suspension or revocation of certification.
Option 1--Create a Uniform and Efficient Information System To Inform the
Public of USDA Actions To Suspend or Revoke Certification
Option 2--Provide for an Expedited Process, Including Special Rules of
Practice and Shortened Time Frames, To Review Certifier Recommendations
and Make Determinations.
Option 3--Design an Informal Alternative Procedure To Resolve Enforcement
Issues on an Expedited Basis Short of an Adjudicatory Hearing
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