As I wrote earlier ten days ago, " Organic Agriculture began as a revolution.
Revolutions are always difficult to codify..."
Now comes a counter-revolution, a wheel within the wheel.
There is a fairly broad movement building now that calls for abandoning the
federal process. Private certifiers, individual organic farmers, activists,
some members of the National Organic Standards Board itself ( whose allegiance
to the process was never very firm), have just about had it with USDA.
The folks who were initially repulsed by the very idea of USDA oversight on
organic agriculture have every right and reason to say " I told you so!"
The Organic Foods Production Act wasn't that bad of an effort. Eight years
later, we have a pretty funky mess on our hands. There is not much of a
salvage crew left to make sense of what WE have wrought during all this time.
We ignored it for years, and to ignore it now will be just as troublesome.
Ignored it? Yes, we ignored the entire process. Very few people became
familiar with the law, tried to comprehend the players and systems at USDA,
worked for better representation on the NOSB, attended the meetings or
corresponded with the Agricultural Marketing Service personnel when
rulewriting began in 1991-92.
Individuals have always had differing opinions about what organic agriculture
was. Few may remember that 20 years ago the use of urea was acceptable-to
some- and I recall how we went round and round on that one, with one side
reminding us that synthetic urea was just like its natural cousin. Never mind
that naturally ocurring urea is not a marketed commodity. The problem as that
there were some farmers who thought they needed it, and their peer group was
at first poorly prepared to explain why it was not acceptable. But eventually
we figured out some criteria- the natural versus synthetic paradigm.
For a deja-vu, consider Biotech's argument to EPA that GMO soybeans are not
substantively different from normal beans.
We are still embroiled in subjective arguments based on "need" versus absolute
criteria.
For example:
We are still trying to finesse the use of synthetic paraciticdes on livestock,
according to regional need. Organic consumers are pretty well against
antibiotics, and know very little about paraciticide use in organic
agriculture. I imagine they would be surprised to learn that synthetic
anthelmics like Abendiazole and Ivermectin are acceptable according to some
certification organizations. This is what USDA/AMS Issue Paper Number Two
covers, and for your viewing pleasure it is on the web at usda.ams/nop, and
one may also comment via email.
Issue Paper 2. The Use of Antibiotics and Parasiticides in Organic Livestock
Production
1. Goal
USDA's goal is to establish clear, consistent regulations that stimulate
the growth of the organic livestock sector, satisfy consumer expectations and
allow organic livestock producers flexibility in making site-specific, real-
time management decisions.
2. Issue
In its proposed rule published December 16, 1997 (62 FR 65850), USDA
specifically requested public comment on the use of animal drugs in the
production of organic livestock. Many commenters advocated the adoption of
the National Organic Standards Board (NOSB) recommendations on both
antibiotics and parasiticides. The NOSB recommendations prohibit the use of
antibiotics and parasiticides in organic production except under certain
clearly delineated animal health conditions.
Many other commenters go beyond the options proposed by USDA and the NOSB
by advocating an absolute prohibition on the use of antibiotics in organic
livestock production. Further, commenters who specifically mention the use of
parasiticides as an area of concern assert that the language in the proposed
rule defining the term routine use of parasiticides as administering a
parasiticide to an animal without cause is inadequate. These commenters
suggest that it would be too easy for producers to find cause to administer a
parasiticide, and that they might therefore become reliant on parasiticides
rather than on preventative measures. Some commenters would prefer a complete
ban on the use of all animal medications, including antibiotics and
parasiticides, in organic livestock production.
3. Background
The OFPA prohibits only the use of subtherapeutic doses of antibiotics
and of
synthetic internal parasiticides on a routine basis. Since young animals are
especially vulnerable to disease, USDA believed there was sufficient
justification for additional protection in the early days of life. To ensure
the health of animals during critical periods, USDA also allowed the
therapeutic use of antibiotics in dairy and breeder stock because of the
animals' longevity and the potential for infections arising from pregnancy and
delivery. USDA attempted to capture the statutory prohibition on routine use
of parasiticides by defining such use as, administering a parasiticide to an
animal without cause.
4. Options
In light of these comments, USDA is analyzing options to assist in
determining the proper role for antibiotics and parasiticides in organic
livestock production. Options under consideration, along with USDA's
assessment of the pros and cons of each option, are listed below:
Option 1 Prohibit all use of antibiotics and parasiticides
Pros
Consistent with many comments
Cons
Animal health could be adversely affected, particularly that of
young animals
Inconsistent with NOSB recommendations
Compliance verification could be difficult
Could limit industry growth by preventing the production of some
types of
livestock in specific geographic areas
Option 2 Prohibit the use of all animal medications, other than vaccinations,
including antibiotics and parasiticides
Pros
Consistent with some comments
Cons
Animal health could be adversely affected, particularly that of
young animals
Inconsistent with NOSB recommendations
Compliance verification could be difficult
Could limit industry growth by preventing the production of some
types of livestock in specific geographic areas
Option 3 Allow the therapeutic use of antibiotics and the non-routine use of
parasiticides under specific animal health conditions
Pros
Consistent with NOSB recommendations
Allows for the protection of animal health
Animal production could be enhanced
Provides producer/certifier flexibility to respond to rapidly
changing animal
health conditions
Cons
Compliance verification could be difficult
USDA is interested in exploring other options. Additionally, we are
seeking
comments on the following questions: 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?
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
^^^^^^^