>This message contains comments from the Henry A. Wallace Institute for
>Alternative Agriculture on USDA organic Option Paper #2, "The Use of
>Antibiotics and Parasiticides in Organic Livestock Production." A copy
of
>our comments are also found on the Institute's web page at:
www.hawiaa.org.
>
>This USDA option paper, along with two others, were published in the
>Federal Register October 28, 1998 and are found on the USDA National
>Organic Program webpage at www.ams.usda.gov/nop. The deadline for
>submission of public comment is December 14, 1998.
>
>We hope that you find our comments helpful as you begin the burdensome
task
>of crafting your own individual and organizational responses. Good
luck!
>
>Kathleen Merrigan and Mark Keating
>
>Comments on "Issue Paper 2"
> The Use of Antibiotics and Parasiticides in Organic Livestock
Production
>
> The Wallace Institute appreciates this opportunity to analyze options
for
>implementation of the Organic Foods Production Act (OFPA). We support
the
>Department's goal of clear, consistent regulations that stimulate the
>growth of organic markets, satisfy consumer expectations, and allow
organic
>producers flexibility in making site-specific, real-time management
>decisions. Our response to the options presented in Issue Paper 2 is
>consistent with, and an expansion upon, the comments on the Proposed
Rules
>for the National Organic Program submitted by the Wallace Institute on
>April 30, 1998.
>
> Our comments will not respond to individual options outlined in Issue
>Paper 2. The multiple and conflicting interpretations of the options
>discussed at the October, 1998 NOSB meeting confused participants and
USDA
>staff alike. Therefore, rather than qualify or condition our responses
to
>specific options, we will use the important substantive issues they
address
>as the focus for our recommendations.
>
> While the options outlined in Option Paper 2 for antibiotic and
>parasiticide use treat these two categories of animal medications
>identically, we find substantial justification for evaluating them
>separately. The significant differences which exist in purpose of
>application, essentiality to organic systems, and consumer expectations
>merit the consideration of antibiotics and parasiticides as distinct
>categories of synthetic materials. While the NOSB had, in the past,
made
>parallel recommendations concerning the use of antibiotics and
>parasiticides, the Board recognized clear distinctions between the two
>categories at the Ontario, California meeting in March, 1998.
>
>Recommendations
>
>(1) The Wallace Institute supports a prohibition on the use of all
>antibiotics in certified organic livestock operations, with two
exceptions
>and one caveat.
>
> Exception: We endorse the recommendation of the NOSB to allow the
>exceptions for breeder and conversion stock contained in Section 205.12
of
>the Proposed Rules, except as allowed for in Section 205.12(a)(4)
>(non-edible products).
>
> Exception: An exception may be appropriate in apiculture operations
for
>materials added to the National List, subject to certifying agent
approval.
>
> Caveat: The Wallace Institute does not, at this time, have sufficient
>expertise to comment on the use of antibiotics in aquaculture
operations.
>As a result, we will refrain from making recommendations in this area
until
>more information becomes available.
>
>(2) The Wallace Institute recommends allowing the use of specific
>parasiticides, provided they are approved by the NOSB, added to the
>National List, and their use is detailed in an approved farm plan. The
use
>of an approved synthetic parasiticide should only be permitted when the
>certifying agent determines that no alternative management option can
>provide an acceptable measure of control.
>
>(3) The Wallace Institute recommends that USDA initiate immediately an
>intensive research effort on parasiticide use, including the resistance
>characteristics of different breeds, the role of climatic variables on
>efficacy of treatment, and alternative (non-synthetic) treatment
practices.
>
>(4) The Wallace Institute expects that certain synthetic and natural
>medications are potentially suitable for organic livestock production.
>Therefore, as a class, "animal medications" should not be banned
outright.
>
>DISCUSSION
>
>Antibiotics
>
> The role of antibiotics in animal production has long been
controversial
>and limiting their use in organic operations was a priority in the
OFPA.
>Section 6509(d)(1)(A) prohibits the use of subtherapeutic doses of
>antibiotics. Subsequent language in Section 6509(d)(1)(C) prohibits
the
>administration of medicine, other than vaccinations, in the absence of
>illness. The OFPA does identify "livestock parasiticides and
medicines",
>including antibiotics, as a category of material suitable for inclusion
on
>the National List of approved synthetics. Synthetic materials placed
on
>the National List can only be used for itemized, specified
applications.
>The NOSB is responsible for identifying which synthetic materials are
>suitable for use in organic operations and the Secretary, before and
after
>public comment, develops the National List by choosing from these
>recommendations.
>
> Organic production must be an expression of, not an alternative to,
the
>humane treatment of livestock and provide at least as much protection
to
>animals as conventional systems do. It has always been the NOSB's
>position, which the Wallace Institute strongly supports, that an ill
animal
>requiring antibiotics must receive the treatment to alleviate prolonged
>suffering and potential mortality. Just as a field which has been left
>fallow for years does not become "organic by neglect", an animal cannot
>become certified because it is denied a conventional treatment it
requires.
> Certified livestock operations must adopt a pro-active approach to
animal
>welfare and divert to conventional operations (and markets) those
animals
>which are not sustained by organic care.
>
> Reliance upon synthetic antibiotics in organic agriculture has evolved
as
>producers acquire expertise in preventative management and alternative
>treatments. Innovators in organic livestock management have
consistently
>found ways to reduce, even eliminate, their dependence on synthetic
>antibiotics. Driven by consumer demand which favors unqualified label
>claims ("no ... used", "never treated with..."), the organic livestock
>industry has been quick to adapt innovative techniques. The USDA has
>facilitated this trend by approving label claims such as "antibiotic
and
>hormone free" which have become successful marketing devices. The pace
of
>change has been so swift that the NOSB fundamentally re-wrote its
>recommendations for the use of antibiotics before the original position
was
>four years old. By re-writing its recommendations on use of
antibiotics,
>the NOSB demonstrated that meaningful standards need to respond to
industry
>practice and consumer preference. In re-evaluating its position on
>antibiotics and parasiticides, the USDA should incorporate proven
>innovations in organic practice while leaving some flexibility for
>production areas where change has not been as conclusive.
>
> In its initial recommendations from 1994 and 1995, the NOSB supported
>using the flexibility within OFPA to allow use of antibiotics in dairy
and
>breeder stock under certain conditions and with extended withdrawal
>periods. In 1998, however, the Board eliminated these exceptions by
>recommending that "No animal product or animal by-product may be
labeled as
>organic once an antibiotic has been given to the animal, except as
provided
>for production stock under the Origin of Livestock Section 205.12."
This
>recommendation means that once a certified animal is treated with
>antibiotics for any reason, none of its products can again be sold as
>organic. This position is far more stringent than the standard found in
the
>USDA's Proposed Rules. The Section 205.12 exception pertains solely to
the
>treatment of animals prior to their introduction to organic systems.
While
>we support the NOSB's position, we do not favor extending the exemption
to
>the category "Livestock used for the production of non-edible livestock
>products" created in Section 205.12(a)(4). In our comments of April
30, we
>stated that there is no statutory provision within OFPA to support
>differential treatment of animals based upon the nature of the products
>derived from them. The Wallace Institute continues to believe that
>creating this category and applying weaker standards will mean that
>affected animals will be inadequately integrated into the certified
>operation. The exception for antibiotic use prior to an animal's
>introduction to an organic operation should be determined by its
species,
>not its market niche.
>
> The NOSB was able to strengthen its standards on antibiotics because
>producers developed innovative ways to avoid using them. These
innovations
>came through considerable effort; most producers agree that avoiding
>antibiotics requires highly sophisticated management techniques.
Advances
>in understanding animal health care and the improved availability of
>replacement stock contributed to the NOSB's decision to revise its
>antibiotic use recommendation. Organic livestock producers have
>consistently demonstrated their ability to raise animals without using
>antibiotics. In instances when antibiotic use is deemed essential for
>survival, the treated animal can be diverted to the conventional
market.
>Because certified replacement stock have become more widely available,
a
>producer who loses capacity due to required treatments can efficiently
>rebuild his organic operation. Consumers are paying a price premium
for
>animals products raised without antibiotics and the USDA should support
>this trend by adopting the NOSB's 1998 recommendation.
>
> Apiculture is one important production system in which we suspect that
>alternatives to antibiotics are not yet fully developed. Use of
>antibiotics may be necessary and justifiable for the control of
documented
>occurrences of American foulbrood in apiculture operations. We do not
>support prophylactic applications of antibiotics in instances where
>disease is not established. While apiaries should be regulated as
>livestock operations, beekeepers cannot exercise the same measure of
>control over their operations that other producers do. For example,
>beekeepers cannot monitor the source of their animals' food as
producers of
>pastured animals can. Neither can beekeepers protect the hive by
culling
>individual sick bees. We believe that organic operations which
otherwise
>comply with their farm plan should be allowed an exception for the use
of
>specific approved antibiotics in cases where foulbrood becomes
established
>in the hive.
>
> The Wallace Institute supports the initiative the organic industry and
the
>NOSB have taken to restrict and, in cases, eliminate the approved uses
of
>antibiotics in certified operations. We hope that the limited and
>conditional uses we support for production stock and in hives diagnosed
>with foulbrood are the exceptions that prove the rule. We endorse
these
>exceptions because we do not believe that natural alternatives are
viable
>and that the antibiotic treatments satisfy OFPA's requirements for
>allowable synthetics.
>
> At this time, the Wallace Institute does not have sufficient
information
>or expertise to determine whether the prohibition on the use of
antibiotics
>should apply to aquaculture operations. It is possible that aquaculture
>operations may operate without antibiotics, just as organic livestock
>producers have refined their practices to eliminate them. It is also
>possible that specific applications of antibiotics will be as
justifiable
>and unavoidable in aquaculture operations as we believe they are for
the
>control of foulbrood. The NOSB has received minimal public input on
this
>subject and there are few existing operations from which to learn. We
>need additional insight into current practice and the potential for
>innovation before reaching a conclusion on the use of antibiotics in
these
>operations. We urge the USDA and the NOSB to solicit input from
affected
>producers and consumer interests on this topic.
>
>Parasiticides
>
> Our analysis of organic livestock production indicates that producers
have
>not been able to develop practices and treatments to replace
parasiticides
>as they have for antibiotics. Without parasiticides, poultry and young
>sheep seem to be especially vulnerable to parasites. For the control of
>parasites, environmental conditions, including temperature and
>precipitation, may exist for which no level of management expertise can
>substitute for parasiticide use. In the absence of parasiticides, many
>organic pasture-based grazing systems may be impossible to maintain
without
>excessive animal culling and mortality. Organic standards which have
>allowed conditional use of parasiticides essentially trade off use of a
>synthetic material for the multiple benefits (for the land as well as
the
>animal) associated with grazing. The ability to pasture raise animals,
>especially poultry and sheep, is a significant potential benefit to
weigh
>when considering the suitability of parasiticides in organic production
>systems.
>
> On balance, the Wallace Institute supports the conditional use of
>parasiticides in organic livestock operations. We encourage the
Department
>to incorporate into the next Proposed Rules the 1994 New Mexico NOSB
>recommendations for allowing the use of synthetic parasiticides. These
>recommendations are based on prevention of illness, biological
controls,
>and culling of infected animals, and permit the use of parasiticides as
a
>last recourse. Producers are allowed the discretion to use approved
>parasiticides, but their decision would be subject to certifier review
of
>the farm plan. We expect that these procedures will result in a
>collaborative relationship where producers incrementally refine their
>management practices to reduce their dependence on synthetic materials.
>
> The Wallace Institute also supports the NOSB recommendations on the
>handling of products from animals which have been treated with
synthetic
>parasiticides. The NOSB proposed that animals which receive necessary
>treatment could not be sold as certified slaughter stock, but could be
>allowed as breeder and dairy stock after appropriate withdrawal
periods.
>These provisions allow producers to provide humane treatment without
>preventing their animals from eventually returning to organic care.
>Allowing the conditional use of parasiticides rewards producers for
>maintaining organic systems without removing their final safety net
during
>emergencies.
>
> Producers should assess the need for parasiticides in their farm plan
by
>providing a detailed analysis of their efforts to minimize exposure to
>parasites and what synthetic treatments they believe will be required.
>Given their understanding of regional conditions and the producer's
past
>performance and compliance record, certifying agents can best determine
if
>the suggested treatment regime is allowable. Dialogue during the
>certification process can insure that the quantity and duration of
>treatment are appropriate to the operation under prevailing regional
>conditions. Requiring producers to document their parasite management
>practices in a certifier-approved farm plan and establishing handling
>restrictions on treated animals will insure that synthetic treatments
are
>the option of last resort. We find it relevant that the NOSB's 1994
>recommendations on conditional use and post-treatment withdrawal
periods
>were applicable to antibiotics as well as parasiticides. Producer
>innovation in organic livestock management has enabled the NOSB to
amend
>its antibiotic recommendations in favor of more restrictive standards.
We
>believe that the evolution of production practices, augmented by
>significant federally-supported research, could similarly achieve a
>pronounced reduction in the dependence on parasiticides in organic
>livestock operations.
>
> OFPA's provisions for developing a National List of approved
synthetics
>allows the NOSB and the Secretary to identify which parasiticides are
>allowable in organic systems. We strongly encourage the USDA to begin
the
>necessary TAP review process to determine suitability of specific
synthetic
>parasiticides. In addition, the ARS should dedicate resources to
>evaluating current organic production practices related to
parasiticides
>and evaluate the conditions which most directly contribute to their
use.
>We suspect that a better understanding of the susceptibility of
particular
>species to disease (especially older breeds relative to modern hybrids
>developed for intensive production) as well as the climatic conditions
>which contribute to regional differences in the pressure from parasites
>will significantly advance the ability of organic producers to handle
the
>problem appropriately.
>
>Reflections on Public Comment and the Role of Animal Medications
>
> The outpouring of negative public reaction to the livestock production
>provisions in the Proposed Rules has clearly affected the options put
>forward in this Issue Paper. Many comments adamantly rejected the
>provisions which the USDA proposed for synthetic medications but did
not
>substantively address what role they thought they should have. The
USDA
>has had to interpret many thousands of comments which did little more
than
>denounce the proposed policy. This blanket criticism may have prompted
the
>Department to raise the option of prohibiting the use of any medication
in
>organic livestock production. Upon review of the statute, the
historical
>debate on this subject, and the comments themselves, the Wallace
Institute
>believes that a blanket prohibition on the use of medications is
>unwarranted. With regard to food safety and animal welfare,
antibiotics
>and hormones have consistently been the medications of greatest concern
to
>the general public. The OFPA specifically prohibits the use of
hormones
>and growth promoters and sets very prescribed conditions on the use of
>antibiotics. Taken together, the ban on hormones and the stringent
NOSB
>recommendations on antibiotics will go a long way towards allaying
public
>concern about synthetic materials in organic operations.
>
> OFPA allows, and concern for the animals dictates, that the NOSB
>evaluate every natural and synthetic medication on its own merits.
Many
>natural treatments, including pro-biotic and homeopathic remedies, have
a
>proven success record and are perfectly compatible with organic
systems.
>The Secretary should not seek to prohibit any natural medication unless
the
>NOSB has recommended that it be placed on the National List of
prohibited
>natural materials. Similarly, as mandated by OFPA, the Secretary may
elect
>to add synthetic medications to the National List of approved materials
>upon the NOSB's recommendation.
>
>
>
>
>
>
>Henry A Wallace Institute for Alternative Agriculture
>9200 Edmonston Rd Ste 117
>Greenbelt MD 20770-1551
>
>Phone: 301-441-8777
>Fax: 301-220-0164
>Web site: www.hawiaa.org
>
>Please place my first name somewhere in the Subject area of any reply
to
>this message, as our email account is shared by several people. Thank
you.
>
>To Unsubscribe: Email majordomo@ces.ncsu.edu with "unsubscribe
sanet-mg".
>To Subscribe to Digest: Email majordomo@ces.ncsu.edu with the command
>"subscribe sanet-mg-digest".
______________________________________________________
Get Your Private, Free Email at http://www.hotmail.com
To Unsubscribe: Email majordomo@ces.ncsu.edu with "unsubscribe sanet-mg".
To Subscribe to Digest: Email majordomo@ces.ncsu.edu with the command
"subscribe sanet-mg-digest".