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 Web site at www.ams.usda.gov/nop. The deadline for
submission of public comment was December 14, 1998.
Kathleen Merrigan and Mark Keating
--------------------------------------
Comments on Issue Paper 1
Livestock Confinement in Organic Production Systems
The Henry A. Wallace Institute for Alternative Agriculture appreciates
this opportunity to evaluate options for implementation of the Organic
Food
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 1 is consistent with, and an
expansion
upon, the comments on the Proposed Rules for the National Organic Program
we submitted on April 30, 1998.
Resolving the confinement issue is an essential step towards the
development and implementation of credible organic livestock production
standards. At its heart, organic agriculture represents an integrated
and
interrelated group of management practices which run contrary to the
concentration which characterizes much of conventional agriculture. By
carefully balancing the needs of animals with the resources they provide,
organic livestock management can contribute to a diversified and
profitable
farm. By contrast, the proliferation of conventional intensive livestock
confinement systems has created a host of environmental, economic and
animal welfare problems. Inappropriate waste disposal practices,
financial
domination by vertically integrated corporations and breeding practices
driven by volume of production, not vigor of the animal, are undermining
conventional livestock production. Recognizing how intensive livestock
production has impacted animals, the environment, farming communities,
and
human health, consumers are demanding alternatives. Organic production
standards which responsibly and humanely address the issues of space and
mobility will reward farmers for reintroducing animals into their
management systems in ways which support environmental and economic
sustainability.
Standards pertaining to confinement and mobility will help to integrate
livestock production into an operation's nutrient management strategy.
Not
every producer will maintain livestock, but those that do should balance
the needs of their animals with the other components of their operation.
The requirement that animals have access to an outdoor environment
appropriate to their species moves the production paradigm away from
concentration and high yield towards integration with available resources
and environmental conditions. Confinement standards will require
operations
to identify and sustain linkages between the number and variety of
animals
they raise and available land resources. In developing a farm plan for
livestock operations, organic producers will think in terms of what type
and how many animals their land will support, not withstand.
The Wallace Institute believes that none of the four policy options
outlined in the Confinement Issue Paper provide an adequate expression of
the fundamental space and mobility requirements for organically raised
livestock. The USDA should strengthen its position by requiring that
certified operations provide access to the outdoors for all animals under
conditions appropriate to each species. While requirements can include
justifiable conditions for exceptions, the organic standards should
acknowledge that restrictions on access to the outdoors can only be
temporary. By mandating access to the outdoors for all animals and
establishing species-specific conditions for compliance, the USDA can
facilitate conversion to organic systems, satisfy consumers' expectations
and position organic producers to compete in international markets.
Note: Standards for the certification of aquaculture production are
receiving increased attention within the organic community, and are
usually
considered in the context of livestock operations. While the Wallace
Institute supports the development of aquaculture standards and believes
that they should be viewed as livestock operations, our comments on Issue
Paper 1 are limited to the consideration of land-based animal production.
Standards pertaining to confinement in aquatic systems are too
rudimentary
and untested to be evaluated side by side with those for land-based
operations. By contrast, extensive experience with certification of
land-based systems, primary for the production of ruminants and poultry,
provides sufficient precedent from which to derive comprehensive national
standards. Issues related to confinement, mobility, and stocking rates
in
aquaculture operations need to be more thoroughly assessed in the
production setting before they can be translated into meaningful
standards.
Recommendations
(1) The Wallace Institute strongly recommends that certified livestock
operations be required to provide access to the outdoors to all animals
under conditions appropriate to their species. The term "access to the
outdoors" should be interpreted as the ability of an animal to move
freely
from its enclosure into an open air environment with suitable ground
cover.
The simulation of a natural environment is a cornerstone provision in
organic livestock production systems. An environment which allows
animals
to engage in feeding, resting, and grooming behavior compatible with
their
inherent preferences is best suited to minimize stress and promote vigor.
Because the satisfactory amount and condition of the outdoor environment
is
dependent on the type of livestock, the Secretary should implement
specific
standards for individual species. Requiring that organic livestock
producers provide access to an outdoor environment suitable to the needs
of
specific species will help balance the animal and land resources of
certified operations. A clear commitment to outdoor access will also
conform with the expectations of organic consumers as reflected in the
overwhelming support for such access voiced in the first round of
comments
on the Proposed Rules of the National Organic Program.
(2) The Wallace Institute recommends that temporary denial of access to
the outdoors to organically raised livestock may be justifiable due to
inclement weather, the health, safety and well being of the animal, and
protection of soil and water quality. Under certain conditions, organic
livestock producers need the discretion to prohibit temporarily the
access
of the animals under their care to the outdoors. Justifiable conditions
for restriction include protecting animals from the elements, providing
health care treatment, or preventing excessive damage to soil and water
resources. The length of the indoor confinement is not as important as
the
requirement that producers keep the period as brief as possible. For
example, severe weather may necessitate extended intervals of restriction
as long as the producer provides free access to the outdoors when
conditions permit. Justification for restricting access to the outdoors
should be carefully detailed in the operation's approved farm plan and
reflect the well recognized factors - such as climate and animal life
cycles - most likely to impinge on unrestricted access.
(3) The Wallace Institute recommends that certified livestock operations
be
required to provide ruminants access to managed pasture. The term
"managed
pasture" should be interpreted as a distinct, organically certified field
which is maintained to produce animal forage. Organically raised
ruminants
should receive a significant portion of their nutritional requirements
from
managed pasture. Pasture based rotational grazing systems provide
substantial animal welfare as well as soil and water conservation
benefits.
Additionally, requiring pasture grazing for ruminant production will
help
to correlate the of size an operation with its impact upon the local
environment. Operations which use their land resources to provide a
substantial portion of their feed requirement (as well as to accept the
attendant manure) will be able to maintain larger herds than those that
do
not. We are aware that certain private certification standards currently
do not require access to pasture, but we believe that adopting this
provision in national standards will best protect and promote the
integrity
of organic production.
(4) The Wallace Institute recommends a prohibition on the use of cages
for
the confinement of organically raised poultry. To constitute a clear
alternative to conventional production systems, organic standards must
prohibit those practices most closely associated with factory farming.
Many currently certified poultry operations have proven that organic
production is possible without the use of cages. Caging poultry is
incompatible with organic approaches to animal welfare and health
maintenance, and is inconsistent with consumer expectations. In addition
to the prohibition on confining birds in cages, certified poultry
production operations need to comply with the access to the outdoor
requirement contained in recommendation (1). Our preference is that
poultry producers provide managed pasture for the animals they raise, but
we do not recommend requiring it. Pasture raised poultry is an excellent
production option for some producers, but others may prefer to use
alternative systems which provide their animals equally satisfactory
access
to suitable outdoor conditions.
(5) The Wallace Institute recommends that the Secretary provide
accelerated
review to standards for access to the outdoors in swine production
operations. State and private certifying agents have long maintained
confinement standards for dairy animals and poultry because producers
could
make an organic claim on certified milk products and eggs. However,
because the Food Safety and Inspection Service has prohibited using the
term organic on meat labels, analogous standards for livestock raised
solely for their meat have not appeared. The recent increase in consumer
demand for pork products has created a potentially lucrative market for
which current certification standards provide little guidance. At the
same
time, many pork producers are adopting new production systems such as
hoop
houses, pasture farrowing and rotational grazing which may be compatible
with organic principles. The Secretary should facilitate implementation
of
confinement standards for pork production to enable certified producers
to
enter this market expeditiously. We strongly believe that a grass-based
system such as managed pasture is the most suitable environment in which
to
raise organic swine.
(6) The Wallace Institute recommends that the Secretary work with the
NOSB
and a Technical Advisory Panel representing the organic livestock
production community to develop species-specific confinement standards.
The development of confinement standards suitable for individual species
will require a significant investment of resources. However, intense
consumer interest in livestock produced through alternative production
practices should make such standards a high priority for the NOP. The
Secretary should rely upon the NOSB as his principal adviser for
establishing confinement standards. In addition, the Secretary should
devote resources to recruiting a qualified Technical Advisory Panel drawn
from experienced producers and certifying agents to provide an
authoritative analysis of existing standards and potential improvements.
DISCUSSION
Recommendations of the National Organic Standards Board
The NOSB has outlined a position on animal confinement which provides a
constructive framework for developing more comprehensive standards. The
Board grounded its work in the belief that livestock production
environments which replicate natural conditions are best suited to
minimize
stress and promote health. In 1994, the NOSB recommended that certified
operations provide "access to shade, shelter, fresh air, and daylight
suitable to the species, the stage of production, the climate, and the
environment." The Board also proposed that design of animal housing must
accommodate "the natural maintenance, comfort behaviors, and the
opportunity to exercise" required by specific species. These
recommendations established guidelines for strict but achievable
confinement standards capable of reflecting differences among species,
their stage of development, and variation in climatic and environmental
conditions. The Board coupled species- specific welfare requirements with
considerable leeway for producers and certifying agents to flesh out
actual
site-specific conditions in an approved farm plan. This approach was
designed to insure protective baseline standards for livestock living
conditions while affording producers flexibility to meet those
requirements.
In 1995, the NOSB strengthened its recommendation on organic livestock
living standards by specifying the conditions under which temporary
restriction to indoor housing may be justified. These conditions are
limited to inclement weather, the health care, safety and well being of
the
livestock and protection of soil and water quality. At its 1998 Ontario
meeting, the NOSB reaffirmed its earlier positions on confinement and
recommended that no exceptions be allowed for large livestock
concentrations. While the Board did not further define large livestock
concentrations, it recognized that, by contrast, organic operations must
address the natural space and mobility needs of the animals they raise.
The work of the NOSB has balanced the interests of animal welfare,
variation between species, producer discretion, and environmental
variables
to create a workable, enforceable, and understandable definition of
organic
livestock management. To develop a credible confinement standard, the
USDA
should adopt the recommendation that exceptions to space and mobility
requirements can only be temporary and must be based on the conditions
outlined by the NOSB.
Current Organic Livestock Production Practices
The Food Safety and Inspection Service's prohibition on labeling meat or
meat products as organic has hampered the development of certification
standards for the production of livestock. Currently, fluid milk, related
products including yogurt and cheese, and eggs are the only food
commodities derived from animals which can be labeled as organically
produced. In response to these opportunities, state and private
certifying
agents have developed a variety of standards for the certification of
dairy
and poultry layer operations. There has been little agreement, however,
on
what constitutes an appropriate standard for confinement. For example,
different standards for poultry certification in the United States
currently vary from caged birds, to free-roaming, to a requirement for
outdoor access. Similarly, the standards for certification of dairy
herds
allows for everything from pasture based rotational grazing to dry lot
operations.
The absence of industry consensus on appropriate livestock standards,
and
the confusion it creates when consumers discover the wide array of
conditions currently allowable under different standards, makes the
development of a clear and communicable NOP policy especially important.
Concerned organic consumers used the first round of comment on the
Proposed
Rules of the National Organic Program to express their strong support for
a
policy on confinement which clearly requires access to the outdoors. An
analysis conducted by the group Organic Watch of 201,794 comments posted
on
the NOP Web site identified 57,911 (28.70% of the total) responses which
favored a stronger requirement for access to the outdoors for livestock.
Potential Benefits of Organic Production Systems
Just as organic production represents a systems approach (responsiveness
to natural cycles, strength through diversity), intensive confinement
production is also predicated on interrelated components. However, with
the confinement approach, fixation on a single component - yield - causes
other variables in the system to be compromised. Breeding animals for
high
feed conversion rates and rapid weight gain means sacrificing properties
such as natural immunity to disease. Forcing vast numbers of animals to
live in cramped quarters contaminated with their own waste insures that
synthetic medications will become required treatment. Mandating access
to
the outdoors is a solid first step towards resolving many of the animal
health problems which plague intensive confinement operations. By
establishing a relationship between an operation's available land
resources
and the number of animals it can raise, the requirement for access to an
outdoor environment appropriate to each species provides a foundation for
successful nutrient management. Certified livestock operations will
balance their land and animal resources to provide feed (in cases of
managed pasture) as well as dispose of manure. Access to the outdoors can
also be an integral factor in other production considerations including
disease suppression and the reduction of aggressive behavior.
Recent research supports the understanding that organic livestock
production practices are linked to with reduced animal stress,
strengthened
immunity and reduced pest infestation. Data recently published in
Science
identified a strong positive correlation between the percentage of grain
fed to cows and the concentration of E. coli in their rumens. The
authors
concluded that a hay or pasture based diet could be significantly less
likely to support E. coli populations, including potentially pathogenic
strains, than the high corn diets fed to confinement animals.
Additionally, confinement poultry operations are experiencing well
documented disease and parasite resistance problems with the increasingly
narrow genetic base found in the most commonly used breeds. Because
organic producers have to consider multiple variables when selecting
breeds, they will generally employ and preserve a much broader amount of
genetic diversity. The Wallace Institute believes that research in
genetic
diversity is a top priority for determining how organic operations can
overcome the production problems plaguing conventional production.
Conclusion
To deliver livestock standards which producers, certifiers, and
consumers
can embrace and support, the Secretary should establish a firm
requirement
that all organically raised animals enjoy access to the outdoors under
conditions suitable to their species. With standards for ruminants, the
requirement should entail access to a managed pasture under organic
management which provides a significant portion of the animals'
nutritional
requirements. In conjunction with the NOSB and a Technical Advisory
Panel
of industry experts, the Secretary should develop and implement species-
specific conditions to satisfy the outdoor access requirement. The Final
Rules of the National Organic Program should acknowledge that temporary
restrictions on access tot he outdoors for organically raised livestock
are
allowable only for reasons of inclement weather, the safety and welfare
of
the animals, or the protection of soil and water resources.
___________________________________________________________________
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