Actually, the preamble to that proposed rule included requests for public
comment about what conditions should be considered "necessary" in this and
a couple of other cases. The intent was to use the public comment as the
basis to put more specific restrictions into the final rule. The organic
plan would also have to include a justification that was acceptable to the
certifier. Overall, there was never any idea that a determination of
necessity would be totally up to the producer.
As for consumer expectations, most consumer groups we heard from were
primarily concerned about feeding antibiotics at subtherapeutic levels to
stimulate weight gains, and a few, especially the Humane Society, were
concerned that antibiotics be permitted in cases of illness or injury.
While some consumers believe that any antibiotic use could "open the door"
for violations, we felt that the consequences of a blanket prohibition
would be too burdensome for *snmall* organic producers. This is also one
of those cases that erects a barrier only to honest people--with one or two
inspections a year, it would be very easy for anyone caught in a bind with
a sick animal to get away with it. It also goes back to the question of
whether it is better to reassure consumers with rules that are hard to
enforce, or to take the trouble to educate and inform them.
At 06:11 AM 3/23/00 -0800, Loren Muldowney wrote:
>Grace Gershuny wrote:
>> USDA's attempt to provide flexibility
>> for antibiotic use only "if necessary" was attacked as contradicting
>> consumer expectations,
>How do you think the "if necessary" idea could be implemented? I recall
>that the circumstances under which "necessary" might be determined were
>It seems safe to say that every time anybody gives an antibiotic to a
>cow, it has been decided that it is necessary to do so. There were and
>are a whole lot of people who think that methyl bromide is "necessary"
>and daily sub clinical antibiotics is necessary and anhydrous ammonia is
>necessary and the roundup ready trait is necessary too. So many things
>And it DOES contradict consumer expectations. Does that count?
>> and so the purist position that penalizes farmers
>> like the Amish has won the day.
>Few of the Amish farms of my knowledge sell to the fluid milk market,
>for reasons not related to antibiotic status. Most sell to the
>cheesemakers. Sounds like they are doing the very best thing by
>producing for their own local community anyway. If they were "certified
>Organic" for the same product, would their own communities go begging
>for milk? Would all the milk fly to the cities to be sold for $8 per
>If I had a personal choice (perish the thought) between buying milk from
>a neighbor I trust and buying certified organic milk from some big
>store, I'd head to the neighbor's, for many reasons. Once that
>connection is severed and the trust aspect is missing, then no
>exceptions are possible, because that requires that I trust someone I
>don't trust, or even know.
>If it is really true that antibiotics are seldom needed for a properly
>managed milk cow, then the overall burden of removing from organic
>production those animals which must be treated will be light, and
>animals which have the lowest infection rate will be favored over those
>with the highest production.
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