The National Organic Standards Board (NOSB), which advises the Secretary of Agriculture on organic policy and rulemaking, is considering several changes to the USDA’s organic standards that would water down organics, catering to corporate interests.
We cannot allow corporate-backed members of the NOSB to chip away at the integrity of the label. The following proposals are highly objectionable. Please comment on them through www.regulations.gov (complete instructions below).
The proposal would allow any synthetic additive that qualifies as a “nutrient” to be added freely to organics, even those that have never been tested for safety by the FDA. Currently, organic law requires all synthetic additives, including nutrients, to be individually petitioned, carefully reviewed and approved by the USDA before they can be added to organics.
Message to the NOSB: Reject the Handling Committee’s proposal regarding nutrient additives. Nutrient additives must be individually petitioned, reviewed and approved as safe and appropriate for organics before they can be used, as the law currently requires.
Already, some companies are illegally adding a synthetic form of DHA omega-3 (from algae) and ARA omega-6 (from soil fungus) oils to organic food, including organic infant formula. These additives have been linked to serious gastrointestinal reactions in some babies and toddlers.
More information: An action alert on this topic was sent out in late March. If you already sent in your comments—Thank You! If you haven’t already commented, please do so today.
Space for Chickens
Factory farms, with as many as 100,000 birds in a building, that do not have legally mandated access to the outdoors, would be shut down if new strict rules are put into place.
The good news is that the NOSB Livestock Committee proposal would outlaw the tiny enclosed porches that industrial-scale producers had been illegally calling “the outdoors.”
But our struggle for meaningful animal welfare standards is not over! The committee caved once again to industry pressure—proposing outdoor space requiring just 2 ft.² per layer and 1 ft.² per broiler! In the European Union, organic standards require at least 43 ft.² per bird outdoors and the US leading organic brand, Organic Valley, affords their birds 5 ft.² outdoors.
2ft.² and 1 ft.² is simply not enough for birds to have meaningful outdoor space where they can exhibit their natural behaviors (like running around and “foraging”).
Furthermore, the proposal would grant 1.2 ft.² indoors for laying hens and 1.0 ft.² for meat birds, which is no better than the current industry standard for factory farms, and certainly inadequate for organics. Many legitimate organic farmers currently provide 1.5 ft.² of indoor space for their laying hens.
Message to the NOSB: Please resist pressure by the industrial-scale producers to reduce the outdoor space requirements for chickens any further. When I buy organic eggs and chicken, I expect that the birds were raised with ample access to real outdoor runs—5 ft.² should be the bare minimum!
Indoor and Outdoor Space for Growing Pigs
The Livestock Committee’s proposed space requirements for growing pigs are so small, even standards set by the National Pork Board—which is controlled by industrial hog producers—are more generous! The proposed space requirements would make it impossible for growing pigs to turn around in their bedded indoor space, with even less space outdoors.
Message to NOSB: The proposed space requirements for growing pigs are woefully inadequate. If organic standards are going to be the gold standard in terms of animal welfare, growing pigs should be granted more space than what is currently proposed.
More information: A complete action alert for organic hogs is available.
Indoor Space for Dairy Cows
The opposite is true for dairy cows. The latest proposal for indoor space requirements is so overly generous that it could essentially put thousands of family-scale dairy producers out of the organic business.
Many small-scale organic dairy farmers use stalls in their barns to position the cows and direct their manure away from their bedding. The proposed space requirements would have cows lying in their own excrement. Most family farm producers would have to build new barns to meet these space requirements—a capital investment that many could not afford, forcing them out of the organic business.
Message to NOSB: A previous recommendation, which had been accepted by the full NOSB, already requires stall barns to provide one full, traditional stall per animal. Therefore, indoor space requirements for dairy producers with stall barns are unnecessary.
More information: A complete action alert for organic dairy cows is available.
Please submit your comment electronically before the April 10 deadline.
We strongly recommend submitting two separate comments—one for nutrient additives and one for animal welfare. Also remember that a message in your own words carries more weight than cutting and pasting the sample letter, so please personalize your message, at least at the beginning and end if possible!
And your message doesn’t need to be long to be effective.
Tell your family and friends to submit their comments as well!
To speak in person at the NOSB meeting (important if you can make it):
In addition to sending their written comments, organic farmers and consumers living in the Seattle area, or willing to travel, are encouraged to also sign up for a five-minute speaking slot at the meeting at the end of April. Individuals can find more information about the meeting, and can pre-register for a slot by April 10, 2011, by visiting http://www.ams.usda.gov/nosbseattleslots or by calling (202) 720-3252.
Please email email@example.com or call 715-514-2627 if you are planning on attending the Seattle meeting.
Sample Letter for Consumers
Unregulated Synthetics/Animal Welfare
Dear Members of the National Organic Standards Board,
Thank you for your efforts in setting animal welfare standards for organically raised farm animals. I appreciate the clarification that organic laying hens and meat birds be required to have outdoor access beyond a tiny, lifeless enclosed porch.
However, I have some concerns about the proposed stocking rate chart.
For chickens, the current proposal does not grant enough space. Please require more outdoor space for chickens, since birds cannot run around freely in outdoor runs if they only have 1 ft.² or 2 ft.² Many producers already grant much more outdoor space, and 5 ft.² should be the bare minimum in the organic standards.
Please resist pressure by the industrial-scale producers to reduce the outdoor space requirements for chickens any further. When I buy organic eggs and chicken, I expect that the birds were raised with ample access to real outdoor runs. And indoors, birds should have at least 1.5 ft.² of space (1.2 ft.², the agribusiness standard for uncaged birds, is inadequate).
For growing pigs, the proposed stocking rate would not allow pigs to even turn around inside, and they would not all fit in their outdoor space. The space requirements for growing pigs must be increased.
For dairy cows, the proposed indoor space requirements would make it impossible for thousands of family-scale organic dairy producers to comply. Since a previous recommendation already requires one traditional stall per animal, indoor space requirements for dairy producers with stall barns are unnecessary.
Furthermore, I strongly object to the inclusion of any synthetic nutrient ingredient in organic food without the careful review by the NOSB, which is legally mandated.
Please do not water down the working definition of organic agriculture and food production!