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Tell the USDA: Organic Milk Must Not Come From Factory Farms
The USDA’s National Organic Program (NOP) is debating guidelines and amendments to its regulations requiring organic dairy cows access to pasture. Under the existing USDA enforcement policy, producers of organic milk are not clearly required to raise their organic cows on pasture. The lack of a stringent enforcement standard has placed the organic dairy industry under scrutiny and led to complaints that industrial-style, confined dairy feedlots are selling milk under the organic label. The public comment period ends June 12th – make your voice heard today!
| Sample Letter for Campaign |
Subject: Re: Docket # TM-05-14 National Organic Program - Access to Pasture (Livestock)
Dear [ Decision Maker ] ,
I am writing to comment on the advanced notice of proposed rulemaking regarding the National Organic Program's regulations on access to pasture in organic milk production (Docket # TM-05-14).
As a consumer, I expect that the organic milk I purchase comes from cows that have been raised on pasture - not from a factory farm where animals are confined. Industrial-style confined dairy feedlots have no place in an organic program and only serve to erode consumer confidence in the organic standards. Such operations also threaten the livelihoods of family farmers who adhere to true organic principles.
According to an April 2006 poll commissioned by the Center for Food Safety I am not alone in these expectations. The new national poll indicates that most (51% overall, and 61% of women) U.S. organic milk purchasers would stop buying organic milk after learning that some organic dairy companies do not allow significant access to pasture for their dairy cows. The poll suggests that if the USDA does not require stringent regulations that organic cows be raised for a significant period of time outdoors and on pasture, there could be substantial erosion of the organic milk market.
Organic dairy feed lots, with thousands of confined dairy cows, do not reflect what consumers want from the National Organic Program. I urge the USDA NOP to adopt a mandatory verifiable regulatory requirement for pasture that clearly excludes confined animal feeding operations (CAFOs).
At a minimum, the new standard should contain the suggestions for regulatory amendments made by the National Organic Standards Board (NOSB) regarding pasture requirements in its Draft Recommendations of Nov. 17, 2005. In addition, I strongly support the NOSB's proposal to close the existing loophole that allows dairy animals that are lactating to be confined.
I hope that the agency will move quickly to adopt these changes and maintain my confidence in the organic milk I purchase and the organic standards that I, and so many others, have come to trust.
Sincerely,
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Campaign Launched: April 11, 2006
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In its final Organic Rule of March 2000, the USDA did not adequately define for organic dairy producers how organic dairy cows should be raised, stating only that they must have “access to pasture.” In light of this vague standard, the National Organic Standards Board (NOSB – an advisory Board to the USDA on organic standards) repeatedly raised the issue of defining more meaningful and enforceable standards for dairy farms. In November 2005, NOSB developed recommendations detailing pasturing practices that would be necessary in organic dairy farming, including that animals graze pasture for at least 120 days per year (except during birthing or up to 6 months of age), and that organic operations must not prevent dairy animals from grazing pasture during lactation (currently, organic producers are allowed to temporarily confine dairy animals under vague “stage of production” temporary confinement standards. This language has been used by some dairies to confine animals that are lactating, deeming lactation a “stage of production.” Given that dairy cows are raised to produce milk, this “stage of production” could be used to confine them indefinitely).
The November NOSB recommendations followed several years of input and recommendations from the Board. As the group noted last year, “The NOSB has received thousands of comments in support of its draft recommendations. The preponderance of supportive comments have been submitted by dairy producers and consumers, stressing the environmental, animal health, and nutritional benefits derived from pastured ruminants.”
More Information and New Releases:
Center for Food Safety: Organic Milk Market Threatened by Lack of Adequate Pasture Requirement
Joint press release from the Center for Food Safety and Consumers Union
Read written testimony from the Center for Food Safety (pdf document)
Read the November 17, 2005 NOSB Draft Recommendation on Pasture Requirements for Ruminants (pdf)
Read the USDA’s Federal Register Notice on Public Comment Period (pdf document)
Read the Polling Data from CFS (pdf)
Read the Cornucopia Institute’s Dairy Report and Scorecard “Maintaining the Integrity of Organic Milk.”