After gathering input from organic farmers, researchers, the National Organic Standards Board (NOSB), and the public over the past ten years, the National Organic Program (NOP) rolled out its Organic Livestock and Poultry Practices Rule (OLPP) in January. The OLPP or "animal welfare" rule would allow the NOP to consistently enforce stronger animal welfare standards on organic farms and remove loopholes being taken advantage of by some large operations.
However, rather than allowing the OLPP or "animal welfare" rule to take effect this month, the USDA has delayed implementation of the rule until November 14th and in June held a public comment period asking whether it should be implemented at all. On June 9th, NOFA-VT and VOF submitted the following comments urging USDA to allow the proposed rules to take effect without further delay.
June 9, 2017
Dr. Paul Lewis, Ph.D., Director
Standards Division, National Organic Program
USDA-AMS-NOP
1400 Independence Ave. SW
Room 2646-So., Ag Stop 0268
Washington, DC 20250-0268
Re: AMS-NOP-17-0031; NOP-15-06A Organic Livestock and Poultry Practices Second Proposed Rule
The Northeast Organic Farming Association of Vermont (NOFA-VT) is one of the oldest organic farming organizations in the country with 1,200 members – farmers, gardeners and consumers – working to promote an economically viable and ecologically sound food system. Vermont Organic Farmers LLC (VOF) is a USDA accredited certifier representing over 700 certified organic farmers and processors. VOF has been certifying producers since 1985 and has been accredited by the USDA since 2002.
NOFA-VT and VOF strongly support implementation of the Organic Livestock and Poultry Practices (OLPP) rule and urge USDA to allow the rule to take effect on November 14th without further delay. Of the possible actions being considered by USDA, we strongly support option “(1) Let the rule become effective. This means that the rule would become effective on November 14, 2017.”
The OLPP rule was developed over many years with extensive input from organic farmers, researchers, multiple government agencies, the National Organic Standards Board (NOSB), and the public. The organic community widely agrees that these rules are necessary to ensure greater consistency in the enforcement of organic standards and to preserve consumer confidence in the organic label.
The vast majority of organic livestock and poultry producers already adhere to high standards and comply with the provisions of the OLPP rule. However, a few operations are currently taking advantage of loopholes that allow them to deny meaningful outdoor access to animals. In doing so, these producers are undercutting the investment of those who work hard to meet the letter and spirit of the regulations. This rule is necessary to level the playing field among producers and to and maintain the integrity of the organic seal.
As a USDA accredited certifier, VOF ensures that our producers comply with all National Organic Program (NOP) rules and regulations. Those rules require that meaningful outdoor access be provided to all animals. Until the OLPP rule is implemented and the rules are consistently enforced by all certification agencies, our producers (and others) are being put at a disadvantage.
Like many other certification agencies, we have already begun the process of informing our certified producers and preparing them for implementation of the rule. Further delay or withdrawal of the rule will cause significant confusion for our producers, in addition to undercutting their investment in providing meaningful outdoor access for their animals.
Participation in the National Organic Program by producers is voluntary, meaning that producers choose to adhere to NOP rules in exchange for market opportunities and other benefits the program provides for their farms. If certain producers are unwilling or unable to adhere to the full extent of NOP requirements, they should not be receiving the benefits of marketing their products as organic.
As an industry that reached $47 billion in 2016 and continues to grow, organic has emerged as a bright spot in the U.S. agricultural economy. Consistently enforced standards are critical to maintaining consumer trust in the organic seal, and the OLPP rule is necessary to bring about greater fairness and consistency across the organic sector. Further delay or withdrawal of the proposed rule does damage to the organic industry and the families and rural communities it supports. We urge you to implement the rule no later than November 14, 2017.
Sincerely,
Maddie Monty, Policy Advisor
NOFA-VT
Nicole Dehne, Certification Director
VOF