This will be a brief diary because I've left it to the last minute so it HAS TO be written, and yet - I have no time to write it. But here's the deal. The USDA proposed new organic rules that may have a good intent but the actual rules themselves are a friggin' mess. They have a comment period ending December 23 - in 11 days. So they need an earful from us, and quick!
Here's the short story surrounding this:
When you pay a premium for organic milk, you want your money's worth, right? Not just a lack of pesticides and antibiotics in the milk, but some environmental benefits and an extra cancer fighting nutrient in the milk called CLA would be nice, right? And when you have solar-powered cows - cows that graze on grass, converting energy from the sun into organic milk - that's what you get.
Well to date, some factory farms have been able to pose as "organic" and charge you the high price without giving you what you're paying for. Those are oil-powered cows - you get the lack of pesticides/antibiotics but nothing else from them. The rule aims to stop that - but accidentally takes out about half of legitimate organic dairies in the process.
Details on how to comment and what to say are below.
I'm going to apologize up front for my cut and paste job here, and for my lack of explanation of the talking points. Honestly, when I read through the details of this stuff it made my head spin. I've known about these impending rules for a few months and it took a bunch of farmers and experts coming together to come up with talking points because it was just convoluted and confusing!
So here's the best of what I've got, and it's what was agreed upon by the experts who are FOR ensuring that organic means organic. Again, apologies for lack of explanations and for asking you to take a leap of faith that the talking points below will help keep the legitimate dairy farmers in the game while disqualifying the "organic" factory farms.
From the National Organic Coalition:
The USDA National Organic Program (NOP) released the long anticipated proposed rules tightening the pasture requirements for organic livestock on Friday October 24, 2008. This is a strong proposal that guarantees that organic milk production meets consumer expectations.
The proposal needs to be improved to remove overly prescriptive language that will cause problems for the health and safety of animals, might have negative impacts on the environment, and place extensive record keeping burdens on farmers. This can be done while preserving the requirement that organic ruminants be on pasture as much as possible during the grazing season.
Please submit your comments ASAP - see below for detailed instructions
See the NOC website, http://www.nationalorganiccoalition.org or http://www.nodpa.com/... for more detailed information and a suggested re-write of rule language. Suggested key points for comment:
§ Support the requirement for a minimum 30% dry matter intake (DMI) from pasture, averaged over the full growing season, with the growing season
ranging from 121 - 365 days, but substitute "grazing season" for "growing season," to take into account the reality of the grazing seasons in
different areas.
§ Require that ruminants are managed on pasture only during the grazing season, (not year round) to take into account different farming conditions, to protect pastures from damage, and to protect the health and safety of the livestock during adverse weather conditions.
§ NOP must provide needed exemptions for ruminants from pasture and outdoor access during periods of inclement weather and to protect soil and water quality.
§ Revise the definition of "inclement weather" so that any condition that causes physical harm to animals is a valid reason for limiting pasture
and outdoor access.
§ Dry lots and feed lots, where animals are confined and there is little or no vegetation, should be explicitly banned for ruminants. However, clean well-managed feeding pads (barn yards) are essential facilities needed
for exercise and outdoor access during the non-grazing season, and as a
supplement to pasture during the grazing season.
§ Modify the definition of "sacrificial pasture" to indicate this
can be used during the non-grazing season to provide outside access, and
make use of this practice optional, as the practice may be detrimental to
the environment, including to soil and water quality, and to animal health
when operations do not have well drained land that is accessible for
livestock or during winter weather or excessive rain conditions.
§ Streamline the proposed record keeping requirements for livestock operations so that farmers can document their pasture feed rations in
various ways that are acceptable to certifiers.
§ NOP must drop proposed language regarding replacement dairy animals. As proposed, it will allow certain farms to buy non-organic animals, and require others to buy or raise only organic young stock. The NOP must move quickly to publish a Proposed Origin of Livestock Rule that has one criterion for dairy replacement animals for all operations: "Once an operation has been certified for organic production, all dairy animals born or brought onto the operation shall be under organic management from the last third of gestation."
§ Permit grain finishing of beef slaughter stock, such that these animals may be exempt from the 30% pasture DMI requirement during the finishing period, not to exceed 120 days, but must not be denied access to pasture during that period.
§ Remove "bee" and "fish used for food" from the definition of "livestock" until proposed standards are issued for those production systems.
Please also demand that USDA NOP enforce the current regulation in regards to pasture while the proposed rule goes through the process of becoming a Final Rule
Once in effect and with implementation by 2010, we urge NOP to enforce the new regulation and work with producers and certifiers to educate them on the requirements of the new rules. With these changes, a final rule can be written that can safeguard the long-term integrity of organic farming.
How to Comment: Go here and submit your comment based on the talking points above. In case the link fails, you need to go to http://www.regulations.gov and you're looking for the Proposed Rules for docket AMS-TM-06-0198