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NODPA Speaks Out On The Origin of Livestock

Next Steps to Save Organic -- By Ed Maltby, NODPA Executive Director.

The National Organic Standard Board (NOSB) met in St Paul, MN, from Wednesday, October 24, 2018 to Friday, October 26, 2018. On the last day of the meeting they made a clear and unanimous recommendation to the Secretary of Agriculture on the need for a Final Rule on the Origin of Livestock. They have opened the door to reactivating the 2015 Proposed Rule and bring the consistent interpretation of the one-time exemption for transitioning conventional dairy animals called for by the USDA Inspector General in 2013.

The Final Rule would need to be as simple as possible: One time transition for a conventional herd to organic that is tied to place and ownership. No exceptions. No loophole. No implementation timeline.

Friday was the day that the Board considered livestock issues and they kept the following livestock sunset materials on the list Alcohols: ethanol, isopropanol; Aspirin; Biologics- vaccines; Electrolytes; Glycerin; Phosphoric acid; Lime, hydrated; and Mineral oil. They voted to delist sucrose octanoate esters. The Board wholeheartedly agreed that there was a need for apiculture standards.

The Board then moved on to the Origin of Livestock debacle. They recognized the pressure from all sides of the organic community to present another recommendation on the Origin of Livestock Rule. Over the years, they have been asked to support the need for rulemaking and have not acted. Stimulated by a discussion at the National Organic Coalition (NOC) pre NOSB meeting, attended by 100 organic stakeholders, they passed a unanimous resolution urging USDA Secretary Perdue to issue a Final Rule on the origin of livestock that reflects the will of public stakeholders and the organic community. This was the first time in twelve years that they have acted on this issue with the following resolution:

It has come to the attention of the National Organic Standards Board (NOSB) that the continued state of varying interpretations and practices around the Origin of Livestock standards is creating market instability for organic producers. The 2015 USDA Origin of Livestock Proposed Rule was based on six recommendations from the NOSB between 1994 and 2006. The proposed rule responds to findings from the July 2013 USDA Office of Inspector General (OIG) audit report on organic milk operations stating that certifying agents were interpreting the origin of livestock requirements differently. Rulemaking is necessary to ensure consistent interpretation and enforcement of the standards for origin of livestock and to provide industry with additional clarity of application of the organic dairy standards. In early 2017 the Origin of Livestock Proposed Rule was removed from the government’s Unified Agenda of Regulatory and Deregulatory Actions. Support for this rule has been expressed through public comment by the majority of organic stakeholders. Strong federal oversight is essential for fair, consistent certification and for creating a level playing field for all certified organic operations. Therefore, be it resolved by unanimous vote, the National Organic Standards Board—as USDA’s Federal Advisory Board on organic issues and representing organic farmers, ranchers, processors, retailers and consumers—urges the Secretary to directly issue a final rule for Origin of Livestock that incorporates public comments submitted in response to the Proposed Rule (Docket Number AMS-NOP-11-0009).