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National Association of State Departments of Agriculture comments on several concerns.

July 11, 2016

2 Min Read

The comment period for amending the organic livestock and poultry production requirements is July 13.

Related: USDA extends comment period for organic production practices

USDA’s Agricultural Marketing Service proposes to:

-Add new requirements for livestock handling and transport for slaughter.

-Clarify requirements covering livestock health practices.

-Clarify outdoor and indoor animal living space requirements.

Related: USDA proposes changes to organic poultry production requirements

As of July 11, more than 5,100 comments had been received.


The National Association of State Departments of Agriculture submitted their comments on July 6. The organization represents leaders of state departments of agriculture across the country.

Among their comments:

- “The proposed rule flies in the face of modern, peer-reviewed science on animal husbandry practices which should be the driving principles behind safe, efficient, sustainable, and profitable food production.”

- “The proposal will require direct outdoor exposure and contact with wild birds and animals that are known vectors for Highly Pathogenic Avian Influenza (HPAI) and exotic Newcastle disease.”

“As written, the proposed rule changes will effectively create a contradictory regulatory framework where organic producers will have to expose their poultry and livestock to enhanced mortality, predation, animal health, and biosecurity risks or allow their organic certification to lapse. NASDA notes increased animal health and biosecurity risks will not only impact organic producers but may result in increased transmission risks across a broad range of producers, states, and regions.”

- The proposed change that amends space requirements for dairy cows would eliminate all organic dairy producers who have freestall barns. “This proposed change is based in consumer perception, not science,” the NASDA writes.

- “NASDA requests USDA conduct a more thorough economic analysis of the proposed rule using species-specific data to determine the cost producers will incur to continue participation in the organic system and how those costs will be passed down to consumers.”

Related: Organic livestock standards proposed

USDA’s AMS estimates the production cost of its proposed rule changes at $9.5 million to $24.1 million per year, annualized over 13 years.


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