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Concerns with new National Organic Program proposed animal welfare rules

USDA has proposed new animal welfare standards for the National Organic Program that, if enacted, would be the first time such standards are codified in federal law. This could present serious challenges to livestock producers.

Livestock organizations pointed out a number of problems with the proposed new standards, including: animal production practices have nothing to do with the basic concept of “organic” production; the standards add complexity to the organic certification process, creating significant barriers to existing and new organic producers; and they could jeopardize animal and public health.

Following are specific points on the new standards from the National Pork Producers Council.

 

Animal welfare is not germane to the basic concept of “organic”

  • Organic has pertained to foods produced without synthetic pesticides, antibiotics, synthetic fertilizers, genetically modified organisms or growth hormones.
  • The Organic Food Production Act of 1990 limited its coverage of livestock to feeding and medication practices.
  • While the Agriculture Secretary can consider additional provisions, they must be within the scope of the 1990 act.
  • Some of the proposed standards, such as requiring outdoor access and, for pigs, allowing for rooting behavior, conflict with other tenets of organic production such as environmental stewardship.
  • Consumer confusion about the meaning of “organic” should not drive rulemaking; consumer education campaigns should address confusion, not an expansion of the scope of the organic program.
  • Animal welfare is important to all producers and is not exclusive to organic production.

 

New standards add complexity and create barriers to existing and new organic producers

  • Current organic producers have designed their enterprises around existing organic standards. The new requirements may make it cost prohibitive to retrofit operations to come into compliance.
  • The proposed standards, many of which run counter to best management practices to protect animal health and the environment, could be a barrier to new producers considering organic production.
  • The standards will increase the cost of organic livestock products without making them more “organic” by standard definition.
  • Rather than expanding organic livestock production, the standards could reduce the number of organic producers.

 

Animal welfare is complex and needs to be science-based

  • The proposed standards are rigid, inflexible and not science-based; they will not allow organic producers the flexibility to respond to new housing and handling systems that may be developed to enhance animal welfare.
  • The standards are based on public perception of what is good animal welfare and do not reflect a consensus by experts in animal welfare and handling.
  • Producers need flexibility to make animal welfare decisions based on the needs and challenges of their particular animals, facilities and customer preferences. A one-size-fits-all approach eliminates that flexibility. Standards should be outcome-based; there is not yet an international standard for pigs:
  • Livestock industry and NGO animal welfare programs are available and suitable for use by organic producers.
  • The pork industry’s PQA Plus program is a good example of an industry program that provides a significant and outcome-based measure of animal welfare.
  • The World Animal Health Organization (or OIE, of which the U.S. is a member) sets international animal welfare standards and has not yet issued a chapter on pigs.
  • It is premature to put any welfare practices into the Code of Federal Regulations since they may conflict with the international standards now under development.

Proposed standards for pigs present challenges to animal and public health:

  • Requirements on outdoor access, bedding and rooting behavior are in conflict with best management practices to prevent significant swine diseases that pose a threat to animal and human health.
  • The U.S. made a significant and costly effort to eliminate pseudorabies from the commercial swine herd. Keeping pigs outdoors facilitates exposure to feral pigs known to harbor the pseudorabies virus. There would be significant international trade ramifications if pseudorabies were reintroduced to farmed pigs.
  • Outdoor production is the major route of introduction for the trichinae parasite. Increased cases of trichinae in organic pork would lead to consumer trust problems for all pork products and to potential distrust of our pork from U.S. trading partners.

Restrictions on tail docking and teeth clipping would not allow producers the freedom to make needed husbandry decisions, which are implemented to protect animal welfare.

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