Proposed pasturing exemption

April 16, 2010

Toni Strother, Agricultural Marketing Specialist
National Organic Program, USDA-AMS-NOP
Room 2646-So., Ag stop 0268
1400 Independence Ave. SW
Washington D.C. 20250-0268

Re: Docket # AMS-TM-06-0198; TM-05-14FR

Thank you, USDA, for soliciting comments on whether organic stakeholders support 205.239(d), allowing ruminant slaughter stock to be exempt from the minimum 30 percent dry matter intake (DMI) requirement from grazing, to allow all-grain finishing for up to 120 days.

As a consumer-owned retail grocer with 45,000 member/owners, our experience is that organic consumers absolutely want organic livestock to be pastured throughout life.

Our customers have told us for many years that they trust and expect that organic rules reflect care for an animal’s health and welfare. They assert that ruminants — dairy cows, beef cattle, sheep and goats— have evolved to eat grass and are healthiest when allowed their natural diet. They believe strongly, in turn, that 100-percent grass-fed ruminants provide the healthiest products with the best nutrient profile for consumers. This is confirmed by numerous studies on the nutritional advantage of grass-fed ruminant products.

Consumers are increasingly aware that corn and other grains are not a natural food for ruminants, and can and do make ruminants sick. The longer ruminants eat these unnatural feedlot rations, the sicker they typically become.

Based on how often we have heard opposition to these practices, we are certain that the overwhelming majority of organic consumers would not support the DMI/grazing exemption at all. They do not believe organic livestock should be in feedlots on a grain diet, even if it is organic grain. They are highly critical of producers that confine animals to feedlots.

We understand that about 20 percent of the U.S. organic beef producers today finish their beef in feedlots and do not have any pasture nearby. This mirror image of the conventional production/feedlot model does not meet organic consumers’ expectations of organic principles or organic standards.

It is unfortunate that these producers chose not to adhere to the published rule requiring them to “maintain all ruminant animals on pasture.” It is unfortunate that they chose to build their business models on a 2001 NOSB recommendation — never adopted as a rule — that beef animals may be exempted from being pastured during the final stage of finishing for no more than 120 days. Misjudging the organic standards, however, does not justify changing the standards to accommodate existing mistakes.

While organic consumers generally are sympathetic to challenges facing organic farmers, our judgment is that their aversion to the feedlot model exceeds any tolerance for compromised standards allowing an exemption to pasturing. Our assessment is that they would not want any organic slaughter stock to be confined and forced to consume an unnatural, unhealthful feed. We believe that organic consumers would understand and support not allowing the exemption, even if that makes it very difficult, if not impossible, for these producers to keep their organic status.

We believe, however, that organic consumers would understand and accept the need for supplementary grain — brought to feeders for livestock on pasture — during the non-grazing season. We are certain organic consumers would want the 30 percent DMI requirement to apply, no exemption.

For these reasons, it is entirely sensible to support a dual labeling system for organic meat: 1) “Organic – 100% grass-fed,” or 2) “Organic – pastured with grain,” a label that would require pasturing throughout a ruminant’s life but allow farmers to supplement the diet with grains at pasture.

This dual labeling system would allow for the exemption but also would convey the information organic consumers are demanding to know, more than ever: “How are the animals raised? Are they pastured throughout life? Are they eating grass or grain?” Dual labeling would provide answers, right at the point of sale.

Dual labeling also would help retailers tremendously. It would enable us to know more definitively whether consumers prefer beef produced with some grain in the diet, or whether they prefer 100 percent grass-fed. This sorting out at the consumer level would help us better understand consumer demand based on sales. It also would reward producers according to their practices.

In the absence of such a dual labeling system, we would not advocate the DMI/pasture exemption for slaughter stock. Our organic consumers do not support the feedlot-finishing model. They see it as virtually equivalent to the non-organic, industrial model.

We believe organic standards must reflect the organic consumers’ desires and expectations, not a production model that is simply faster or cheaper or more expedient.

Sincerely,
Trudy Bialic
Director, Public Affairs

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