Sulphur in organic wine; Living conditions for organic poultry and hogs

November 15, 2011

National Organic Standards Board
USDA-AMS-NOP
1400 Independence Ave., SW.
Room 2646-S, Mail Stop 0268
Washington, DC 20250-0268

Dear NOSB members,

In addition to our comments on additives deemed nutrients, please consider the following:

Livestock health care practice standard - Sec. 205.238
We appreciate the prohibitions of physical alternations, such as de-beaking, de-snooding, dubbing, and toe trimming. Thank you. We urge you also to prohibit forced molting.

The recommendation allowing ammonia levels to a maximum 25 ppm must be improved. Scientific analyses cited in the book, “Measuring and Auditing Broiler Welfare,” by Claire Weeks and Andrew Butterworth (CAB International, 2004) determined that “… broiler chickens (and adult hens) are averse to ammonia at concentrations of 20 ppm and higher, indicating that various physiological systems and processes are adversely affected.”

Evidence from original papers reviewed by Kristensen and Wathes (2000) show excessive ammonia exposure among chickens “cause air sac lesions and keratoconjunctivitis, may increase susceptibility to certain diseases; affects foraging, preening, and resting behavior; may reduce food intake and cause weight loss; and may irritate mucous membranes.”

According to Weeks and Butterworth, “DEFRA (Department of Environment, Food and Rural Affairs, U.K., 2002) recommends a maximum ammonia concentration of 20 ppm on the grounds of welfare, and this is consistent with the scientific evidence. If a cautionary approach is taken, then a suggested upper guideline for the ammonia concentration in broiler houses is 10 ppm.”

Based on such science, the NOSB recommendation that “Ammonia levels should be less than 10 ppm” is appropriate as an upper level from a cautionary approach. But to be consistent with the scientific evidence for chicken welfare, ammonia levels must never exceed 20 ppm. This is the maximum level we support.

Exposure limits to ammonia for swine health are 11 ppm, according to Kelley Donham, University of Iowa (Donham et al, 2002).

Since organic standards are a process based system, methods and practices to prevent excessive ammonia build-up may be prescribed, such as keeping ammonia monitors at the height animals breathe, not higher where readings can be different and misleading. Monitors should be checked and levels recorded daily so exposure does not exceed upper limits, except for very short periods of time under unusual circumstances.

Regarding space for chickens, we advocate the consumer’s expectations \x{2500} that organic standards represent the highest animal welfare standards in the nation. This means at least 2 sq ft indoors and 5 sq ft outdoors for both broilers and layers; anything less would make organic standards lower than the highest current U.S. standard. These allowances reflect the average chicken’s wingspan of 2.5 ft and the need for sufficient outdoor space to allow vegetation to regenerate.

Regarding space allowances for swine, we’re grateful you recommend prohibition of confinement in cages under any circumstances. We agree, however, with the minority opinion that Livestock Committee recommendations are ignoring the voice of the market.

The minority opinion cites results of 337 citizen comments on poultry and pigs for the April 2011 meeting. It says 73.5% (83 of 113 comments) recommended MORE space for poultry, and 99.6% (223 of 224 comments) recommended MORE space for pigs. These comments cited, for instance, the need for all chickens to have room to spread their wings at any given time (just as the proposal says “all birds must be able to get up off the floor at any given time”); they cited the need for organic standards to give pigs more space than so-called factory farms.

The Livestock Committee action does not reflect these majority views, as though the process for public comment is irrelevant to some board members. The poultry numbers have barely budged, and there’s no change in space requirements for pigs.

The recommendations of a representative body, such as NOSB, should reflect the considered thoughts of constituents.

Sulfites in organic wine
We strongly advocate no change to the current rules regarding sulfites for wine. Consumers accept naturally occurring sulfites, allowed in organic wine up to 20 ppm. (Many quality organic wines, for instance, contain about 7 ppm.) But organic consumers do not support a change that would allow any added sulphur in wines labeled organic and, as a retailer, we reject the notion that up to 100 ppm of total sulfites is either reasonable or acceptable.

The 100 ppm figure is hugely excessive. Responsible non-organic winemakers generally limit added sulphur to levels far below that threshold, from 20 to 50 ppm. Too much sulphur can be smelled and tasted, and sound wine-making practices make it completely unnecessary.

The prohibition against adding sulphur to organic wine also is clear and easy for consumers to understand. Allowing added sulphur would blur the distinction of organics in the marketplace. Raising the threshold of total sulfites to 100 ppm is well beyond what any responsible, quality winemaker would allow.

Thank you for reading these comments, and for respecting that organic standards were designed to be consumer-driven.

Trudy Bialic

Director, Public Affairs
PCC Natural Markets

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