Suggestions for organic animal welfare

October 19, 2009

To: National Organic Standards Board Livestock Committee

Re: AMS-TM-09-0060
Livestock Committee recommendation: Animal Welfare

As a consumer-owned grocery chain — the nation’s largest consumer-owned grocer — PCC Natural Markets is very pleased with the Livestock Committee’s initiative to strengthen organic standards for animal welfare.

We are glad the NOSB conducted several conference calls with experts, that you invited speakers to a meeting, and that you made site visits to farm operations. We very much agree with and support your conclusion that current livestock regulations lack specificity. We agree that imprecise language has allowed unintended production practices that limit animal welfare.

We have reviewed the Livestock Committee’s recommendations and applaud the care and thought that went into addressing shortcomings of the current regulations. We believe the recommendations will improve animal welfare on organic operations. We are disappointed, however, that the 34 days allowed for public comment is not sufficient for many organic ranchers and consumers to read and consider the recommendations, and to draft comments.

We respectfully ask that the full NOSB vote be delayed to the next meeting so a concerted effort can be made to notify independent ranchers and consumers of the opportunity to comment on the proposed recommendations. We ask that you allow an additional 60 days for comment, so the comment can be discussed and addressed before the recommendations are voted on, finalized and forwarded to the Secretary of Agriculture. Animal welfare is of such critical importance to the retailer’s and consumer’s perception of organic value that it is more important to “get it right” than simply to “get it done” for expediency’s sake.

For years, numerous shoppers/consumers have asked, for instance, about the living conditions and health care practices for laying hens and broilers. The committee recommendations thankfully prohibit debeaking and de-toeing, and do set stocking rates for indoors and outdoors, ensuring an improved standard for space per bird, but they fail to guarantee the kind of outdoor access that the organic consumer now is demanding after reading about the current reality in popular books and articles.

As one shopper asked just the other day, “How many popholes are allowed for how many hens in how large a barn?” We believe our organic shoppers would support the Cornucopia Institute’s recommendation for outdoor access and ask that you review and consider the European organic standards for entry/exit pophole (door) requirements for chickens; that is, “at least 4 m per 100 m2 area of the house available to the birds.”

The space recommendations to give laying hens 2 sq. ft. per bird inside and 3 sq. ft. outside is an improvement over current standards (which give no numbers at all), but it’s still far from what European organic producers have to provide for outdoor space. We urge you to adopt the EU standard as the U.S. standard.

Shoppers also have asked, “How long do they have the option of being outdoors during daylight hours, and for what portion of their lives?” This is a concern we’ve heard expressed for years, one that we know is costing us lost sales. We know that at least some (otherwise) dedicated organic shoppers are choosing instead to purchase eggs and poultry from non-certified providers who market their products as being from truly pastured hens. These shoppers point out that an “all vegetarian diet” is not natural to chickens (or turkeys) and they want birds to be able to hunt and peck for insects and grubs and worms.

We therefore also support Cornucopia’s suggestion to delete the phrase, “or other exercise area,” in the current recommendation 205.239 (a) (2) (iii), so the rule could not be interpreted to allow concrete porches. It should read “Poultry reared in houses shall have complete access to pasture, open-air runs, and water subject to the species …” Organic consumers tell us they want organic chicks and hens to have access to outdoor areas with vegetation their whole lives, not just “a minimum of one-third of their life,” as the current recommendation reads.

We also suggest that the minimum age for slaughtering broilers to be set at 81 days, which is the European organic standard. We understand the slaughter age for U.S. broilers is considerably less. The current rules, and the Livestock Committee’s recommendations, do not address slaughter age at all but should.

Regarding ruminant livestock: Given that the amount of grain required for a 3X/day milking regimen causes acidosis and a high level of constant physical stress, increasing the risk of disease and resulting in a shortened life span, the 3X/day milking regimen should not be allowed. It is inconsistent with organic principles. The minority opinion’s defense of the 2X/day milking pattern, which better echoes the natural demand by a nursing calf, makes good sense and we believe our shoppers would support the minority opinion here, to honor the health of the cow as the priority over the desire for larger volumes of milk to sell. It also might ease fluctuations in the total supply, leveling the field for all dairies.

Many shoppers over the years have expressed how upsetting it is that calves are separated from their mothers virtually after birth, and are not allowed to nurse naturally, even for some limited weeks. This is perceived as animal cruelty, not consistent with the principle of allowing “natural behaviors.” Some organic dairies do allow calves to nurse for some specified period of time. Please consider some standard for nursing before weaning.

We also ask you to discuss and address two additional concerns, mandatory testing for Johne’s disease, and the desirability of closed herds. Again, we support the minority opinion, which suggests that organic dairies should provide a list of the animals that have left the farm, and why. The animal welfare regulations should require testing for Johne’s disease, which some estimates figure is affecting 70% of U.S. dairy cows. The MAP bacteria that causes Johne’s have been linked to Crohn’s disease in human consumers of infected meat and dairy. We know Johne’s testing is encouraged by Organic Valley, and it is conducted even by some non-organic dairy providers that supply our stores.

We ask that you add a provision to require testing to ensure Johne’s-free herds of cows, sheep and goats. Keeping a closed herd after testing would provide reasonable assurance for the farmer, protecting the health of the animals (and the farmer’s investment), and possibly the health of organic consumers.

Keeping a closed herd also would minimize the risk that offspring of cloned animals are entering the organic food supply. As the Wall Street Journal reported in March 2009, milk and meat from the offspring of cloned livestock already have entered the U.S. food supply. The owner of a farm in Jefferson, Iowa told the WSJ he has sent offspring of clones to be slaughtered for food over the past “several years.” Establishing a requirement for keeping closed herds seems like a necessary precaution given that government regulators are not tracking clones or their offspring.

We realize it’s a difficult line to walk in establishing standards, given the need for commercial scale production of organic foods. We wish to offer our suggestions to help establish a reasonable floor, so as not to cede the integrity of the consumers’ expectations.

Please extend the comment period so more stakeholders may weigh in.

Trudy Bialic
Director, Public Affairs

Related reading

Reject changes to the Packers and Stockyard Act

Letter sent to House and Senate Appropriations Committees, urging them to oppose any policy riders to limit the rulemaking authority of the Secretary of Agriculture under the Packers and Stockyards Act.

Organic ruminants need pasture and grass

Letter to the NOSB about a proposed exemption on pasturing slaughter stock.

Strengthen protections against BSE (mad cow disease)

Letter to USDA Secretary Vilsack, advocating stronger protections against BSE (mad cow disease) in the U.S. meat supply