Support Changes to the Origin of Livestock Rule

The USDA’s National Organic Program (NOP) has reopened the comment period on the 2015 Origin of Livestock proposed rule that attempts to prevent large, industrial dairy and cattle operations from gaming the system. While the rule proposes positive steps, it needs to be strengthened significantly to level the playing field for small farmers and protect the integrity of the organic label.

Write to Congress and the NOP, demanding that the Origin of Livestock rule is strengthened before it is completed and implemented.

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Please enact a strengthened Origin of Livestock rule

Dear [Decision Maker],

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The USDA's National Organic Program (NOP) has reopened the comment period on the 2015 Origin of Livestock proposed rule that attempts to prevent large, industrial dairy and cattle operations from gaming the system. While the rule proposes positive steps, it needs to be strengthened significantly to level the playing field for small farmers and protect the integrity of the organic label.

There are two key issues. The first deals with organic milk. In organic regulations, there is a provision that allows the one-time conversion of a conventional dairy herd to an organic herd. The intent of this rule was to allow a farmer the flexibility to transition his or her operation from conventional to organic. This provision has been abused by industrial "organic" dairies that continuously transition non-organic cows to organic. This continuous transitioning of animals allows these industrial producers to grow their dairy herds more quickly and less expensively than farmers doing the right thing, enabling them to flood the market with cheap "organic" milk.

I support changes to the existing law to prohibit continuous transitioning of dairy cows.  Some have suggested that the term "producer" should be replaced with "certified operation" for clarity, since the latter term is more commonly used and understood in the industry.

The second issue is breeder stock. The rule should be strengthened to prohibit the cycling of breeder stock. Like the above change, NOP could amend the rule by stipulating that breeder stock can be transitioned only once to organic to prohibit the cycling back and forth, as this practice undermines the basic concept of organic herd health.

With these changes, please complete this rule and start protecting organic integrity!

Sincerely,
[Your Name]
[Your Address]
[City, State ZIP]
[Your Email]