Adapted from Organic Trade Association (OTA) https://ota.com/advocacy/critical-issues/organic-animal-welfare-standards
The USDA released the Organic Livestock and Poultry Standards (OLPS) Proposed Rule and is currently seeking public comments through October 11, 2022. The long-awaited rule has strong support from the organic industry and is a serious step toward updating critical animal welfare provisions.
OLPS clarifies the production standards of avian and mammalian livestock as authorized by the Organic Foods Production Act (OFPA) to support consistent enforcement across producers and alleviate market failure by assuring consumers that USDA-certified organic livestock products meet a robust and uniform standard. The proposed rule
- clarifies living conditions, health care, transportation, and slaughter practices to support animal welfare for mammalian livestock species and
- establishes poultry indoor and outdoor space requirements and stocking density limits. Enclosed porches are not considered outdoor spaces.
Current USDA organic standards already require outdoor access and appropriate living conditions for poultry and livestock. Unfortunately, these regulations have not been consistently enforced, resulting in some large poultry companies utilizing narrow, enclosed porches instead of true outdoor access to meet this requirement. OLPS clarifies the standards for animal living conditions to require true outdoor access and room to roam for all poultry operations.
USDA has proposed two implementation periods (5 years versus 15 years) for certified egg operations to meet the outdoor space requirements for laying hens. We must take immediate action to 1) show the widespread industry and consumer support for the rule and 2) express the absurdity of the proposed 15-year implementation period and urge no more than 5 years.
USDA needs to hear from organic producers and businesses!
#1: Submit a custom comment directly to the Federal Register on behalf of your business or organization by October 11, 11:59 p.m. ET.
Comment Writing Instructions
- Write your own unique comment using our key talking points (below) or Organic Trade Association’s fill-in-the-blank template (see page 5 of the toolkit). The template is fully editable, so copy the text into your own Word document, fill in the blanks as appropriate, and delete any text that isn’t relevant to your operation.
- Submit your written comment to the USDA through the Federal Register e-portal. Word documents or PDFs can be attached (no page limit). Comments may also be submitted by mail to Erin Healy, MPH, Director Standards Division, National Organic Program, USDA-AMS-NOP, Room 2646-So., Ag Stop 0268, 1400 Independence Ave. SW, Washington, D.C. 20250-0268.
#2: Add your organization’s name to a coalition sign-on letter to USDA in support of the rule by October 4.
#3: Poultry producers and handlers, complete our survey to inform OTA’s comments by September 21.
#4: Galvanize your network of consumers to encourage individual comment submissions to the Federal Register using the Consumer Action Toolkit.
Key Talking Points
- I support the Organic Livestock and Poultry Standards Rule to strengthen organic animal welfare standards, create greater consistency among organic producers and certifiers, and meet consumer expectations for organic livestock products.
- I support true outdoor access for all organic livestock. The proposed clarification that enclosed porches do not meet the outdoor access requirements for poultry will level the playing field for producers and help eliminate consumer confusion about the meaning of the USDA organic label.
- Consumer trust and confidence in the USDA “Organic” seal are the foundation of our industry. Consumers are willing to pay a premium for expected animal welfare standards. Not meeting expectations in this area of the standard puts consumer trust in the USDA seal at stake, and it will have long-term detrimental effects on the entire industry.
- Organic is a choice. The voluntary National Organic Program relies upon regulations that are consistent, clearly enforced, and renovated over time. Market demand for organic is driven by the distinction and differentiation that the standards provide.
- Timely implementation is critical. The excessively long 15-year implementation option is unacceptable as it would amplify the existing consumer confusion and market failure that USDA acknowledges in the proposed rule. Poultry operations certified at the time of the final rule’s publication date should have no more than five years to comply, and new entrants must comply within one year.
Hint: Use the following steps to calculate your egg productivity rate:
- Count the total number of eggs you get from a hen at 78 weeks of total bird age (Example: 340 eggs/hen).
- Divide by 12 (Example: 28.33 dozen eggs per hen).
- Divide by 60 weeks of laying (Example: 0.472 dozen eggs per hen per week).
- Multiply by 52.14 weeks in a year (Example: 24.62 dozen eggs per hen per year).
For more information, visit the Organic Trade Association website and download the Action Toolkit. If you have any questions about the proposed rule and how it might impact you or need assistance submitting your comment, please reach out to CCOF Senior Policy Research Specialist Laetitia Benador at lbenador@ccof.org.