Statement in response to the USDA Organic Livestock Hearing Notice dated Dec. 30, 1993: 1994
Statement by Roger Blobaum, President. Blobaum & Associates,
907 North Tower, 1331 Penn. Ave.. N.W. Washington, DC 20004.
Submitted April 4, 1994
In response to USDA Organic Livestock Hearing Notice Dated Dec. 30. 1993
My name is Roger Blobaum and I own and manage a Washington-based consulting firm that provides professional services to organic and sustainable agriculture organizations. I have many years of experience as a board member, staff member, or consultant with organic grower and industry groups and with nonprofit organizations that advocate adoption of organic methods. I appreciate this opportunity to submit a statement and request that it be included in the hearing record and considered in your deliberations.
My specific comments on implementation of organic livestock standards are based primarily on my experience in 1989-92 as director of Americans for Safe Food, a project of the Center for Science in the Public Interest (CSPI). During that time I co-chaired the Organic Food Act Working Group, a coalition of more than 25 consumer, environmental, and other organizations. The working group helped shape the Organic Food Act and push it through both houses of Congress in 1990.
National organic standards remained a high priority at CSPI in 1991 and 1992 and, during that period, I chaired a similar working group made up of representatives of most of these same organizations. Its main purpose was mobilizing public support for full implementation of national organic standards. I continued my involvement in the implementation process in 1993 as the Washington representative of the Organic Food Production Association of North America (OFPANA).
I want to begin by emphasizing that the Organic Food Act Working Group took the position throughout 1990 that national standards should not be so strict that only a few could meet them. We wanted organic farming to continue to be a fast-growing sector of agriculture and we opposed proposals for standards that would become a financial burden for growers or that would be extremely difficult to meet. I would urge you to apply that same test in your consideration of livestock standards.
It also was not our intention to have an implementation process that resulted in re-invention of the wheel. The intent was to take the 90 percent of the existing standards that organic farmers had imposed on themselves, and on which all certifying organizations agreed, and to build on that. The intent also was to draw on the expertise of state agriculture departments and farmer-controlled organizations with a track record of operating successful organic programs that enjoyed public confidence.
In testifying for CSPI during hearings in both houses, I called for legislation that struck a balance between strong national standards that guarantee the integrity of the organically-grown label and the ability of organic farmers to meet them, between the authority given to USDA to implement a program and the constraints needed to prevent any weakening by the government of standards organic farmers had developed over the years and imposed on themselves, and between the need to have some government involvement in accreditation and the need to guarantee the independent status of existing certifiers. I believe that is the kind of legislation that Congress ultimately adopted.
Although CSPI has been militant in pressing the Food and Drug Administration to make certain milk is residue free and in urging the agency repeatedly to crack down on extra-label drug use, we did not support a prohibition on the use or application of synthetic antibiotics in organically produced livestock. We felt the restricted use provisions included in standards that had been adopted by several states and certifying organizations would be acceptable to consumers. The issue of parasiticide use did not come up at all.
I would like the record to show that organic livestock standards received little attention from consumer organizations when the Organic Food Act was moving through Congress. None of the consumer organizations, as far as I can recall, ever made any public comments or submitted any testimony that dealt specifically with livestock standards. Much of the debate focused on consumer concerns related to pesticide residues in fresh produce. I would submit that is the main reason Congress gave the National Organic Standards Board so much leeway in setting livestock standards and, in addition, required this series of public hearings.
Another reason was that USDA at that time did not, and still does not, permit the sale of organic livestock products. Consumers did not have any first hand experience dealing with the organic livestock standards issue.
This is not to suggest that consumers were unaware of problems in the livestock industry. Consumer organizations would have fought hard against any provision that permitted use of sub-therapeutic doses of antibiotics, any routine use of internal parasiticides, and the use of any medications, other than vaccinations, in the absence of illness. Members of CSPI, and many other consumer groups as well, have consistently opposed the production of livestock and poultry in factory-type operations where medicated feed and other routine drug use is common practice. Concerns of this kind have been dramatized by press reports relating to inhumane practices, unbalanced rations, and drug use in veal production. Consumers also are concerned over use of hormone implants and don’t want them used under any circumstances.
There was strong support for the preventative health maintenance requirements included in existing state and private certifier standards. The emphasis in these programs is on proper sanitation and manure management, reduction of animal stress, well managed pastures, and humane living conditions. I urge you to reject standards that allow factory-type production and routine use of drugs in organic production of livestock and to recommend standards that are based on humane treatment and preventative health care.
One important area consumers were concerned about then, and still are, is the possibility of fraud and misrepresentation in the sale of organic food. I urge you to call for strict implementation of the Organic Food Act’s mandate relating to farm recordkeeping and a verifiable audit trail for each animal or flock. That includes complete and accurate records of amounts and sources of all medications administered. The medications also must be substances approved by the technical advisory panel and prescribed by a veterinarian.
Medication also should be administered when necessary but only as a last resort. Its use should be reviewed annually by certifiers, who should be required to evaluate and discuss with producers the preventative practices they have adopted to reduce use.
I also want to caution you against claims by some that consumer surveys demonstrate strong support for strict livestock standards and a total ban on use of antibiotics and parasiticides. I am unaware of a single credible survey, either in existence when the Organic Food Act was passed or since, that concludes this is what consumers want. I would submit that any survey that attempts to measure consumer attitudes toward organic livestock products should be heavily discounted due to the fact that these products are unavailable. It seems a little far fetched to be asking consumers how they feel about organic meat when they have never been able to buy any.
The one survey that may be useful is the one conducted by OFPANA’s National Livestock Committee. It identified several hundred livestock producers who now meet all the requirements for certification or plan to meet them in the future. It is extremely important to reach out to organic livestock farmers for expertise in making these decisions. I would hope that you would give serious consideration to the results of this survey.
I became convinced during my tenure at CSPI that most consumers have little or no knowledge of how livestock is produced. My impression is that they would be willing to leave most of the details related to medications to veterinarians who work with organic farmers. Consumers know a great deal about fruit and vegatable production, however, and have definite opinions about the use of pesticides and other inputs and what is needed to meet organic standards.
Another issue before you is the question of requirements for organic feed. It is important to point out that the supply of organic grain, forage, and feed supplements is limited, especially in grain-deficient regions that normally rely on supplies from other parts of the country. New organic grain and hay producers will be needed to meet feed demand as the organic livestock sector expands. I would urge you to consider a phase-in period following the implementation period with 80% organic feed required the first year, 90% the second year, and 100% in the third and subsequent years. The strictest feed standard possible, in my opinion, will slow the development of an organic production sector that, for all practical purposes, is starting from scratch.
Finally I would urge you to avoid recommending standards that are so strict that they result in livestock products that can be consumed by all chemically-sensitive people. The Organic Food Act calls for a minimum national standard based on a production claim. Congress did not require a guarantee that food labeled as organic would be residue free. It also does not bar producers from setting higher standards for themselves in order to serve this special need.
A large number of organic producers, including many in Texas and California, became certified under standards allowing them to enter this market after only one year of farming without the use of synthetic chemicals and other prohibited inputs. These farmers have, in effect, been grandfathered in. There is justification for much tighter standards now, these have been or will be adopted by certifiers, and farmers are demonstrating that they can meet them. But they should not be set so high that conventional farmers are discouraged from switching to organic methods. I would submit that most consumers would rather have much easier access to organic food than to have standards so strict that expansion of the organic sector is severely limited.
I would urge you to recommend livestock standards that guarantee the integrity of organic food but give full consideration to the need for a balance between strict standards and the ability to meet them. That is the standard that consumer groups supported when the Organic Food Act was passed. It is the standard that Congress endorsed. It is the standard that I hope the National Organic Standards Board will follow. And it is the standard that I would urge you to recommend for organic livestock as well.