CAFOs Are Gaming Organic Standards

November 21, 2019
Category: Uncategorized

The USDA is considering a rule that would help close loopholes, but it doesn’t go far enough. Action Alert!

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.

This unlevel playing field has decimated small and mid-sized organic dairies. More than half of the 125,000 dairy farms (organic and conventional) that operated in the US in 1997 have disappeared. Fifteen thousand have gone under between 2007 and 2017. These smaller operations simply cannot compete with industrial giants that abuse the spirit, if not the letter, of the law.

The second issue involves breeder stock, defined in organic regulation as “female livestock whose offspring may be incorporated into an organic operation at the time of their birth.” Breeder stock can be used to diversify the genetic pool of a herd. Under organic regulations, a non-organic cow can give birth to organic calves if the mother is under organic management from the last third of gestation. Note that conventional livestock that have transitioned to organic cannot be sold as organic slaughter—only their calves who have been under organic management since the last third of gestation can be sold as organic.

Once again, industrial concentrated animal feeding lots (CAFOs) are abusing the rule by cycling breeder stock between organic and conventional production. This is particularly a concern with hogs. CAFOs can raise a hog non-organically—that is, on GMO feed, with the use of drugs and other substances prohibited in organic production—until she is pregnant with a litter. The hog can then transition to organic management until she gives birth. The offspring are organic, and the mother is transitioned back to the non-organic sector. Again, this lowers the cost for CAFOs to produce organic livestock and puts smaller farms following the spirit of organic agriculture at a competitive disadvantage.

The NOP’s proposed rule addresses the first issue but not the second. It amends organic regulations such that the one-time conversion of conventional to organic dairy cows applies to each producer, rather than a herd; this change will prohibit the continuous transitioning currently going on in CAFOs.  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 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.

The NOP can and must make these changes. Not only are the above-mentioned abuses unfair to small producers who take seriously the philosophy of organic agriculture; they are unfair to consumers who are unwittingly paying a premium for sham organic products from CAFOs that are gaming the system. Unfortunately, as we’ve seen with other fraudulent practices in the organic system, the USDA seems perfectly fine with turning a blind eye to the abuses of Big Ag. We cannot allow it to continue.

Action Alert! Write to Congress and the NOP, demanding that the Origin of Livestock rule is strengthened before it is completed and implemented. Please send your message immediately.

31 responses to “CAFOs Are Gaming Organic Standards”

  1. Tom says:

    I demand that the Origin of Livestock rule is strengthened before it is completed and implemented

  2. Scott Rubel says:

    Class action suit against the USDA should happen for perpetuating lies.

  3. Dr. Alexander Henrich says:

    The USDA is considering a rule that would help close loopholes, but it doesn’t go far enough.

    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:
    1. 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.

    This unlevel playing field has decimated small and mid-sized organic dairies. More than half of the 125,000 dairy farms (organic and conventional) that operated in the US in 1997 have disappeared. Fifteen thousand have gone under between 2007 and 2017. These smaller operations simply cannot compete with industrial giants that abuse the spirit, if not the letter, of the law.

    2. The second issue involves breeder stock, defined in organic regulation as “female livestock whose offspring may be incorporated into an organic operation at the time of their birth.” Breeder stock can be used to diversify the genetic pool of a herd. Under organic regulations, a non-organic cow can give birth to organic calves if the mother is under organic management from the last third of gestation. Note that conventional livestock that have transitioned to organic cannot be sold as organic slaughter—only their calves who have been under organic management since the last third of gestation can be sold as organic.

    Once again, industrial concentrated animal feeding lots (CAFOs) are abusing the rule by cycling breeder stock between organic and conventional production. This is particularly a concern with hogs. CAFOs can raise a hog non-organically—that is, on GMO feed, with the use of drugs and other substances prohibited in organic production—until she is pregnant with a litter. The hog can then transition to organic management until she gives birth. The offspring are organic, and the mother is transitioned back to the non-organic sector. Again, this lowers the cost for CAFOs to produce organic livestock and puts smaller farms following the spirit of organic agriculture at a competitive disadvantage.

    The NOP’s proposed rule addresses the first issue but not the second. It amends organic regulations such that the one-time conversion of conventional to organic dairy cows applies to each producer, rather than a herd; this change will prohibit the continuous transitioning currently going on in CAFOs. 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 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.

    The NOP can and must make these changes. Not only are the above-mentioned abuses unfair to small producers who take seriously the philosophy of organic agriculture; they are unfair to consumers who are unwittingly paying a premium for sham organic products from CAFOs that are gaming the system. Unfortunately, as we’ve seen with other fraudulent practices in the organic system, the USDA seems perfectly fine with turning a blind eye to the abuses of Big Ag. We cannot allow it to continue.

    So, I am demanding that the Origin of Livestock rule is strengthened before it is completed and implemented.

    Thank you for your consideration,

  4. Joyce Espineta says:

    Please strengthen the origin of livestock rule. We want real and true organic mile, meat and produce, that is why we buy it. Do not allow farmers to cheat the system.

  5. Sheri Ambrose says:

    Allow small organic farmers to equally compete.

  6. Janice Banks says:

    Another huge chip removed from our democracy.

  7. Karl Hamann says:

    NOP: Stop letting Big Ag play games with the “Organic” label!

  8. jorge jtamargo says:

    Nothing more needs to be said then CAFOs are not in any form shape or processes Organic . For someone to approve it as so only tells me that illegal payments have been paid to make it seem like officials are just plain ignorant or corrupted and not up to the job trusted on them .

  9. Please strengthen the Origin of Livestock rule before it is completed and implemented.

  10. Kristin Felix says:

    Foods labeled “organic” should genuinely be organic, not cheap knock-offs for making extra bucks. Don’t allow us to be cheated, and don’t pander to Big Business.

  11. Rae Ball says:

    Strengthen the origin of livestock prior to passing. You are harming small and mid size dairies and favoring huge dairies.
    Thank you

  12. Thomas Nelson says:

    I demand that the Origin of Livestock rule is strengthened before it is completed and implemented.

  13. How criminal that they can get away with these horrific practices. many Thanks to You Gretchen and ANH Team for your great work and leadership in advocating for public and environmental health. Obviously our elected representatives and alphabet agencies do not care about us or our degraded, toxic environment. God Bless You All with a shield of Truth and light.

  14. Paulette Pivano says:

    I wasn’t able to forward the request on the next page to send to my representatives about homeopathic and the FDA

    • Ila Kimata says:

      Hi Paulette,

      You’ve actually already successfully submitted your request to the FDA and Congress. The page you saw that asks you to forward your request allows you to share the article and petition with a friend. I hope this helps! Thank you so much for your support!

  15. Margot says:

    hi,
    I signed it , but I can not get with that because it ask me toplace letters on end, II did several times and seam like wrong. I do not know where th problem it is

  16. francesca says:

    While the revision of the 2015 Origin of Livestock 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.

    This uneven playing field has effectively decimated small and mid-sized organic dairies. More than half of the 125,000 dairy farms (organic and conventional) that operated in the US in 1997 have disappeared. Fifteen thousand have gone under between 2007 and 2017. These smaller operations simply cannot compete with industrial giants that abuse the spirit, if not the letter, of the law.

    The second issue involves breeder stock, defined in organic regulation as “female livestock whose offspring may be incorporated into an organic operation at the time of their birth.” Breeder stock can be used to diversify the genetic pool of a herd. Under organic regulations, a non-organic cow can give birth to organic calves if the mother is under organic management from the last third of gestation. Note that conventional livestock that have transitioned to organic cannot be sold as organic slaughter—only their calves who have been under organic management since the last third of gestation can be sold as organic.

    Once again, industrial concentrated animal feeding lots (CAFOs) have been actively abusing the rule by the cycling of breeder stock between organic and conventional production. This is particularly a concern with hogs. CAFOs can raise a hog non-organically—that is, on GMO feed, with the use of drugs and other substances prohibited in organic production—until she is pregnant with a litter. The hog can then transition to organic management until she gives birth. The offspring are organic, and the mother is transitioned back to the non-organic sector. Again, this lowers the cost for CAFOs to produce organic livestock and puts smaller farms following the spirit of organic agriculture at a competitive disadvantage.

    The NOP’s proposed rule addresses the first issue but not the second. It amends organic regulations such that the one-time conversion of conventional to organic dairy cows applies to each producer, rather than a herd; this change will prohibit the continuous transitioning currently going on in CAFOs. 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 rule should be strengthened to prohibit the cycling of breeder stock. 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.

    The NOP can and must make these changes. Not only are the above-mentioned abuses unfair to small producers who take seriously the philosophy of organic agriculture; they are unfair to consumers who are unwittingly paying a premium for sham organic products from CAFOs that are gaming the system.

  17. Norma Hall says:

    The USDA should pay more attention to the health and wishes of the American public than ignoring abuses of the regulations by the big factory farms, including dairy and hog producers. Give the organic farmers a chance to compete on an even playing field. We need to know that when we pay extra for an “organic” product, it truly is organic. Tighten the standards and hold those who don’t follow them accountable for their actions. No juggling back and forth between organic and non-organic. The National Organic Program needs to step it up. It will be better for us and better for the environment.

  18. Natalie Alexander says:

    Please strengthen the Origin of Livestock rule before it is completed and implemented.

    Thank you.

  19. Jay McCaman says:

    What has happened to the pasture rule?

  20. Robin Patten says:

    Please make sure the Origin of Livestock rule is strengthened before it is completed and implemented, for the sake of consumers.

  21. Dianna Vagianos Armentrout says:

    Keep organic stock and milk pure by regulating big farms who abuse the current system.

  22. Rande Wagner says:

    Dear Congress & the NOP,
    We demand you strengthen the Origin of Livestock rule, so that the spirit of this rule will actually be effective. There are hundreds of thousands of US Citizens who are severely and adversely affected every time they are deceived at the grocery store by Big Ag’s practices. Organic products are perhaps the ONLY way these people can safely eat, so they should be able to trust labels they read and research to make sure their health is not compromised. We know, because our household is one of these. The continuous use of antibiotics, pesticides, GMO’d grains, produce and meats are a threat to us, our children, and grandchildren for many generations. We will add that the incidence of children born or susceptible to manifesting Autism Spectrum Disorders has risen 400% since the 1950’s. Asthma, diabetes, congenital malformations, and many more serious disabling conditions are now running rampant due to the greed of Big Ag, Pharma, and Chemical companies. Please, for the love of our nation’s children, stop this madness at every step. Strengthen the Origin of Livestock rule. Thank you.

  23. Peter Booth Lee says:

    The Origin of Livestock rule must be strengthened before it is completed and implemented!

  24. sharon wojno says:

    The second issue involves breeder stock, defined in organic regulation as “female livestock whose offspring may be incorporated into an organic operation at the time of their birth.” Breeder stock can be used to diversify the genetic pool of a herd. Under organic regulations, a non-organic cow can give birth to organic calves if the mother is under organic management from the last third of gestation. Note that conventional livestock that have transitioned to organic cannot be sold as organic slaughter—only their calves who have been under organic management since the last third of gestation can be sold as organic.

    Once again, industrial concentrated animal feeding lots (CAFOs) are abusing the rule by cycling breeder stock between organic and conventional production. This is particularly a concern with hogs. CAFOs can raise a hog non-organically—that is, on GMO feed, with the use of drugs and other substances prohibited in organic production—until she is pregnant with a litter. The hog can then transition to organic management until she gives birth. The offspring are organic, and the mother is transitioned back to the non-organic sector. Again, this lowers the cost for CAFOs to produce organic livestock and puts smaller farms following the spirit of organic agriculture at a competitive disadvantage.

    The NOP’s proposed rule addresses the first issue but not the second. It amends organic regulations such that the one-time conversion of conventional to organic dairy cows applies to each producer, rather than a herd; this change will prohibit the continuous transitioning currently going on in CAFOs. 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 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.

  25. Michaela Estes says:

    The Origin of Livestock rules needs to be revised and strengthened before being put into action

  26. Karen Deckel says:

    The Origin of Livestock Rule should be strengthened before it is completed and implemented. The NOP’s proposed rule addresses the first issue but not the second. It amends organic regulations such that the one-time conversion of conventional to organic dairy cows applies to each producer, rather than a herd; this change will prohibit the continuous transitioning currently going on in CAFOs. 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 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. It needs to be strengthened significantly to level the playing field for small farmers and protect the integrity of the organic label.

  27. Stefanie Sellars says:

    I demand that the Origin of Livestock rule is strengthened before it is completed and implemented.

  28. A. Farmer says:

    Far better than any ‘fix’ to the USDA organic standards is finding and supporting the small and independent farmers in your local and regional area – farmers that care deeply about the land and livestock, and providing healthful food to families. Farms that use sustainable and even regenerative
    practices, improving the soil and biodiversity on the land they farm.

    It is well worth seeking out these dedicated and hardworking people.

    These are the very farms that are being squeezed by skyrocketing costs, government regulations more suited to mega-CAFOs and industrial food production, and are increasingly being harassed for raising livestock as naturally as possible.

    Among other places, you can find many of these farms on the Farm & Garden section of Craigslist.

  29. Barbara Melanson says:

    It is virtually criminal to me that there would be an effort to prevent truly organic food, especially milk from being readily available to consumers. You must strengthen the Origin of Livestock Rule. We consumers will have less “rights” than any other American” if we have to suffer this change. You have the power to do the right thing and I am hoping you will. My daughter is on board with organic foods. She learned so much in the past 2 years and is raising my beautiful grandchildren in the best possible say feeding the entire family on wonderful, flavorful organic food and drink……milk is so delicious. You must come to the aid of we consumers that want and desire organic foods………….please do the right thing.

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