The comment period has come to a close on the U.S. Department of Agriculture’s proposed new animal welfare standards for the National Organic Program. The overall sentiment from the major livestock industry groups was less than welcoming, as they each posed a rundown on issues they have with USDA’s proposed rule.

The proposed rule featured a number of substantial changes and requirements, including changes pertaining to space and property requirements for animals.

Poultry, eggs

Perdue Farms said it endorses the proposal to give broilers more room inside chicken houses, ensure sufficient pasture space with ready access to the outdoors and require husbandry practices that promote natural behaviors. Perdue Foods has been raising and selling organic broiler chickens since its 2011 acquisition of Coleman Natural Foods, and is now the largest organic-certified broiler producer in the U.S.

In its letter, Perdue also asks that the implementation deadline for additional space be extended from one year to three years. This will ensure the ongoing availability of organic chicken for consumers while producers expand farm space, Perdue said.

The National Chicken Council, representing vertically integrated companies that produce and process more than 95% of the chicken marketed in the United States, expressed concern that the proposed rule imposes “unreasonable costs and requirements of doubtful benefit on organic farmers, presents grave risks to animal health…and undermines ongoing international efforts to develop poultry welfare standards,” said Ashley Peterson, Ph.D., NCC senior vice president of scientific and regulatory affairs.

The proposed standards are assumed to increase the mortality rates for laying hens and broiler chickens from 5 to 8%, a 60% increase. Mortality rates are a key indicator of animal welfare and flock health, yet the proposed changes would increase mortality, significantly decreasing bird welfare and farmer economic viability.

The United Egg Producers (UEP), the farmer-owned cooperative whose producer members independently market more than 95% of all eggs produced in sold in the United States. USDA acknowledges that only 10% of the organic layer flock is owned by farms that already comply with the proposed rule, therefore UEP said this rule will significantly increase costs for 90% of the flock which many may not be able to comply with due to existing facility construction and land restraints.

UEP strongly urged USDA to reconsider the proposed requirements requiring outdoor space, with respects to both the amount required and what counts toward outdoor space. They also sought changes to the stipulation that outdoor areas much have suitable enrichments to entice the birds to go outdoors.

Dairy

In 2009, the National Milk Producers Federation (NMPF) with support from Dairy Management Inc., recognizing the importance in ensuring consistency in dairy animal care and wellbeing, launched the National Dairy FARM Program: Farmers Assuring Responsible Management (FARM Program). The FARM Program is a national on-farm education, evaluation, and verification program designed to help dairy farmers assure high standards in animal care and wellbeing.

In their comments, NMPF said it believes that the FARM Program assures animal care and wellbeing in the U.S. dairy industry and the changes proposed by USDA-NOP in the Proposed Rule are unnecessary and duplicative for dairy cattle. Their comments take a very thorough look at the proposed rules and make several suggested changes based on how the FARM Program is already set up and working.

Pork

The National Pork Producers Council commented on what it views as a number of problems with the proposed welfare rules which for the first time would be codified in federal law and could pose serious challenges to livestock producers.

NPPC, which opposes the new standards, explained that animal welfare is not germane to the concept of "organic," which previously has pertained to foods produced without synthetic fertilizers or pesticides, antibiotics, genetically modified organisms or growth hormones. Some of the proposed standards, such as requiring outdoor access and, for pigs, allowing for rooting behavior, conflict with other tenets of organic production, such as environmental stewardship, NPPC noted.

Consumer confusion about the meaning of organic should not drive rule-making, NPPC noted; rather, consumer education campaigns should address any confusion.

Beef

The National Cattlemen’s Beef Assn. (NCBA) said that voluntary agency marketing programs – such as the National Organic Program – is not the place to codify animal production practices. Tracy Brunner, NCBA president, said NCBA has worked for the past 30 years to develop and improve animal care and handling standards through the Beef Quality Assurance Program.

“Rather than set rigid politic standards in statute, the Beef Quality Assurance program is driven by experts in animal care, using industry-accepted and peer reviewed sciences to set the program guidelines,” Brunner said.

NCBA asked USDA to withdraw the current proposed rule and work with all producers to draft a rule that gives consumers choice and producers marketing opportunities that do not disparage conventional products.