Implement organic animal welfare rule without delay

Paul Lewis Ph.D., Director
Standards Division, National Organic Program
USDA-AMS-NOP
1400 Independence Ave. SW., Room 2642-So.
Ag Stop 0268, Washington, DC 20250-0268

Docket # AMS-NOP-17-0031; NOP-15-06A
Regulatory Information Number 0581-AD74

Dear Mr. Lewis,

As a certified organic retailer, we know that a heavy portion of our business is dependent upon the integrity of organic standards and, in particular, their attention to animal welfare. We are concerned that further delay in implementing the new animal welfare rule will damage public perception of USDA’s trustworthiness and the value of its organic seal. We urge prompt implementation.

Organic and mainstream shoppers alike have made it very clear they demand strong animal welfare practices for the meat and dairy products they buy. The animal welfare practices in organics are a top attraction drawing shoppers to our stores. Consumers want to trust that a USDA organic seal provides an extra measure of care in how livestock are raised, their living conditions, what they eat, and how they die. The rule includes many provisions vital to meeting market demands. It is a market-based solution to market demands.

Organic industry stakeholders spent more than a decade developing consensus for the rule that was finalized this past January. Further delaying or suspending it disrespects the legal process put in place by Congress 27 years ago with the Organic Food Production Act. Modifying the rule to placate two large industrial egg farms and other non-organic groups that do not meet the spirit or letter of the standards would insult due process. Further delay or modification is not acceptable.

On behalf of our 56,000 member-owners, we ask USDA to finalize the organic animal welfare rule without further delay and allow it to become effective November 14, 2017.

We appreciate the opportunity to comment,

Trudy Bialic
Director, Public Affairs & Quality Standards