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AMSRulemakingAMS-TM-06-0198

National Organic Program (NOP) - Access to Pasture (Livestock).

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National Cattlemen's Beef Association filings
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National Cattlemen's Beef Association filed 1 comment on this docket between Jan 27, 2009 and Jan 27, 2009. 95 other organizations filed here. The comment window closed 5944d ago.

What National Cattlemen's Beef Association filed (1)

Jan 27, 2009· Comment from Andy Groseta, National Cattlemen's Beef Association· AMS-TM-06-0198-3762

December 23, 2008 Mr. Richard H. Mathews Chief, Standards Development and Review Branch National Organic Program Transportation and Marketing Programs USDA-AMS-TMP-NOP 1400 Independence Ave, SW Room 4008-So., Ag Stop 0268 Washington, DC 20250 RE: Docket No. AMS-TM-06-0198; TM-05-14 Proposed Rule: National Organic Program (NOP) – Access to Pasture (Livestock) Dear Mr. Mathews: The National Cattlemen's Beef Association (NCBA) is America's oldest and largest cattle producer organization. Through direct membership and our state and breed affiliates, we represent over 230,000 cattle producers across the United States. We appreciate the opportunity to review and comment on this proposed rule which was published in the "Federal Register" on October 24, 2008 (vol. 73, no. 207, pages 63584-63608). We understand the need to further define the criteria for organic production and to create uniformity in organic practices in order to ensure that consumers feel confident with the United States Department of Agriculture's (USDA) organic label. We understand that without consumer confidence in the program, the organic label has no value to cattle producers who want to meet the demand from our consumers who want organic beef. This proposed rule, however, goes beyond consumer concerns by blurring the lines between organic and naturally raised or grass fed production systems, and by giving the impression that conventional beef production is of lower quality. The proposed rule also arbitrarily dictates cattle nutrition without scientific basis. First and foremost, we want to remind USDA and our consumers that organic beef is not any safer than conventionally raised beef. USDA and the Food and Drug Administration (FDA) have multiple firewalls, production/processing requirements, and guidelines that ensure that the U.S. beef supply is safe and wholesome. Even more important are the steps that the U.S. beef industry has voluntarily taken to raise healthy cattle and produce high quality beef. Programs such as NCBA's Beef Quality Assurance (BQA) educate, train, and certify cattle producers in the most up-to-date animal production methods. Every day, cattle producers work with their veterinarians, extension agents, animal nutritionists, and other experts to ensure their animals are healthy and that America's resulting beef supply is safe, wholesome, and fit for all of our consumers. Organic beef is raised in order to meet a demand from some consumers for beef that is produced in a different manner. That manner is no more or less safe, or of better quality, than non-organic beef. We urge USDA to be clear in this message. The National Organic Program is a marketing program, not a food safety tool. NCBA's biggest concern is with the prohibition on finishing cattle in a feedlot. As you mention in the proposed rule on page 63596, the National Organic Standards Board (NOSB) recommended that the Secretary of Agriculture publish regulatory language authorizing temporary confinement (up to 120 days) in feedlots for the finish feeding of organic cattle. The rule's prohibition, however, is one area where we believe AMS blurs the line between organic and naturally raised or grass fed production systems because as long as the feed ration meets the organic feed requirements, there should be no need to disqualify that product from carrying the organic label. Your argument that this exception would be contrary to the consumers' expectations illustrates the need to better educate the consumer on organics and not allow emotion or unrealistic views to direct these regulations. We agree that cattle enrolled in USDA's organic program should be given access to pasture, but taking those cattle off of the pasture and finishing them out in a feedlot with organic feed does not negate the end result – beef from cattle that have been raised according to the specifications of an organic production process. We als…

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