Organic regulations currently require year-round outdoor access for all livestock raised in organic systems. Despite this requirement, not all organic producers are providing true outdoor access. This lack of consistency in the organic standards hurts both consumer and producer trust in the organic label. And organic livestock and poultry operations that already adhere to high standards are being undercut economically because of loopholes that allow a few very large opera-tions to deny meaningful outdoor access.
The National Organic Coalition (NOC) has long advocated for regulatory action by USDA’s National Organic Program (NOP) to address animal welfare stand-ards for organic poultry and livestock operations. We strongly support the passage of new rules to create clarity and consistency in the standards and to facilitate level enforcement.
Because the National Organic Standards Board (NOSB) and organic community have consistently called for meaningful outdoor access for poultry dating back to 1998, it is disingenuous for poultry operations that do not meet these requirements to claim that they have been taken by surprise. Furthermore, the pro-posed rule provides ample time to comply. NOC is urging the USDA to move expeditiously with the rulemaking process and implement the much-needed changes to the organic standards that will assure consumers and producers alike that farms meet basic animal welfare standards, including meaningful outdoor access for organic poultry.
In our detailed comments we suggest significant changes to strengthen the proposed rule and also list parts of the proposed rule that we support.
- NOC urges the NOP to require that at least 50 percent of outdoor areas are covered with vegetation, rather than bare soil. The NOSB recom-mendation for outdoor space requirements for poultry was developed in concert with their belief that the area would also be vegetated. This vegetation is a cornerstone of providing a healthy, beneficial environment for the birds.
- Pasture-based systems of poultry production provide a high level of animal welfare because birds have access to vegetative cover, are moved frequently to new pasture, and are not left to sit in excrement. These systems are distinct in several key ways from poultry production that relies on sta-tionary houses. The NOP must put forward a separate set of requirements for pasture-based operations pertaining to space, perches, and dust baths, and we have provided specific language and suggestions in our draft comments.
- We support the clarification in the proposed rule that porches cannot be considered outdoor space (§ 205.241(c)(6)), that outdoor areas must in-clude enrichment (§ 205.241(c)(1)), that producers are required to introduce birds to outdoor spaces early in life (§ 205.241(c)(1)), and that forced molting is prohibited (205.238(c)(10)).
- We urge the NOP to require more outdoor space for laying hens in systems that rely on stationary poultry houses. 2.25 pounds of hen per square foot of outdoor space is simply not enough space to allow for freedom of movement and living conditions that accommodate the natural behaviors of laying hens.
- Requiring that 50 percent of outdoor access be on soil is not appropriate during much of the non-grazing season and would create permanent condi-tions that threaten soil and water quality. This issue was grappled with and ultimately addressed via the “pasture rule”. We suggest changes to ensure that this proposed rule does not conflict with the “pasture rule.”
- We also ask for clarification through the regulatory language that bedded packs, compost packs, tie-stalls, free-stalls and stanchion barns are all acceptable as housing systems for dairy cattle.
- The proposed rule is inadequate in addressing the range of production systems for swine in a holistic way. While NOC supports the parts of the rule that do address animal welfare for swine, including sections 205.239(a)(8 – 11) and 205.239(a)(4)(i), we believe the NOP must more fully address stocking densities and minimum space requirements, swine production in hoop houses, wallowing, types of bedding, pasture farrowing, and issues around soil and water quality.
- The NOP must provide further opportunities for public debate and input to ensure that the regulations provide high animal welfare for swine and are tailored to the multiple systems of production in use.
- We support the clarification provided by this proposed rule that swine in organic operations must have access to the soil, though we would like to see a three-year implementation period to ensure the producers who do not currently meet this requirement have time to comply.
We are aware of arguments that chickens should be confined continually indoors in order to protect food safety and animal health. These arguments seem to be primarily from producers whose poultry houses would not be able to accommodate the outdoor space requirements for all chickens. We do not agree with these arguments, as scientific studies indicate that indoor confinement is a risk factor, and therefore not part of the solution, for food safety and ani-mal health problems.
In July of 2015, NOC published a policy paper summarizing scientific research that demonstrates that confinement increases the risk that low pathogenic Avian Influenza (AI) will mutate into highly pathogenic AI (HPAI) because confinement decreases access to fresh air and because the birds are sitting on top of contaminated feces and dead bird carcasses.
NOC asserts that organic systems that require that birds exhibit “natural behaviors” and require true outdoor access contribute to good animal health and food safety. Preventing future outbreaks of HPAI, salmonella, and other diseases and food borne illnesses should involve addressing the root of the prob-lem, by building a system of poultry farming with low densities, outdoor access, and healthy birds with strong immune systems.
NOC’s detailed comments on the Organic Livestock and Poultry Practices Rule and our policy paper on avian influenza are available at http://www.nationalorganiccoalition.org/news-items/animal-welfare.