Comments on NOSB’s
“Livestock Committee Recommendation for Guidance –
Pasture Requirements for the National Organic Program”
June 10, 2005
The Organic Trade Association thanks the National Organic Standards Board (NOSB) for this opportunity to comment on the proposed pasture guidance. We support NOSB addressing these concerns and appreciate the need for clarifying guidance on pasture, thus ensuring consistent application of the organic standards. We also thank the NOSB Chair and the National Organic Program (NOP) for agreeing to accept comments after May 20, giving them equal consideration.
OTA would first like to note that NOSB’s proposed rule changes from the February meeting are excellent. We fully support NOSB’s recommendation for a rule change clarifying that lactation is not a stage of production exempt from pasturing, and support the proposed rule change that specifies that ruminants shall be grazing on pasture during the growing season.
With regard to the proposed guidance from the NOSB Livestock Committee, OTA e
specially appreciates the recognition of the farm plan as the vehicle for constant improvement. This position is consistent with language in the preamble to the Final Rule, which describes the organic system plan or the farm plan as follows:
The organic system plan is the forum through which the producer or handler and certifying agent collaborate to define, on a site-specific basis, how to achieve and document compliance with the requirements of certification. The organic system plan commits the producer or handler to a sequence of practices and procedures resulting in an operation that complies with every applicable provision in the regulations. Accreditation qualifies the certifying agent to attest to whether an organic system plan comports with the organic standard. The organic system plan must be negotiated, enacted, and amended through an informed dialogue between certifying agent and producer or handler, and it must be responsive to the unique characteristics of each operation. (7 CFR Part 205, Preamble, Subpart C, Production and Handling, General.)
OTA recognizes the value of using the farm plan to document goals and methodologies toward organic compliance. OTA’s American Organic Standards (AOS) are based on the Organic Foods Production Act of 1990, recommendations of the NOSB, the Organic Trade Association’s Guidelines for the Organic Industry, and consider provisions from U.S. organic certification agency standards, state organic laws, and international documents, including those from International Federation of Organic Agriculture Movements (IFOAM), Codex Alimentarius Committee on Food Labeling, the European Union, the Canadian Organic Advisory Board, and the International Standards Organization.. The U.S. Department of Agriculture used AOS as one of its references in preparing the NOP Rule.
The AOS pasture requirements, are farm plan based, not prescriptive:
6.5. Feed Requirements.
6.5.3. Requirements for Pasture
6.5.3.1. Lands on which livestock are grazed or pastured shall be certified, and the Organic Plan shall contain management measures designed to maximize edible forage throughout the grazing season, establish appropriate stocking rates, and maintain or improve soil fertility and range land health, as approved by the certification agent.
OTA supports the sections of the NOSB’s Livestock Committee’s proposed pasture guidance which describe how the organic system plan shall define timelines and goals set by the certified entity and evaluated by the certifier as a means of verifying compliance with the regulations. A reader of such a plan would be easily able to see how an operation was implementing the regulation. Certifiers need this information in each operation’s farm plan to effectively evaluate the operation.
NRCS Conservation Practice Standard (CSP) 528 is valuable guidance for farmers and certifiers, as it includes factors that a farmer or certifier should consider in determining whether pasture has been appropriately addressed in the individual organic farm system plan. It provides an excellent example of how farmers can outline prescribed grazing in their farm plan. OTA approves of the approach of using CSP 528 as a guide. Based on OTA member research there is inadequate regional specificity developed by NRCS to mandate its use. The following could be amended thusly:
C) Appropriate Pasture Conditions
Appropriate pasture conditions shall could be determined in accordance with the regional Natural Resources Conservation Service Conservation Practice Standards for Prescribed Grazing, (Code 528) for the number of animals in the Organic Systems Plan.
OTA does not feel the NOSB proposal should be taken to the level of a rule change. Guidance, combined with the proposed Rule changes from the February meeting, will be adequate.
Thank you very much for your consideration.
