April 3, 2012
Toni Strother, Agricultural Marketing Specialist
National Organic Program, USDA–AMS–NOP
Room 2646–So., Ag Stop 0268
1400 Independence Ave., S.W.
Washington, DC 20250–0268
RE: National Organic Program: Proposed Amendment to the National List of Allowed and Prohibited Substances (Livestock) – Methionine - Docket # AMS-NOP–11-0063; NOP-11-11PR
Dear Ms. Strother:
Thank you for the opportunity to comment on the proposed rule to continue the exemption for synthetic methionine. This proposed rule would revise the current annotation on methionine to reduce the levels currently allowed in organic poultry production after Oct. 1, 2012. The proposed rule permits the use of synthetic methionine at the following maximum levels per ton of feed after Oct. 1, 2012: laying and broiler chickens—2 pounds; turkeys and all other poultry—3 pounds. This action also proposes to correct the Chemical Abstract Service (CAS) numbers for the currently allowable forms of synthetic methionine, and seeks comments on these changes.
The Organic Trade Association (OTA) is the membership-based business association for organic agriculture and products in North America. Its members include growers, shippers, processors, certifiers, farmers’ associations, distributors, importers, exporters, consultants, retailers and others. OTA’s Board of Directors is democratically elected by its members, and its mission is to promote and protect the growth of organic trade to benefit the environment, farmers, the public and the economy (http://www.ota.com/
). OTA represents hundreds of certified operations that will be impacted by this proposed rule.
OTA supports a final rule that will extend the allowance of methionine in the diets of organic poultry until natural alternatives are commercially available. While we are concerned that the step-down levels recommended by the National Organic Standards Board (NOSB) are not based on the science of poultry nutrition and will not meet the nutritional requirements of organic poultry at all stages of life, we agree that it is necessary to move this proposed rule forward to final in order to prevent any gap in the allowance of synthetic methionine due to the current expiration date of Oct. 1, 2012.
We acknowledge, as NOP has done in the proposed rule, the new petition submitted by the Methionine Task Force (MTF) for revised maximum allowable levels of synthetic methionine. To the best of our understanding, the step-down rates included in the new petition are more appropriate because they express the maximum average pounds per ton of methionine needed over the life of the bird which will allow for feed rations to be adjusted according to the naturally changing demands of the bird.
OTA strongly supports research and efforts to actively reduce the use of synthetic methionine. However, given the lack of commercially sufficient sources of allowable natural alternatives and the significant impact the premature loss of synthetic methionine would have on organic poultry welfare and production, a final rule extending its allowance is needed. We strongly urge NOP to move this proposed rule to final, and we urge NOSB to take up the new petition presented by the MTF as soon as possible.
Again, on behalf of our members across the supply chain and the country, OTA thanks NOP for the opportunity to comment and for carefully considering our comments.
Associate Director of Organic Standards and Industry Outreach
Organic Trade Association
cc: Laura Batcha
Executive Vice President,
Organic Trade Association