COMMENT
of the Organic Trade Association
on the
National Organic Standards Board draft:
“Access to Pasture”
July 31, 2001
Submitted by
Tom Hutcheson, Policy Coordinator
Organic Trade Association
P.O. Box 547, Greenfield, MA 01302
The Organic Trade Association proposes the following revisions to the National Organic Standards Board (NOSB) Livestock Committee recommended standard for access to pasture for ruminants:
1. Remove the section on intent.
2. Remove the section on benefits.
3. Reword number one of the next section (numbers two and three are the same as the original NOSB recommendation) to read:
ACCESS TO PASTURE FOR RUMINANTS:
1. Ruminant livestock must have access to graze pasture during the months of the year when pasture can provide edible forage, and the grazed feed must provide a significant portion of the total feed requirements. The Organic Farm Systems Management Plan must illustrate how the producer will
manage the pasture component of the farm in order to provide feed value and maintain or improve soil, water, and vegetative resources. Natural variation in climate, topography, precipitation, vegetation, and breed selection may mean organic system plans may vary widely.
2. The producer of ruminant livestock may be allowed temporary exemption to pasture because of:
a. Conditions under which the health, safety, or well-being of the animal could be jeopardized.
b. Inclement weather
c. Temporary conditions which pose a risk to soil and water quality.
3. The producer of bovine livestock may be allowed exemption to pasture during the following stages of production: [Note: recommendations for other ruminant livestock are being developed]
a. Dairy stock under the age of 6 months
b. Beef animals during final stage of finishing for no more than 120 days
The rationale for these changes was to make the recommendation/standard more consistent with the rule by requiring compliance with the rule’s definition of pasture and to insert the concept of regional variation.
4. Remove the section on implementation.
5. Remove the section on final rule references.
Rationale: OTA feels that the sections entitled “Intent”, “Benefits”, “Implementation Issues”, and “Final Rule References” are extraneous and do not belong with the standards.
