Small-Ag activists and organic watchdog groups found themselves in terra incognita recently: cheering the USDA for tightening the definitions of organic meat and dairy. On February 12th, the agency published "Access to Pasture," a "final rule and request for comments" regarding organic standards for livestock. It's been called the most sweeping rewrite of federal organic standards since their inception in 2002.
The rule closes several loopholes that mega-dairies have used to exploit the organic market with milk from farms that hardly resemble the farms that inspired the now $24.6 billion organic industry.
"Access to Pasture" mandates that meat and dairy cattle branded organic must graze for a minimum of 120 days on pasture. At least 30 percent of the animals' total annual caloric intake must come from grazing.
While definitive with regard to dairy, the rule leaves one significant question open with regard to meat production: whether beef cows should be exempt from the above grazing requirements during a four-month fattening, or "finish feeding," period, after which they are slaughtered. A 60-day comment period closes April 19th.
The new rule is a major blow to certain mega-dairies that for years took advantage of the previous rule requiring only that organic cows have "access to pasture." The real-life manifestation of this famously ambiguous phrase was often a warehouse door opening to a muddy side yard.
Clarifying "access to pasture" has been under discussion between the National Organic Program and the USDA since 1994, and a rule similar to the new rule was first proposed in 2005. It languished in Bush's USDA for a variety of reasons, some of which are currently under investigation. When the draft was opened for public comment, 80,327 were lodged, of which a large majority — all but 28 — favored clarifying the phrase access to pasture.
In addition to clarifying pasturing requirements for cattle, "Access to Pasture" tightens up several other cracks in the federal definition of organic. It expands and strengthens the language prohibiting antibiotics in organic feed, requires that any edible bedding (like straw and corn cobs) be certified organic, and mandates that pasture be managed as a crop — that is, to produce abundant forage.
Much of the new 160-page rule consists of comments, which are parsed and organized into arguments for or against the rule's measures. Of the 26,970 public comments the USDA received, 26,000 supported more pasture time for organic cattle. All but 130 of the comments arrived via three modified form letters.
Many Small-Ag types were skeptical of Obama's appointment of former Iowa governor Tom Vilsack as secretary of agriculture. Vilsack's cozy relationship with corporate agribusiness earned him "Governor of the Year" kudos from the Biotechnology Industry Organization.
One of Secretary Vilsack's first moves was to rip up the plaza in front of the USDA building in Washington and install a certified organic garden. He then recommended that all USDA facilities around the country do the same. Then Vilsack appointed Kathleen Merrigan as deputy administrator, the USDA's number-two spot. She's credited with writing the Organic Foods Production Act of 1990, in which Congress gave the USDA authority to oversee the organic industry.
While organic cheerleaders appear to have much to celebrate, some unfinished business will soon tell us more about which direction the USDA is really headed and how much the public's hands are guiding it.
Public comment just ended on the USDA's December 2009 determination that Monsanto's genetically engineered (GE) alfalfa seed meets USDA standards. The determination came despite the agency's acknowledgment that the GE alfalfa is likely to cross-contaminate with non-GE alfalfa.
Not one comment in a brief online survey of the registered comments favored approving this contagious alfalfa for planting. If the pattern holds, the response to these comments could create a showdown between Vilsack's biotech interests and the newly comment-friendly agency he leads.
Another looming question is what will replace the National Animal Identification System (NAIS) proposal, which was recently scrapped in another victory for Small Ag. NAIS would have forced all livestock farmers to keep painstaking and expensive records of their animals.
And finally, the burning item of business that "Access to Pasture" leaves unresolved for another 60 days: "We are requesting comments on the exceptions for finish feeding of ruminant slaughter stock."
As it stands, the USDA exempts beef cattle from the requirement that 30 percent of nutrition come from forage for a period of 120 days prior to slaughter. In practice this exemption allows organic beef cattle to be confined and fed grain for four months prior to slaughter, a practice known as feedlot finishing.
"Access to Pasture" notes, "The sentiment among most of the commenters is that there is no place in organic agriculture for the confinement feeding of animals nor should there be any exception for ruminant slaughter stock."
If that sentiment holds, the organic feedlot exception should end. But if the exception is upheld and "organic" beef is allowed to be "finished" in confinement, that would not only cast doubt on what appears to be a newly inclusive and democratic USDA, it would arguably violate several key aspects of organic livestock production. Confined feeding goes against the organic tenet that animals be allowed to express their true nature, and feeding grain to animals not only produces a different kind of meat that's much less healthy, it's also much more energy-intensive and environmentally destructive.
Perhaps the real discussion shouldn't even be about whether organic beef cows can be confined and grain-fed for the last 120 days of their lives. The discussion should be about whether organic cattle should be fed any grain at all.