This USDA issue paper, along with two others, were published in the Federal Register October 28, 1998 and are found on the USDA National Organic Program Web site at http://www.ams.usda.gov/nop/. The deadline for submission of public comment is December 14, 1998.

The Henry A. Wallace Institute for Alternative Agriculture appreciates this opportunity to evaluate options for implementation of the Organic Food Production Act (OFPA). We support the Department's goal of clear, consistent regulations that stimulate the growth of organic markets, satisfy consumer expectations, and allow organic producers flexibility in making site-specific, real-time management decisions. Our response to the options presented in Issue Paper 1 is consistent with, and an expansion upon, the comments on the Proposed Rules for the National Organic Program we submitted on April 30, 1998.

Resolving the confinement issue is an essential step towards the development and implementation of credible organic livestock production standards. At its heart, organic agriculture represents an integrated and interrelated group of management practices which run contrary to the concentration which characterizes much of conventional agriculture. By carefully balancing the needs of animals with the resources they provide, organic livestock management can contribute to a diversified and profitable farm. By contrast, the proliferation of conventional intensive livestock confinement systems has created a host of environmental, economic and animal welfare problems. Inappropriate waste disposal practices, financial domination by vertically integrated corporations and breeding practices driven by volume of production, not vigor of the animal, are undermining conventional livestock production. Recognizing how intensive livestock production has impacted animals, the environment, farming communities, and human health, consumers are demanding alternatives. Organic production standards which responsibly and humanely address the issues of space and mobility will reward farmers for reintroducing animals into their management systems in ways which support environmental and economic sustainability.

Standards pertaining to confinement and mobility will help to integrate livestock production into an operation's nutrient management strategy. Not every producer will maintain livestock, but those that do should balance the needs of their animals with the other components of their operation. The requirement that animals have access to an outdoor environment appropriate to their species moves the production paradigm away from concentration and high yield towards integration with available resources and environmental conditions. Confinement standards will require operations to identify and sustain linkages between the number and variety of animals they raise and available land resources. In developing a farm plan for livestock operations, organic producers will think in terms of what type and how many animals their land will support, not withstand.

The Wallace Institute believes that none of the four policy options outlined in the Confinement Issue Paper provide an adequate expression of the fundamental space and mobility requirements for organically raised livestock. The USDA should strengthen its position by requiring that certified operations provide access to the outdoors for all animals under conditions appropriate to each species. While requirements can include justifiable conditions for exceptions, the organic standards should acknowledge that restrictions on access to the outdoors can only be temporary. By mandating access to the outdoors for all animals and establishing species-specific conditions for compliance, the USDA can facilitate conversion to organic systems, satisfy consumers' expectations and position organic producers to compete in international markets.

Note: Standards for the certification of aquaculture production are receiving increased attention within the organic community, and are usually considered in the context of livestock operations. While the Wallace Institute supports the development of aquaculture standards and believes that they should be viewed as livestock operations, our comments on Issue Paper 1 are limited to the consideration of land-based animal production. Standards pertaining to confinement in aquatic systems are too rudimentary and untested to be evaluated side by side with those for land-based operations. By contrast, extensive experience with certification of land-based systems, primary for the production of ruminants and poultry, provides sufficient precedent from which to derive comprehensive national standards. Issues related to confinement, mobility, and stocking rates in aquaculture operations need to be more thoroughly assessed in the production setting before they can be translated into meaningful standards.

Recommendations

1. The Wallace Institute strongly recommends that certified livestock operations be required to provide access to the outdoors to all animals under conditions appropriate to their species. The term "access to the outdoors" should be interpreted as the ability of an animal to move freely from its enclosure into an open air environment with suitable ground cover. The simulation of a natural environment is a cornerstone provision in organic livestock production systems. An environment which allows animals to engage in feeding, resting, and grooming behavior compatible with their inherent preferences is best suited to minimize stress and promote vigor. Because the satisfactory amount and condition of the outdoor environment is dependent on the type of livestock, the Secretary should implement specific standards for individual species. Requiring that organic livestock producers provide access to an outdoor environment suitable to the needs of specific species will help balance the animal and land resources of certified operations. A clear commitment to outdoor access will also conform with the expectations of organic consumers as reflected in the overwhelming support for such access voiced in the first round of comments on the Proposed Rules of the National Organic Program.
   
   
2. The Wallace Institute recommends that temporary denial of access to the outdoors to organically raised livestock may be justifiable due to inclement weather, the health, safety and well being of the animal, and protection of soil and water quality. Under certain conditions, organic livestock producers need the discretion to prohibit temporarily the access of the animals under their care to the outdoors. Justifiable conditions for restriction include protecting animals from the elements, providing health care treatment, or preventing excessive damage to soil and water resources. The length of the indoor confinement is not as important as the requirement that producers keep the period as brief as possible. For example, severe weather may necessitate extended intervals of restriction as long as the producer provides free access to the outdoors when conditions permit. Justification for restricting access to the outdoors should be carefully detailed in the operation's approved farm plan and reflect the well recognized factors—such as climate and animal life cycles—most likely to impinge on unrestricted access.
   
   
3. The Wallace Institute recommends that certified livestock operations be required to provide ruminants access to managed pasture. The term "managed pasture" should be interpreted as a distinct, organically certified field which is maintained to produce animal forage. Organically raised ruminants should receive a significant portion of their nutritional requirements from managed pasture. Pasture based rotational grazing systems provide substantial animal welfare as well as soil and water conservation benefits. Additionally, requiring pasture grazing for ruminant production will help to correlate the of size an operation with its impact upon the local environment. Operations which use their land resources to provide a substantial portion of their feed requirement (as well as to accept the attendant manure) will be able to maintain larger herds than those that do not. We are aware that certain private certification standards currently do not require access to pasture, but we believe that adopting this provision in national standards will best protect and promote the integrity of organic production.
   
   
4. The Wallace Institute recommends a prohibition on the use of cages for the confinement of organically raised poultry. To constitute a clear alternative to conventional production systems, organic standards must prohibit those practices most closely associated with factory farming. Many currently certified poultry operations have proven that organic production is possible without the use of cages. Caging poultry is incompatible with organic approaches to animal welfare and health maintenance, and is inconsistent with consumer expectations. In addition to the prohibition on confining birds in cages, certified poultry production operations need to comply with the access to the outdoor requirement contained in recommendation 1. Our preference is that poultry producers provide managed pasture for the animals they raise, but we do not recommend requiring it. Pasture raised poultry is an excellent production option for some producers, but others may prefer to use alternative systems which provide their animals equally satisfactory access to suitable outdoor conditions.
   
   
5. The Wallace Institute recommends that the Secretary provide accelerated review to standards for access to the outdoors in swine production operations. State and private certifying agents have long maintained confinement standards for dairy animals and poultry because producers could make an organic claim on certified milk products and eggs. However, because the Food Safety and Inspection Service has prohibited using the term organic on meat labels, analogous standards for livestock raised solely for their meat have not appeared. The recent increase in consumer demand for pork products has created a potentially lucrative market for which current certification standards provide little guidance. At the same time, many pork producers are adopting new production systems such as hoop houses, pasture farrowing and rotational grazing which may be compatible with organic principles. The Secretary should facilitate implementation of confinement standards for pork production to enable certified producers to enter this market expeditiously. We strongly believe that a grass-based system such as managed pasture is the most suitable environment in which to raise organic swine.
   
   
6. The Wallace Institute recommends that the Secretary work with the NOSB and a Technical Advisory Panel representing the organic livestock production community to develop species-specific confinement standards. The development of confinement standards suitable for individual species will require a significant investment of resources. However, intense consumer interest in livestock produced through alternative production practices should make such standards a high priority for the NOP. The Secretary should rely upon the NOSB as his principal adviser for establishing confinement standards. In addition, the Secretary should devote resources to recruiting a qualified Technical Advisory Panel drawn from experienced producers and certifying agents to provide an authoritative analysis of existing standards and potential improvements.

DISCUSSION

Recommendations of the National Organic Standards Board

The NOSB has outlined a position on animal confinement which provides a constructive framework for developing more comprehensive standards. The Board grounded its work in the belief that livestock production environments which replicate natural conditions are best suited to minimize stress and promote health. In 1994, the NOSB recommended that certified operations provide "access to shade, shelter, fresh air, and daylight suitable to the species, the stage of production, the climate, and the environment." The Board also proposed that design of animal housing must accommodate "the natural maintenance, comfort behaviors, and the opportunity to exercise" required by specific species. These recommendations established guidelines for strict but achievable confinement standards capable of reflecting differences among species, their stage of development, and variation in climatic and environmental conditions. The Board coupled species-specific welfare requirements with considerable leeway for producers and certifying agents to flesh out actual site-specific conditions in an approved farm plan. This approach was designed to insure protective baseline standards for livestock living conditions while affording producers flexibility to meet those requirements.

In 1995, the NOSB strengthened its recommendation on organic livestock living standards by specifying the conditions under which temporary restriction to indoor housing may be justified. These conditions are limited to inclement weather, the health care, safety and well being of the livestock and protection of soil and water quality. At its 1998 Ontario meeting, the NOSB reaffirmed its earlier positions on confinement and recommended that no exceptions be allowed for large livestock concentrations. While the Board did not further define large livestock concentrations, it recognized that, by contrast, organic operations must address the natural space and mobility needs of the animals they raise. The work of the NOSB has balanced the interests of animal welfare, variation between species, producer discretion, and environmental variables to create a workable, enforceable, and understandable definition of organic livestock management. To develop a credible confinement standard, the USDA should adopt the recommendation that exceptions to space and mobility requirements can only be temporary and must be based on the conditions outlined by the NOSB.

Current Organic Livestock Production Practices

The Food Safety and Inspection Service's prohibition on labeling meat or meat products as organic has hampered the development of certification standards for the production of livestock. Currently, fluid milk, related products including yogurt and cheese, and eggs are the only food commodities derived from animals which can be labeled as organically produced. In response to these opportunities, state and private certifying agents have developed a variety of standards for the certification of dairy and poultry layer operations. There has been little agreement, however, on what constitutes an appropriate standard for confinement. For example, different standards for poultry certification in the United States currently vary from caged birds, to free-roaming, to a requirement for outdoor access. Similarly, the standards for certification of dairy herds allows for everything from pasture based rotational grazing to dry lot operations.

The absence of industry consensus on appropriate livestock standards, and the confusion it creates when consumers discover the wide array of conditions currently allowable under different standards, makes the development of a clear and communicable NOP policy especially important. Concerned organic consumers used the first round of comment on the Proposed Rules of the National Organic Program to express their strong support for a policy on confinement which clearly requires access to the outdoors. An analysis conducted by the group Organic Watch of 201,794 comments posted on the NOP website identified 57,911 (28.70% of the total) responses which favored a stronger requirement for access to the outdoors for livestock.

Potential Benefits of Organic Production Systems

Just as organic production represents a systems approach (responsiveness to natural cycles, strength through diversity), intensive confinement production is also predicated on interrelated components. However, with the confinement approach, fixation on a single component—yield—causes other variables in the system to be compromised. Breeding animals for high feed conversion rates and rapid weight gain means sacrificing properties such as natural immunity to disease. Forcing vast numbers of animals to live in cramped quarters contaminated with their own waste insures that synthetic medications will become required treatment. Mandating access to the outdoors is a solid first step towards resolving many of the animal health problems which plague intensive confinement operations. By establishing a relationship between an operation's available land resources and the number of animals it can raise, the requirement for access to an outdoor environment appropriate to each species provides a foundation for successful nutrient management. Certified livestock operations will balance their land and animal resources to provide feed (in cases of managed pasture) as well as dispose of manure. Access to the outdoors can also be an integral factor in other production considerations including disease suppression and the reduction of aggressive behavior.

Recent research supports the understanding that organic livestock production practices are linked to with reduced animal stress, strengthened immunity and reduced pest infestation. Data recently published in Science identified a strong positive correlation between the percentage of grain fed to cows and the concentration of E. coli in their rumens. The authors concluded that a hay or pasture based diet could be significantly less likely to support E. coli populations, including potentially pathogenic strains, than the high corn diets fed to confinement animals. Additionally, confinement poultry operations are experiencing well documented disease and parasite resistance problems with the increasingly narrow genetic base found in the most commonly used breeds. Because organic producers have to consider multiple variables when selecting breeds, they will generally employ and preserve a much broader amount of genetic diversity. The Wallace Institute believes that research in genetic diversity is a top priority for determining how organic operations can overcome the production problems plaguing conventional production.

Conclusion

To deliver livestock standards which producers, certifiers, and consumers can embrace and support, the Secretary should establish a firm requirement that all organically raised animals enjoy access to the outdoors under conditions suitable to their species. With standards for ruminants, the requirement should entail access to a managed pasture under organic management which provides a significant portion of the animals' nutritional requirements. In conjunction with the NOSB and a Technical Advisory Panel of industry experts, the Secretary should develop and implement species-specific conditions to satisfy the outdoor access requirement. The Final Rules of the National Organic Program should acknowledge that temporary restrictions on access tot he outdoors for organically raised livestock are allowable only for reasons of inclement weather, the safety and welfare of the animals, or the protection of soil and water resources.

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