WASHINGTON- The National Organic Program’s proposed rule to enhance bird health, food safety and the maintenance of a viable organic program, announced in April, has prompted the NCC to ask for revisions of the rule or the clarification of several key aspects of the rule.
"NCC is concerned that the proposed rule imposes unreasonable costs and requirements of doubtful benefit on organic farmers, presents grave risks to animal health… and undermines ongoing international efforts to develop poultry welfare standards," according to Ashley Peterson, Ph.D., NCC senior vice president of scientific and regulatory affairs, in comments submitted July 13 to the U.S. Dept. of Agriculture.
NCC believes the standards of the proposal will increase mortality rates, a key indicator of animal welfare and flock health, for laying hens and broilers by 60 percent, thereby significantly decreasing bird welfare and economic viability for farmers.
Under the current proposal, a “documented occurrence of a disease in the region or relevant migratory pathway must be present before outdoor access can be restricted." NCC suggests the definition of what constitutes a region or documented occurrence is unclear under the proposed rule and inhibits farmers’ ability to take preventive measures to protect their flocks in a timely fashion. This is vital to farmers in light of the recent outbreak of highly pathogenic avian influenza (HPAI) and also opposes recommendations for biosecurity by the Animal and Plant Health Inspection Service (APHIS).
“NOP does not include the cost of an avian illness outbreak, the likelihood and magnitude of which is materially increased through the proposed outdoor access requirement,” Peterson added, meaning that outbreaks like the one in 2015 will be more likely and probably more severe under the proposal. Peterson also noted the proposal underestimates, or doesn’t estimate at all, the cost of the proposed rule’s requirements and the impact of those costs. The anticipated benefit of $62.6 million in the proposed rule is far less than the estimated economic consequence of approximately $3.3 billion of the HPAI outbreak in 2015.
Salisbury, Maryland-based Perdue Farms had a more positive take on a different aspect of NOP’s proposed rule. The company supported NOP’s proposal to provide broiler chickens more space inside chicken houses along with increased pasture space and ready access to the outdoors, as well as the proposed rule’s requirement for husbandry practices that promote natural chicken behaviors.
“Consumers view USDA Certified Organic as the gold standard in agricultural production, and that includes animal welfare,” said Randy Day, chief operating officer, Perdue Farms in a statement. “As the leading producer of organic chicken, we fully endorsed the National Organic Program’s desire to strengthen what it means when products carry the Organic seal.
“Specific requirements for space and indoor air quality, outdoor access and enrichments that promote natural behaviors will further differentiate organic chicken from conventional production in a meaningful way, and we welcome the adoption of uniform and verifiable standards.”
Perdue submitted a letter of support to the federal register in response to a USDA request for public comment on the proposed rule. The letter also contained a request for an extension of the implementation deadline for the extra space from one year to three years to ensure availability of organic chicken to consumers while producers expand their farms.
The proposed rule can be found here.
Full NCC comments on the proposed rule can be found here.