Friday, April 8, 2011

Stop the Corporate Takeover of Organics

This just in from the Weston A. Price Foundation:

Send Your Comments to the National Organic Standards Board


Dear Members,

The following urgent action alert comes via the Cornucopia Institute.  It is a long and detailed message but one that is very important. Please read carefully and take action.

Sally Fallon Morell,

The National Organic Standards Board (NOSB), which advises the Secretary of Agriculture on organic policy and rulemaking, is considering several changes to the USDAs organic standards that would water down organics, catering to corporate interests. 

We cannot allow corporate-backed members of the NOSB to chip away at the integrity of the label.  The following proposals are highly objectionable.  Please comment on them through ( ) (complete instructions below).

The proposal would allow any synthetic additive that qualifies as a nutrient to be added freely to organics, even those that have never been tested for safety by the FDA.  Currently, organic law requires all synthetic additives, including nutrients, to be individually petitioned, carefully reviewed and approved by the USDA before they can be added to organics.  

MESSAGE to the NOSB:  Reject the Handling Committees proposal regarding nutrient additives.  Nutrient additives must be individually petitioned, reviewed and approved as safe and appropriate for organics before they can be used, as the law currently requires.  

Already, some companies are illegally adding a synthetic form of DHA omega-3 (from algae) and ARA omega-6 (from soil fungus) oils to organic food, including organic infant formula.  These additives have been linked to serious gastrointestinal reactions in some babies and toddlers.

More information:  An action alert ( ) on this topic was sent out in late March.  If you already sent in your commentsThank You!  If you havent already commented, please do so today.  

Factory farms, with as many as 100,000 birds in a building, that do not have legally mandated access to the outdoors, would be shut down if new strict rules are put into place.  

The good news is that the NOSB Livestock Committee proposal would outlaw the tiny enclosed porches that industrial-scale producers had been illegally calling "the outdoors." 

But our struggle for meaningful animal welfare standards is not over!  The committee caved once again to industry pressureproposing outdoor space requiring just two square feet per layer and one square foot per broiler! In the European Union, organic standards require at least 43 square feet per bird outdoors and the US leading organic brand, Organic Valley, affords their birds 5 square feet outdoors.  

Two square feet and one square foot are simply not enough for birds to have meaningful outdoor space where they can exhibit their natural behaviors (like running around and "foraging").  

Furthermore, the proposal would grant 1.2 square feet indoors for laying hens and one square foot for meat birds, which is no better than the current industry standard for factory farms, and certainly inadequate for organics.  Many legitimate organic farmers currently provide 1.5 square feet of indoor space for their laying hens.

MESSAGE to the NOSB:  Please resist pressure by the industrial-scale producers to reduce the outdoor space requirements for chickens any further.  When I buy organic eggs and chicken, I expect that the birds were raised with ample access to real outdoor runs5 square feet should be the bare minimum!

More information:  Watch the video ( ) and read Cornucopias report, Scrambled Eggs ( ).  A complete action alert on the NOSBs proposal for organic poultry is also available.

The Livestock Committees proposed space requirements for growing pigs are so small, even standards set by the National Pork Boardwhich is controlled by industrial hog producersare more generous!  The proposed space requirements would make it impossible for growing pigs to turn around in their bedded indoor space, with even less space outdoors.

MESSAGE to NOSB:  The proposed space requirements for growing pigs are woefully inadequate.  If organic standards are going to be the gold standard in terms of animal welfare, growing pigs should be granted more space than what is currently proposed.

More information:  A complete action alert ( ) for organic hogs is available. 

The opposite is true for dairy cows.  The latest proposal for indoor space requirements is so overly generous that it could essentially put thousands of family-scale dairy producers out of the organic business.  

Many small-scale organic dairy farmers use stalls in their barns to position the cows and direct their manure away from their bedding.  The proposed space requirements would have cows lying in their own excrement.  Most family farm producers would have to build new barns to meet these space requirementsa capital investment that many could not afford, forcing them out of the organic business. 

MESSAGE to NOSB:  A previous recommendation, which had been accepted by the full NOSB, already requires stall barns to provide one full, traditional stall per animal.  Therefore, indoor space requirements for dairy producers with stall barns are unnecessary.  

More information:  A complete action alert ( ) fororganic dairy cows is available.

Please submit your comment electronically before the April 10 deadline.!submitComment;D=AMS-NOP-11-0014-0001

We strongly recommend submitting two separate commentsone for nutrient additives and one for animal welfare.  Also remember that a message in your own words carries more weight than cutting and pasting the sample letter, so please personalize your message, at least at the beginning and end if possible!  

And your message doesn't need to be long to be effective.

Tell your family and friends to submit their comments as well!

To speak in person at the NOSB meeting (important if you can make it): 
In addition to sending their written comments, organic farmers and consumers living in the Seattle area, or willing to travel, are encouraged to also sign up for a five-minute speaking slot at the meeting at the end of April.  Individuals can find more information about the meeting, and can pre-register for a slot byApril 10, 2011, by visiting or by calling (202) 720-3252.

Please email or call 715-514-2627 if you are planning on attending the Seattle meeting. 

Unregulated Synthetics/Animal Welfare

Dear Members of the National Organic Standards Board, 

Thank you for your efforts in setting animal welfare standards for organically raised farm animals.  I appreciate the clarification that organic laying hens and meat birds be required to have outdoor access beyond a tiny, lifeless enclosed porch.

However, I have some concerns about the proposed stocking rate chart. 

For chickens, the current proposal does not grant enough space.  Please require more outdoor space for chickens, since birds cannot run around freely in outdoor runs if they only have one or two square feet. Many producers already grant much more outdoor space, and 5 square feet should be the bare minimum in the organic standards.

Please resist pressure by the industrial-scale producers to reduce the outdoor space requirements for chickens any further.  When I buy organic eggs and chicken, I expect that the birds were raised with ample access to real outdoor runs.  And indoors, birds should have at least 1.5 square feet of space (1.2 square feet, the agribusiness standard for uncaged birds, is inadequate).

For growing pigs, the proposed stocking rate would not allow pigs to even turn around inside, and they would not all fit in their outdoor space.  The space requirements for growing pigs must be increased.

For dairy cows, the proposed indoor space requirements would make it impossible for thousands of family-scale organic dairy producers to comply.  Since a previous recommendation already requires one traditional stall per animal, indoor space requirements for dairy producers with stall barns are unnecessary.

Furthermore, I strongly object to the inclusion of any synthetic nutrient ingredient in organic food without the careful review by the NOSB, which is legally mandated.

Please do not water down the working definition of organic agriculture and food production! 

Sincerely yours,
Your name

Thursday, February 3, 2011

Help Preserve the Right to Raise Free Range Poultry

From the Weston A. Price Foundation:
Help Preserve the Right to Raise Free Range Poultry

After initially outlawing raising domestic Muscovy ducks, the Fish and Wildlife Service (FWS) still wants to regulate those that raise domestic Muscovy ducks as livestock, and to ban outright keeping domestic Muscovy ducks as pets.

Muscovy ducks have a long history of domestication dating back to the 1500s. This history of domestication is very similar to that of the turkey. Domestic Muscovy ducks are livestock and have been raised as livestock around the world for hundreds of years.

The public comment period for the most recently revised proposed regulations ended Dec. 31, 2010. The FWS has received numerous public comments insisting that domestic Muscovy ducks are livestock, and therefore not subject to regulation by the FWS. We have been informed that the FWS is considering revising the proposed rule again, but this time exempting domestic Muscovy ducks from any regulation.

Letters and e-mails to both Dr Allen at the FWS, and to your elected representatives will help assure that the FWS does exempt domestic Muscovy ducks.


Dr. George Allen at the Fish & Wildlife Service:

Your congressperson:

Your senator:


I am contacting you in regard to the proposed regulations by the Fish and Wildlife Service regarding Muscovy ducks (Docket No. FWS-R9-MB-2010-0037), urging you not to propose any additional restrictions on raising Muscovy ducks.

The Fish and Wildlife Service (FWS) has failed to recognize the long history of the domestic Muscovy as livestock. Domestic Muscovy ducks have been raised as livestock since the 1500s. As livestock they should not be subject to U S Fish and Wildlife regulations.

The U S Fish and Wildlife Service should recognize a distinction between wild Muscovy ducks and the domestic Muscovy ducks that have been raised as livestock all across the world for hundreds of years.

It is my understanding that the problems with feral Muscovy ducks that prompted these regulations are, for the most part, limited to Florida and possibly Chicago. Considering our country's current budget deficits, why would the FWS propose new regulations that have to be implemented and enforced all across the United States?

I see no problem with the portion of the rules (21.54 Control order for muscovy ducks in the United States) that allows localities to control feral populations of Muscovies that have become a problem. There does not appear to be any conflict between this control order and recognizing domestic Muscovies as livestock and exempting them from this regulation.
I strongly urge the FWS to limit their revision of 21.14 (Permit exceptions for captive-bred migratory waterfowl other than mallard ducks) to include only following:
1) Domestic Muscovy ducks have a long history of domestication and have long been raised as livestock both in the United States and around the world. Muscovy ducks that are owned as livestock (for the production of meat, eggs, or breeding stock), pets, or for exhibition shall be considered domestic Muscovy ducks.

2) No migratory bird permit(s) shall be required to possess, propagate, or sell (as live birds, meat, or eggs) domestic Muscovy ducks.

3) The intentional release of domestic Muscovy ducks to the wild shall be prohibited.

4) You may not take Muscovy ducks or their eggs from the wild , unless such taking is provided for elsewhere in this subchapter.

5) 21.54 Control order for muscovy ducks in the United States shall remain in effect without revision.

Do not place any additional restrictions on domestic Muscovy ducks!



Tuesday, December 7, 2010

Food Safety Bill Fight Continues


Last week, the Senate passed S510, the Food Safety Modernization Act, with the Tester-Hagan amendment.  Almost immediately, members of the House of Representatives raised objections that S510 includes provisions for user fees, which they argued were revenue raising provisions that violated the Constitutional requirement that all tax provisions originate in the House.

No one in the Senate apparently noticed this problem, yet unnamed House members supposedly spotted it within hours.  Other bills that have originated in the Senate have included user fees and passed without objection.  There may be Constitutional problems with the provisions, but it also may be a maneuver to stall the bill in order to make changes.

With the clock ticking on the lame duck session, the procedural objections might finally kill this bill.  But don't count on it!  The SAME day that the procedural objections were announced, Agribusiness lobby groups sent letters urging House members to conference S510 with HR 2749 (the House version), for the single specific purpose of stripping out the Tester-Hagan amendment.  Until the procedural objections were raised, the House leadership had pledged to bring S510 to a vote without conferencing the bills.  It's suspicious that the Agribusiness groups were prepared to immediately take advantage of the delay to try to remove the protections of the Tester-Hagan amendment.
To quote from Agribusiness: one letter was signed by produce industry groups, which represent the majority of fresh fruits and vegetables sold in the United States, while the second letter was sent by organizations that represent the vast majority of growers, producers, shippers, distributors, processors, packers, and wholesalers. In other words, these lobby groups represent the industrial food system that has been the source of the problems.  Yet they are working to convince House members to impose the same regulations on local farmers market producers as on their huge corporate operations.

To be clear, we dont think S.510 is a good bill even with the Tester-Hagan amendment.  It increases FDA's power, which will undoubtedly lead to even more battles between FDA and local food producers and consumers.  FDA has abused the powers it already has, and that will almost certainly continue, with or without this bill.  But as bad as the bill is now, it would be even worse without the amendment.

Agribusiness's real concern about the Tester-Hagan amendment isn't food safety, but the precedent set by having Congress recognize that small, direct-marketing producers are different, and should be regulated differently, from the large Agribusinesses.


Please CALL or EMAIL your Congressman!  You can call the Capitol Switchboard at (202) 224-3121 or go to  to find their website (if the phone lines are busy, the best way to reach them is through the Contact page on their website)

Message: My name is ____, and I am a constituent who is concerned that FDA will abuse its new authority under the food safety bill to hurt small farmers and local food producers.  IF the food safety bill passes, it's critical that it at least include the Tester-Hagan amendment to protect small-scale producers from the regulations for hazard analysis plans and growing and harvesting standards.  And whether this bill passes or not, I want my Congressman to take steps to rein in the FDA's abuses, through limiting appropriations and overseeing the agency's rulemaking.  I would like to talk with you more about this, please call me back at ________.


The structure and language of the Tester-Hagan amendment is complex because every piece of this amendment was fiercely fought by the opponents.  To be understood, the amendment needs to be read in the context of S510 and the existing background law, including the 2002 Bioterrorism Act 

Here are some of the key provisions of the amendment:

*  For farmers selling fresh fruits and vegetables: if the producer grosses under half a million dollars, adjusted for inflation, and sells at least half of their produce directly to qualified end users (see below), then the farmer is exempt from the produce safety standards (i.e. regulations in which FDA would tell farmers how to grow and harvest their crops).  See pages 16-19 of the amendment.  Note that the FDA has already started working on these growing and harvesting standards, and claims that the existing law -- without S510 or Tester-Hagan -- gives it authority to impose the standards on ALL farmers.

* For farmers and producers who sell processed or value-added foods: if they sell more than half of their products directly to individual consumers, they do not have to register with the FDA nor develop a hazard analysis plan.  This is due to the provision entitled clarification of intent that directs FDA how to define retail food establishments, see pages 1-2 of the amendment.

* For farmers and producers who sell processed or value-added foods, but do not sell more than half of their products directly to individual consumers: they are ALREADY under a legal requirement to register with the FDA due to the 2002 Bioterrorism Act.  The Tester-Hagan amendment provides that these producers can avoid having to comply with S510s extensive requirements for hazard analysis plans by:

1)  Submitting documentation that they gross under half a million dollars, adjusted for inflation, and sell more than half their products directly to qualified end users (see below), and

2)  EITHER providing documentation that they comply with state and local laws  such as a copy of their commercial kitchen license  OR preparing a simplified hazard plan.  See pages 5-6 (the or is found on line 4 of page 6)

* Qualified end users are (a) individual consumers, WITHOUT any restriction on their location or proximity to the producer, and (b) restaurants and retail food establishments that are either in-state OR within 275 miles.  The farmers and producers will NOT have to ask individual consumers where they come from.  See pages 7-8 & 18.

* The $500,000 limit on the exemptions is adjusted for inflation.  See page 5, lines 13-14, and page 16, line 12

* The amendment also directs FDA to conduct a study that would, for the first time, look at the issues of scale and type of processes in relation to foodborne illness. The directive to do a study is the first attempt to get data to show that smaller-scale producers who don't commingle their products and who do less processing and transportation produce safer food.  The bill does NOT mandate that any individual person hand over the information to the government.  The FDA is also directed to use the results of the study to define very small businesses that will also be exempt from the hazard analysis plan requirements.  

You can read the Tester-Hagan amendment for yourself at