Final Pasture Rule Recommendations
Posted December 23, 2008
Final recommendations and detailed commentary on the pasture rule from Food Farmers.
By Ed Maltby, NODPA Executive Director
Updated November 30, 2008. The National Organic Program (NOP) published the proposed changes to the Access to Pasture Rule on October 24th which contains many of the recommendations that NODPA and FOOD Farmers have made over the years.
Richard Mathews and Barbara Robinson of the NOP are to be congratulated on their work shepherding the Proposed Rule through the federal system. They have written a rule with the specificity producers and USDA lawyers asked for and in preparing our comments and suggestions we have viewed the proposed rule within the context of ensuring that we close as many loopholes as possible; provide enough specific, legal language that it won’t be necessary to fight court battles for every non-compliance; and that has enough unambiguous language that certifiers who do not have the experience and training to inspect livestock operations are able to rely on the rule and any guidance documents.
NODPA, FOOD Farmers and the National Organic Coalition are working with certifiers and many other groups to assess the new rule and below is the recommendations from that working group under the umbrella of FOOD Farmers..
Please take the time to read the rule and our recommendations carefully and talk it over with others so we can have a measured and constructive response in comments to the NOP.
We should all congratulate ourselves for working together to push this through a system that is not used to being asked to create tighter rules, and views rulemaking as a rare event.
Sit back, read and relax and let the smell of good pasture flow into your veins.
The NOP will be accepting comments on the rule until December 23, 2008. We strongly encourage producers to provide comments, and feedback about the rule to the NOP.
When you submit comments please start by giving your name, farm name (if appropriate), location and the size of your milking herd. Please start by thanking the NOP for publishing the proposed rule that contains the specific recommendations advocated by NODPA and FOOD Farmers on access to pasture. The NOP is looking for documentation on how the proposed rule will affect individual operations so please include in your comments how your farm operations will be affected by the proposed rule, whether you support the changes recommended by NODPA and FOOD Farmers and why you support the recommendations. Wherever possible, back up your comments with examples from your own operation or from research by agencies, universities or other independent organizations. You may include relevant articles as well.
There are three ways to submit comments:
1) Mail written comments to the NOP. Written comments must be received (not postmarked) by Dec. 23, 2008. They must be identified with, “Docket Number AMS–TM–06–0198; TM–05–14”. Mail written comments to:
Richard H. Mathews, Chief, Standards Development and Review Branch,
National Organic Program, Transportation and Marketing Programs
USDA–AMS–TMP–NOP, 1400 Independence Ave., SW.
Room 4008– So., Ag Stop 0268
Washington, DC 20250.
2) Submit comments online. Visit the Regulations web portal: www.regulations.gov. Use the search terms “organic pasture.” Comments must be submitted online by Dec. 23, 2008. Do not leave it to the last moment to submit comments to the .gov site as it tends to get overloaded at the end of comment periods.
3) Send to NODPA. Mail, fax or email your comments to Ed Maltby by 12/19/08 and he will forward them to the NOP. By mail: Ed Maltby, NODPA Executive Director, 30 Keets Rd, Deerfield, MA 01342. Fax: 866-554-9483. Email: email@example.com
Letter to Producers (December 1, 2008)
In this letter, in PDF format, we summarize our recommendations and provide information on how you can contribute your own suggestions and recommendations.
Access to Pasture Rule Recommendations from NODPA
and Food Farmers (November 28, 2008)
In this abbreviated version of the rule, we mark up further recommended changes in language. Click here for the PDF version.
The Pasture Rule (in PDF format)
Includes summary, background information and more.
Want to compare and contrast the existing rule with the proposed rule on Access to Pasture? Click here for the PDF.
Presentation by Richard Mathews, USDA NOP Chief Standards Development & Review Branch, at the first official listening session on Tuesday, October 28th 2008. Click here for the PDF.
NODPA Press Release: Access to Pasture Rule for Organic Livestock supported by organic dairy farmers. Click here to open the PDF.
National Organic Coalition Gives Pasture Rule a Thumbs Up
Click here for a PDF of the release.
The pasture rule - What happens next?
Click here for details.
FOOD Farmers pasture measurement committee report 8.14.07
Click here for the PDF.