October 4, 2010
Dear Director Boggs, Dr. Forshey, Livestock Care Standards Board, and Technical Research Advisory Committee members,
Thank you for the opportunity to submit comments on behalf of the Ohio Ecological Food and Farm Association (OEFFA) for your consideration.
Our comments largely pertain to the draft veal standards document and the draft handling of disabled and distressed livestock document discussed by the Technical Research Advisory Committee (TRAC) on September 28. As these standards are still in early draft form, our comments at this point focus principally on big picture issues, not specific line-by-line language. We urge you to consider and act on the following:
Standard Operating Procedures (901:12-3-04 Veal Standards, 901:12-2-04 Disabled and Distressed Livestock Standards) and Emergency Action Plans (901:12-3-08 Veal Standards, 901:12-2-08 Disabled and Distressed Livestock Standards)
We do not support a requirement that all livestock producers, regardless of scale, produce written Standard Operating Procedures (SOPs) and Emergency Action Plans. Although this may be appropriate, and in fact desirable, for larger commercial facilities that have multiple employees, this requirement would be impractical and burdensome for small-scale producers. Moreover, requiring this documentation is relatively meaningless unless there is a review and approval of these plans, which would be impractical for the ODA given the number of livestock farms in Ohio (unless the board decides to target only larger operations).
Additionally, 901:12-3-04 A1c calls for each farm to have a “training program that addresses animal welfare, signs of disease, routine and special care and handling, and euthanasia.” Again, requiring every livestock producer in the state, regardless of size, to offer a training program, regardless of whether they have employees, is impractical and burdensome.
Instead, the OLCSB should recommend that livestock producers have written SOPs and Emergency Actions Plans, as well as recommend training for farmers and hired personnel if they are not able to meet established standards.
Caretaker Training (901:12-3-04 Veal Standards, 901:12-2-04 Disabled and Distressed Livestock Standards)
We do not support required trainings for all livestock caretakers and transport personnel. By mandating training, these standards would assume farmers do not have these skills and create a potentially costly and time consuming process to train the thousands of livestock farmers in Ohio. The OLCSB will be establishing standards and allowable practices that must be met; it is up to the farmer to comply with those standards. The farmer can determine, after review of the standards and practices, whether they require training in order to be in compliance with the standards or whether they already have the skills to comply. If a farmer can comply with the standards competently, it should not matter whether they have attended a training.
Furthermore, it is unclear what is meant by “training.” Would completing a short online course or reading a fact sheet be considered training? What about learning from your father, an experienced neighbor, or through real-life experience? Would trainings be state-administered or would industry offer trainings? Requiring farmers to attend industry-led trainings is concerning, given the bias these trainings could have toward certain production practices, and farmers should not be required to participate in a certain industry group, if they choose not to.
Instead, the OLCSB should recommend training for farmers and hired personnel if they are not able to meet established standards.
Veal Definition (901:12-3-02)—As currently written, the definition of veal is unclear, and could apply to both calves raised for veal and calves raised for beef. The definition should be clarified, so that beef producers are not subject to two sets of standards.
Disabled and Distressed Livestock Standards
Generally speaking, what appears absent in this document is an emphasis on prevention. There is currently no language in the document about responsibility of a livestock caretaker to understand why there are disabled and/or distressed animals on the farm, so that future problems can be minimized or avoided entirely.
Health (901:12-2-05)—Section 3 indicates that if an animal becomes non-ambulatory disabled, a veterinarian must be consulted. While this may well be an appropriate course of action, veterinary assistance should not be required. The farmer should also have the option of on-farm slaughter or euthanasia.
Subcommittees and Academic Research
As other subcommittees have begun to meet, we would also like to address the request from Dr. Forshey that subcommittee members provide peer-reviewed scientific articles to justify their production practices. Although we understand the rationale behind this request and recognize the merit of animal care standards based on science, we would like to draw your attention to the bias in the scientific research that is available. There simply is not the volume of scientific research on small-scale, diversified, and organic production systems that there is for industrial livestock production. Simply because research is not available, does not mean that small-scale, pasture-based, and diversified production systems lack merit.
Moreover, the role of the subcommittee members is to represent their production model and offer comment on the workability of any regulations, not to produce scientific evidence. In our mind, this is the important role that the TRAC can play in helping to inform the LCSB about the relative merits of different production practices.
In conclusion, any animal care standards need to protect alternative production, processing, and distribution models. Consumer demand is at an all-time high for grass-fed beef, free-range poultry, and pastured pork. Small, diversified, and organic farms are meeting this demand while strengthening our local economies, increasing our food security, and protecting our vanishing farmland and rural traditions. Ohio needs to be creating a climate which encourages beginning farmers to raise livestock and provide viable pathways for the next generation of farmers to see a future in farming. We should not discourage new farmers by putting unnecessary and impractical obstacles in their way, and create a situation in which small-scale and diversified farming is not practical or profitable.Sincerely, Renee Hunt Program Director
The Ohio Ecological Food and Farm Association (OEFFA) is a 31-year-old membership based organization of farmers, backyard gardeners, consumers, retailers, educators, researchers and others who share the desire to build a healthy food system that brings prosperity to farmers, helps preserve farmland, offers food security for all Ohioans, and creates economic opportunities for our rural communities. OEFFA also offers organic certification. We are one of 55 domestic USDA accredited certification agencies, all which certify to the same standard, the National Organic Program (NOP).