April 7, 2015
National Organic Standards Board
USDA – AMS
1400 Independence Ave, SW
Washington, DC 20250
National Organic Standards Board members:
The Ohio Ecological Food and Farm Association (OEFFA) is a grassroots coalition of nearly 3,400 farmers, gardeners, consumers, retailers, educators, and others who since 1979 have worked to build a healthy food system that brings prosperity to family farmers, safeguards the environment, and provides safe, local food to consumers. OEFFA employs education, advocacy, and grassroots organizing to promote local and organic foods, helping farmers and consumers connect to build a sustainable food system. OEFFA’s Certification program has been in operation since 1981. OEFFA certifies 838 organic producers and food processors, ensuring that these operations meet the high standards established for organic products. Of these operations, 300 are dairies, 175 are mixed vegetable operations, and 72 raise poultry.
While there are many issues being discussed at this spring’s NOSB meeting, OEFFA’s comments focus on three materials of particular interest: Copper, Methionine, and Zinc Sulfate. We gathered input from our certified producers through surveys and conference calls. We were heartened by the response and interest from our clients and their desire to participate in this unique democratic process. We at OEFFA are thankful for the process that so many have worked to create and maintain, and respectfully offer the following comments.
OEFFA strongly supports the continued listing of fixed coppers and copper sulfate on the National List for organic crop production.
OEFFA producers utilize many cultural practices to support plant health and prevent diseases, including pruning, wider spacing between plants, crop rotation, variety selection, nutrient management, and mulches. They also employ products containing hydrogen peroxide, as well as several other remedies including milk, oils, and microbial inputs to manage diseases. While these practices and products are helpful, they are insufficient to manage disease problems such as phytopthera in tomatoes, peppers, eggplants, and cucurbits.
OEFFA producers work to make sure that copper does not accumulate in the soil by using specially designed sprayers and spraying techniques, as well crop rotations and soil testing. Some report success in managing disease by alternating between hydrogen peroxide and copper applications, further reducing the use of copper.
Copper is a controversial input in organic production and, due to the negative effects it can have on soil, aquatic ecosystems, and farmworker health, its use is included in critiques of organic production systems. For these reasons, we want to encourage further research into other viable disease management tools for use in organic production. However, copper remains a necessary tool in growing organic produce. Our producers maintain that copper is an essential part of their disease management programs and there is currently no comparable substitute available.
OEFFA supports the Livestock Committee proposal to change the listing of DL-methionine on the National List.
OEFFA producers are primarily raising birds in poultry barns with access to soil and pasture. No major health issues have been observed at the current methionine ration, though some producers noticed minor pecking issues with some flocks. Despite this fact, nutritionists working with our clients are recommending additional methionine beyond the amount currently allowed in the rule. As a result, producers are adding more soybean meal to organic rations, which can lead to wet litter, reduced indoor air quality, and ultimately decreased flock health.
OEFFA producers choose soybean meal over other nonsynthetic forms of methionine such as earthworms and soldier flies for various reasons. Some are concerned that they will be unable to procure a consistent supply, or that inputs may be contaminated with pathogenic organisms or cause diseases. Other nonsynthetic protein sources are prohibited by NOP rules.
OEFFA producers indicate they could continue to produce organic poultry using the current methionine restriction, but they would prefer to calculate and record methionine use per ton of feed as an average over the life of the flock, per the NOSB Livestock Subcommittee’s recommendation. As proposed, OEFFA producers think this modified ration would allow them to increase protein earlier in the birds’ lives leading up to peak production, without the negative effects, and then taper it off as the flock requires less. Producers also feel confident that they could keep records demonstrating compliance with the “average over the life” ration. As a certifier, OEFFA is concerned about how the verification of such records would play out on the ground. Such a change would require clear guidelines and ACA cooperation to ensure consistency across the industry.
OEFFA eagerly anticipates improved poultry standards as part of the forthcoming proposed rule on animal welfare and hopes that the link between synthetic methionine demand and access to pasture is considered in these changes. We emphasize the need for continued research for viable natural methionine alternatives and we are committed, as is stated in the Livestock Committee recommendation, to see a phase out of synthetic methionine in organic rations over time. While these alternatives are being developed and field-tested, we hope to see the Livestock Subcommittee’s proposal adopted to support the health and productivity of organic poultry operations.
OEFFA supports the addition of Zinc Sulfate to the National List.
OEFFA clients are already utilizing several cultural practices to support hoof and foot health in their organic management systems, including rotational grazing, maintaining dry housing and laneways, confining animals in very wet conditions, and conducting hoof trimming as needed. Despite these practices, foot and hoof issues such as foot rot, heel warts, and hairy warts arise from time to time. OEFFA producers are generally seeing these issues in one to three animals at a time, not in the entire herd. More issues seem to arise in those herds engaged in comparatively less grazing, while still meeting the organic grazing requirements.
Currently, OEFFA producers are using varied remedies to treat foot issues, including copper sulfate, hydrogen peroxide, and various home remedies including sulfur and garlic powder, a sugar/molasses paste, and dietary supplements including salt. Producers find the pastes difficult to administer because of the need to isolate the afflicted animal (a stressful process for the animal), clean the foot, apply the paste, and wrap the foot. There are also concerns that wrapping the affected foot could hold in moisture and potentially foster additional foot problems.
Because foot issues generally occur in only a few animals, OEFFA producers indicated both a need and a strong preference to use zinc sulfate directly on the affected hooves rather than as a footbath. An individual, spray-on treatment can be applied in an efficient, stress-free manner in the milking parlor without the need to wrap the affected hoof. We recognize that use as a topical application is not specifically requested in the petition, but topical use provides the needed benefits to farmers and affected animals. As an additional environmental benefit, the individual topical application does not require the disposal of footbath wastewater.
Should a footbath be allowed, our clients noted that the footbath wastewater would be mixed with manure and applied to fields. Although the zinc sulfate would compose a relatively small portion of the manure applied, it should be disposed of in a manner that minimizes accumulation of zinc in the soil, which could be monitored through soil testing.
In keeping with OFPA, we recognize the responsibility that comes with requesting this synthetic material be added to the National List. We hope that, as the process dictates, research for effective alternatives will continue.
Idea Regarding NOSB Material Review Process
This is the first time OEFFA has participated in the NOSB comment process. We are struck by the sheer volume of materials for review and the tremendous amount of work undertaken on behalf of the organic industry. As we experience this process for the first time, and in the spirit of continuous improvement, we offer the following question: Would it be possible to stagger the sunset materials review work over multiple meetings? In other words, perhaps rather than having one meeting in which all sunset 2017 materials are discussed, consider dividing the 2017 sunset materials in such a way that they can be discussed over the course of several meetings, timed in such a way to permit the vote at the appropriate (sunset date) time. This might improve the quality of the dialogue we have with producers, and the quality of information received, while not overwhelming everyone from NOSB members to producers in the process.
In closing, we would like to sincerely thank the Board for your service and for considering our comments. We appreciate the good work you do to maintain integrity and transparency in the organic industry.
Carol Goland, Ph.D.