Submitted by Arizona Farm Bureau Government Relations Team: Dear Debuty Administrator Miles McEvoy (National Organic Program, Agricultural Marketing Service, U.S. Department of Agriculture): The Arizona Farm Bureau Federation represents a diverse membership of farm and ranch families including organic producers, direct marketing businesses, and conventional growers. Together these agricultural entities generate $17.1 billion in economic impact to Arizona’s economy. A number of our state’s agricultural producers will be impacted by the U.S. Department of Agriculture’s (USDA) National Organic Program (NOP) proposed rule and we appreciate the opportunity to submit these comments.

The NOP is a useful marketing platform which provides a framework for farmers to receive organic certification and gain premium value for their specialized products. However, the proposed changes to the program would have an adverse impact on those who participate in the NOP. For this reason, we do not support the proposed rule. Instead we urge the USDA to clarify organic label information, educate consumers about organic food products, create flexibility in standards for livestock and poultry production practices, and encourage participation in science-based animal welfare certification programs.

The concept of “organic” production has always been understood to be production practices that do not utilize synthetic pesticides, antibiotics, synthetic fertilizers, genetically modified organisms, and growth hormones. Furthermore, the Organic Production Act of 1990 limited its coverage to livestock feeding and medication practices. And although Congress does allow the Secretary of Agriculture to consider additional provisions, they should be within the scope of the Act. We do not believe mandated production methods relating to animal welfare falls within what Congress intended of the NOP. Moreover, animal welfare is of concern to all producers and is not exclusive to organic production.

The USDA Agricultural Marketing Service (AMS) notes in the proposed rule that surveys designed to measure consumer trust of the organic label have shown consumers are confused about what the organic label means. Instead of remedying this confusion through rulemaking and attempting to expand the scope of the rule, the USDA should develop consumer education campaigns to address the areas of the label consumers do not understand.  

Additionally, AMS believes that many livestock and poultry producers would prefer to use the organic label to convey information about their practices to consumers. However, organic livestock producers seem to be more opposed to the proposed rule rather than supportive. Organic pork producers are concerned about proposed standards requiring outdoor access that conflicts with other elements of organic production such as environmental stewardship. For organic egg producers the proposed rule would eliminate certain methods of outdoor access which would severely limit their ability to control for diseases as required by the USDA Veterinary Service and the U.S. Food and Drug Administration. The new standards could also force current organic producers to retrofit their operations to come into compliance with the proposed standards, which would be costly endeavor.

The USDA should instead encourage organic producers to participate in science-based animal welfare certification programs. Voluntary national production programs such as the Pork Quality Assurance Plus, Beef Quality Assurance, and National Dairy FARM Program are created by experts who understand the nutritional, physical, and health needs of livestock. They are rooted in science and define good production practices that are flexible to size, system, and species.

As a member of the American Farm Bureau Federation we support the comments they have submitted to this docket. We urge the USDA to carefully consider our collective concerns and make the necessary modifications so that the National Organic Program meets the needs of farmers and ranchers and also the expectations of consumers.


Kevin Rogers, President

Arizona Farm Bureau Federation