NASDA Comments on USDA's Request for Input on the Organic Livestock and Poultry Practices Rule


Filed By
Nathan Bowen, Director, Public Policy
Filed Date
Mr. Paul Lewis, USDA AMS National Organic Program
Re: Docket ID No. AMS-NOP-17-0031; NOP-15-06A: (National Organic Program; Organic Livestock and Poultry Practices)
Docket ID
AMS-NOP-17-0031; NOP-15-06A
166.21 KB, PDF

Mr. Lewis,

The National Association of State Departments of Agriculture (NASDA) appreciates the opportunity to comment on the U.S. Department of Agriculture (USDA) Agricultural Marketing Service’s (AMS) request for input on the disposition of the final organic livestock and poultry practices rule.  

NASDA encourages USDA to proceed with “Option 2” to suspend the rule indefinitely. After suspending the rule, USDA should conduct robust and meaningful consultations with NASDA, state departments of agriculture, state animal health officials, and the regulated community to determine whether to proceed with finalizing a rule, and if so, how a rule should be constructed. No rule should be finalized unless and until USDA satisfactorily addresses the significant animal health and biosecurity concerns raised by NASDA and others. Incorporation of mandatory compliance with animal health and biosecurity requirements should be a top priority by the USDA.  In addition, USDA should conduct an enhanced economic analysis to determine impact of the rule on producers, both organic and conventional, and consumers.

  1. About NASDA

NASDA represents the Commissioners, Secretaries, and Directors of the state departments of agriculture in all fifty states and four U.S. territories. State departments of agriculture are responsible for a wide range of programs including food safety, combating the spread of disease, and fostering the economic vitality of our rural communities.

Promoting their state’s agriculture producers—including organic farmers, ranchers, and value-added food producers—is a key responsibility for NASDA members, as is implementing a host of programs that support those producers and processors. For example, NASDA members engage in outreach to the organic community to disseminate $11.6 million in organic cost share funds and fifteen states serve as organic certifying agents under the National Organic Program (NOP).  

In addition, NASDA members have significant regulatory responsibilities related to animal disease outbreaks and response. In forty states, the state animal health official resides within the state department of agriculture.

  1. General Comments

NASDA supports the National Organic Program (NOP) and science-based recommendations that will enhance the program and increase growth for the organic industry. Organic agriculture is one critical tool to the future of feeding our growing global population. We must work in partnership to maintain or expand—not reduce—both farmer and consumer choice in the marketplace. 

Due to the significant animal health and biosecurity concerns raised in our previous comments, NASDA recommends USDA immediately and indefinitely suspend the current rule. As regulatory partners with USDA and advocates for all forms of agriculture, NASDA stands ready to consult with USDA to address those concerns as the department determines a path forward. It is imperative a rule is not finalized unless and until the department addresses the biosecurity and economic impact-related short comings of the previously finalized rule.

It is important to note that state departments of agriculture are not simply stakeholders, but instead are co-regulators with federal agencies in the implementation of animal health programs. Any future rulemaking should feature robust consultation early, and often, with state agriculture agencies, state animal health officials, and the regulated community.  Sound, validated, and peer-reviewed science must be at the core of any future rulemakings.

  1. Conclusion

NASDA appreciates the opportunity to comment on this important issue. As regulatory partners with USDA and advocates for all forms of agriculture, NASDA stands ready to assist USDA in maintaining the integrity of the coveted organic seal. Please contact Amanda Culp ( if you have any questions or would like additional information.


Nathan Bowen

Director, Public Policy