NASDA Comments on USDA's Organic Livestock and Poultry Practices Withdrawal


Date Sent
January 15, 2018
Nathan Bowen, Director, Public Policy
Dr. Paul Lewis Director, Standards Division National Organic Program, Agricultural Marketing Service
National Organic Program (NOP); Organic Livestock and Poultry Practices-Withdrawal
161.97 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) intent to withdraw the Organic Livestock and Poultry Practices final rule.

I. 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, 31 states engage in outreach to the organic community to disseminate $11.5 million in organic cost share funds annually 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.

II. Support for Withdrawal

NASDA supports the USDA’s intent to withdraw the Organic Livestock and Poultry Practices final rule. For all future rules pertaining to organic agriculture, USDA should conduct robust and meaningful consultations with NASDA, state departments of agriculture, state animal health officials, and the regulated community to determine 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 impacted stakeholders during the rulemaking process of the original Organic Livestock and Poultry Practices rule. In addition, USDA should conduct an enhanced economic analysis to determine impact of any future rule on producers, both organic and conventional, and consumers.

NASDA fully supports the humane care and handling of all animals. All production systems should use the best available science to ensure the health and well-being of animals. Additionally, NASDA supports the National Organic Program (NOP), as well as recommendations that enhance and increase the growth of this sector of American agriculture.

III. 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 organic seal. Please contact Amanda Culp ( if you have any questions or would like additional information.

Nathan Bowen
Director, Public Policy