CENTER FOR FOOD SAFETY | April 2014
“Given other urgent priorities at this time, we do not anticipate addressing NOSB’s proposals on animal welfare in the near future.” (National Organic Program, 2013)
INTRODUCTION Each year in the United States, approximately ten billion animals are raised for food. These animals are sentient, complex beings, capable of feeling pain and discomfort, frustration and contentment.1 Yet, despite this widespread knowledge that farm animals can experience physical and emotional pain, they are consistently abused and deprived of their most basic needs—enough room to engage in natural behaviors, a natural diet suited to their species, ample water, and an overall healthy environment. When these basic needs are removed from the equation, farm animal rearing can become an inhumane and environmentally destructive practice, akin to industrial animal factories.2 While organic consumers often purchase organic meat and dairy products to avoid supporting such unscrupulous animal production practices, what they may not know is that the largest organic producers are not following even the minimal animal welfare practices.3 If the United States Department of Agriculture (USDA) fails to remedy this situation and promulgate timely animal welfare regulations, consumer confidence in organic may suffer. In the organic egg and poultry industry in particular, some larger producers have implemented a sub-par interpretation of the law that many, including Center for Food Safety, would not view as humane animal treatment. Organic production systems—the gold standard of agriculture—are intended to maintain a high bar for animal welfare. Many organic farmers rear food animals as part of an integrated, biologically diverse food production system. These organic farmers and ranchers care for the well-being of the animals they raise. They believe that animal welfare is an integral part of raising animals for food. Unfortunately, organic animal producers and regulators have not universally adopted this philosophy. Although the organic community and the general public have pushed for the adoption of strong animal welfare regulations for many years, the National Organic Program (NOP) recently decided not to proceed with their development for the organic poultry industry.4 Instead, in 2012, USDA commissioned a third-party economic analysis and comparison of the National Organic Standards Board (NOSB or the Board)’s recommended regulatory changes, independent animal welfare standards, and existing regulations. That analysis, Economic Impact Analysis of Proposed Regulations for Living Conditions for Organic Poultry (USDA’s Economic Analysis), concluded that welfare improvements would adversely impact the largest egg producers to such an extent that they would exit organic production. This gave USDA/NOP pause for concern. Subsequently, in a statement that accompanied NOP’s public release of USDA’s economic analysis, NOP announced that “[g]iven other urgent priorities at this time, we do not anticipate addressing [NOSB’s] proposals on animal welfare in the near future.”5 It is unclear whether or when NOP will pursue regulatory development in this area.
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