For the Week Ending June 24, 2016

June 24, 2016


USDA has proposed new animal welfare standards for the National Organic Program that, if enacted, would be the first time such standards are codified in federal law and would present serious challenges to livestock producers, according to NPPC, which opposes the new standards There are a number of problems with the proposed new organic animal welfare rules, NPPC points out, including:

  • Animal welfare is not germane to the concept of “organic.”
    • Organic has pertained to foods produced without synthetic pesticides, antibiotics, synthetic fertilizers, genetically modified organisms or growth hormones.
    • The Organic Food Production Act of 1990 limited its coverage of livestock to feeding and medication practices.
    • While the Agriculture Secretary can consider additional provisions, they must be within the scope of the 1990 act.
    • Some of the proposed standards, such as requiring outdoor access and, for pigs, allowing for rooting behavior, conflict with other tenants of organic production such as environmental stewardship.
    • Consumer confusion about the meaning of “organic” should not drive rulemaking; consumer education campaigns should address any confusion.
    • Animal welfare is important to all producers and is not exclusive to organic production.
  • New standards add complexity, create barriers to existing and new organic producers.
    • Current organic producers have designed their enterprises around existing organic standards. The new requirements may make it cost prohibitive to retrofit operations to come into compliance.
    • The proposed standards, many of which run counter to best management practices used to protect animal health and the environment, could be a barrier to new producers entering organic production.
    • The standards would increase the cost of organic livestock products without making them more “organic.”
    • Rather than expanding organic livestock production, the standards could reduce the number of organic producers.
  • Animal welfare is complex and needs to be science-based.
    • The proposed standards are rigid, inflexible and not science-based; they will not allow organic producers the flexibility to respond to new housing and handling systems that may be developed to enhance animal welfare.
    • The standards are based on public perception of what is good animal welfare and do not reflect a consensus by experts in animal welfare and handling.
    • Producers need flexibility to make animal welfare decisions based on the needs and challenges of their particular animals, facilities and customer preferences. A one-size-fits-all approach eliminates that flexibility.
  • Standards should be outcome-based; there is not yet an international standard for pigs.
    • Livestock industry and other animal welfare programs are available and suitable for use by organic producers.
    • The pork industry’s PQA Plus program is a good example of an industry program that provides a significant and outcome-based measure of animal welfare.
    • The World Animal Health Organization (OIE), of which the United States is a member, sets international animal welfare standards and has not yet issued a chapter on pigs.
    • It is premature to put any welfare practices into the Code of Federal Regulations since they may conflict with the international standards now under development.
  • Proposed standards for pigs present challenges to animal and public health.
    • Requirements on outdoor access, bedding and rooting behavior are in conflict with best management practices used to prevent swine diseases that pose a threat to animal and human health.
    • The United States made a significant and costly effort to eliminate pseudorabies from the commercial swine herd. Keeping pigs outdoors facilitates exposure to feral pigs, which are known to harbor the pseudorabies virus. There would be significant international trade ramifications if pseudorabies were reintroduced to farmed pigs.
    • Outdoor production is the major route of introduction for the trichinae parasite. Increased cases of trichinae in organic pork would lead to consumer trust problems for all pork products and to potential distrust of U.S. pork from America’s trading partners.
    • Restrictions on tail docking and teeth clipping would not allow producers the freedom to make needed husbandry decisions, which are implemented to protect animal welfare.

NPPC is urging pork producers and others to submit by the July 13 deadline comments in opposition to the proposed organic animal welfare standards, which not only don’t add to what makes a product “organic” but could be broadened to encompass conventional livestock production. (Starting Monday, June 27, click here to submit comments.)



NPPC in comments submitted today urged USDA’s Food Safety Inspection Service (FSIS) to delay eliminating its trichinae control regulation until the U.S. pork industry, working with USDA, can establish a negligible risk compartment. Last July, the U.N.’s Codex Alimentarius Commission finalized global guidelines that provide a way for countries to define negligible risk for trichinae and establish methods for monitoring risk over time. In its comments to FSIS, NPPC expressed concern that eliminating the regulation prior to establishment of a risk compartment will negatively affect international trade and that packing facilities will face problems in trying to address trichinae in their HACCP plans. (To read NPPC comments, click here.)



NPPC this week joined 36 other food and agriculture groups on a letter urging U.S. Trade Representative Michael Froman and U.S. Secretary of Agriculture Tom Vilsack to resolve outstanding European Union (EU) market access issues before concluding the Transatlantic Trade and Investment Partnership (TTIP) negotiations this year. The groups asked the officials to push for elimination of tariff and non-tariff barriers on agriculture exports. “If the issues our organizations have identified as serious barriers to our exports to the EU cannot be resolved satisfactorily before the end of the year, we urge you not to proceed with a “TTIP-lite” agreement, which, for the U.S. food and agricultural sector, would do much more harm than good,” the letter stated. While NPPC currently supports the deal, it is skeptical of progress being made on it based on the intransigence of the EU on various issues. NPPC is concerned about the many critical ideological rifts that remain on agriculture. While the EU is willing to eliminate tariffs on nearly all goods, for example, it announced publicly it is unwilling to eliminate them on beef, poultry and pork. It also is refusing to reconsider its stance on beef hormones and the feed additive ractopamine, which is used in beef and pork production. NPPC wants in TTIP the same deal it has gotten in the 20 other free trade agreements the United States has concluded and in the TPP, which was recently finalized: elimination of tariff and non-tariff barriers on U.S. pork exports.



By a slim margin, Great Britain voted Thursday to leave the European Union, and Prime Minister David Cameron, who in 2015 promised to hold a referendum on the United Kingdom’s membership in the EU if he was elected, Friday announced he will resign. Campaigning for and against the so-called Brexit dominated the political scene in Europe for months. The 28-member EU was formed after World War II with the goal of promoting economic growth and avoiding conflict among the member countries. The EU is Britain’s biggest trading partner. The Brexit vote could have implications for the Transatlantic Trade and Investment Partnership (TTIP), which now is being negotiated between the EU and the United States.





President Obama, Canadian Prime Minister Justin Trudeau and Mexican President Enrique Peña Nieto will meet in Ottawa June 29 for the North American Leaders Summit. “The summit is further recognition of the value of a more integrated North America to advance the security and prosperity of the continent. It also highlights the importance of continuing to strengthen the bilateral and trilateral ties between the United States, Canada and Mexico,” the White House said in a statement. Obama is likely to discuss the Trans Pacific Partnership (TPP), which includes all three countries. As with the highly successful North American Free Trade Agreement (NAFTA), NPPC believes TPP should eliminate all tariffs on U.S. pork and pork products.


For questions, comments and suggestions or to subscribe, contact: Dave Warner, Director of Communications, NPPC, at (202) 347-3600, or via e-mail at