NCC on Thursday filed comments on USDA’s Organic Livestock and Poultry Standards proposed rule.

The proposed rule, first announced in August, would change USDA organic regulations including requirements for organic poultry and livestock living conditions, care, transport, and slaughter.

Specifically, the rule would:

  • Specify which physical alteration procedures are prohibited or restricted for use on organic livestock;
  • Set separate standards for mammalian and avian livestock living conditions to … reflect the needs and behaviors of the different species, as well as related consumer expectations;
  • Include proposed avian livestock living standards [that] would set maximum indoor and outdoor stocking densities to ensure the birds have sufficient space to engage in natural behaviors;
  • Add new requirements on the transport of organic livestock to sale or slaughter;
  • Add a new section to clarify how organic slaughter facility practices and USDA Food Safety and Inspection Service (FSIS) regulations work together to support animal welfare.

NCC asked for additional clarity regarding the rule’s year-round access requirement to the outdoors, including any potential impacts from foreign animal disease threats. NCC also requested clarification and scientific references to support the proposed rule’s outdoor space requirements and ongoing maintenance of outdoor space, as well as potential impacts on farm size and land use.

The proposed rule also included a requirement that producers “implement practices to maintain ammonia levels below 10 parts per million (ppm).”

“No concrete reasoning or data has been provided to support the 10 ppm standard and therefore we question its relevance,” NCC’s comments said. “The broiler industry as a whole maintains and implements ammonia monitoring programs to include corrective actions should ammonia levels in the atmosphere rise above 25 ppm at bird height.” The Occupational Safety and Health Administration’s (OSHA) exposure limit is 50 ppm and the National Institute for Occupational Safety and Health’s (NIOSH) limit is 25 ppm. “NCC’s position is that ammonia in the atmosphere must not exceed 25 ppm at bird head height,” the comments said.

Finally, NCC suggested that USDA remove certain parameters, including proposed changes to compliance record keeping that likely would create redundancies and confuse Agency jurisdictions, the requirement to reevaluate at the processing plant whether a bird was fit for transport, and the requirement to provide feed to birds if transport exceeds a certain time period.

“In conclusion, NCC supports science-based and data-driven policy decisions that will result in measurable improvements in the health and welfare of our flocks,” NCC’s comments said. “NCC also supports policy that bolsters the viability of the organic broiler industry. We appreciate the opportunity to provide comments on the proposed rule and hope that the Agency considers only parameters that will truly result in improved welfare.”

NCC’s comments can be found here.