DRAFT – FOR OTA MEMBERS
The Organic Trade Association (OTA) is pleased to submit comments on the National Organic Program (NOP) proposed rule to amend the organic livestock and poultry production requirements in the current USDA organic regulations. This is a basic principle of organic production, and we agree that clarifications are needed in the regulations so that desired outcomes are clear, measurable, and enforceable. OTA is the membership-based business association for organic agriculture and products in North America. OTA is the leading voice for the organic trade in the United States, representing organic businesses across 50 states. Its members include growers, shippers, processors, certifiers, farmers’ associations, distributors, importers, exporters, consultants, retailers and others. OTA’s Board of Directors is democratically elected by its members. OTA’s mission is to promote and protect organic with a unifying voice that serves and engages its diverse members from farm to marketplace. OTA supports NOP’s efforts to create greater consistency in organic livestock practices NOP is proposing amendments to existing regulations to create greater consistency in organic livestock practices. OTA strongly supports the rule making process, and we commend NOP for releasing a proposed rule that is based on 14 years of public input and animal welfare recommendations the National Organic Standards Board (NOSB) unanimously passed in 2011.