USDA Re-Opens FY15 Origin of Organic Livestock (OOL) comment period
An update on Origin of Livestock Rule by Mark Rokala, Policy Director.
On October 1, USDA re-opened the comment period on the FY15 Origins of Organic Livestock (OOL) Rule for 60 days—closing on December 2, 2019.
Both the House and the Senate, at Organic Farmers Association’s request, included legal language in their respective FY20 Agriculture Appropriations bills telling USDA to implement the FY15 OOL Rule in 180 days.
Because of that action by Congress, USDA’s Legal Counsel determined that the federal agency might be vulnerable to a lawsuit by a new entrant, since 2015, in the organic dairy industry. The Administrative Procedures Act requires those impacted by a policy change the opportunity to comment on its impact on their business.
In its official notification, USDA said that it would be adding new comments to the comments submitted in 2015.
The USDA will be including all prior 2015 comments in its review, as well as any new comments that come in before December 2, 2019. Organic Farmers Association was not an organization in 2015, and thus we will submit comments to the rule. We encourage all certified organic farmers to submit comments in favor of a strong Origin of Organic Livestock rule that clarifies that the animal transition for an organic dairy farm is a one-time whole-herd transition in support of organic dairy farmers nationwide. This is an important organic integrity issue where we must stand in solidarity. Organic Farmers Association sent out an action alert to aid in your comment submission. View Action Alert here.
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