Comment on proposed Rules for Implementation of the Organic Foods Production Act submitted to the USDA by Ed Loewenton - part 3

     c. requiring use of organically produced feed (sec       
205.13(a)(1)(I).
USDA's attempts to mitigate NOSB's recommendations, particularly
the use of such vague terms as "if necessary", creates large and
uncontrolled loopholes that threaten to render the proposed
standards meaningless as a guide to consumer choice in food
products.  Under USDA's proposed rule, too  much discretion is
allowed the producer of the foods in determining when exceptions to
recommended practises are allowed. In the case of use of
antibiotics, no guidance is given as to the waiting requirement for
breeding stock, laying hens, and dairy cows.(205.14(d)).  (62 Fed
Reg 65880).
     [Use of antibiotics in food animals, except when
     medically necessary to treat illness, promotes the
     evolution of resistant strains of microbes. This threat
     has become a reality in human medical practise, due to
     the over-prescription of antibiotics.  Therefore, the use
     in animals adds to the threat to human health, even if
     the animal products (meat, milk, eggs, etc)  are free
     from antibiotics.]
     [ Regarding outdoor access and humane living conditions
     generally: confinement and overcrowding creates
     behavioral stresses which reduce the effectiveness of
     mammalian (and presumably poultry) immune systems,
     resulting in impaired health and the need for the use of
     drugs such as antibiotics to maintain adequate
     production.]
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