this is my first visit to an end it was to be meeting and while i'm a member of several organic farmer organizations and support the recommendations to the ten o s b i feel it's important for the board to hear personal comments from individuals my goal for the meeting to attend watch the process take place participate in the process and decide if the open producer position is something i should pursue in the future or families organic dairy farmers in south ability to size freestyles entire stalls specifically for individual heard in cows one stall one cow incorrectly sized stalls are detrimental to livestock welfare it's appropriate that loose housing and better parent born should conform with the chart at the end of that section having access to feed simultaneously during the grazing season is not an animal welfare concern what is of concern is that all cattle maintain good body condition organic inspectors will be checking body condition scores to verify adequate diet therefore space and competition are not issues for cattle were good body conditions course thank you for the consideration and i appreciate the right more than our speed us for the program that afternoon and i mandrake are out and i'm a former chair of the and always be and it's a pleasure to see a lot of my good friends here first a short comment i support the handling committee's recommendation to allow fortification of organic food with what i will call f d a approved materials i have always believed that the board should approve fortification materials as a category and do so in a manner that conforms to f d a judgments just as we've done in the past with other materials that are listed on the national list however the inclusion of one zero for twenty was a mistake it was never any part of the recommendation from the  and should not have been added i agree that books ponying the decision to allow for greater input and gathering the information about fortification products consumers would want is help particularly in the areas of infant and toddler products my comment is more of a question and it is posed to the n o p because i don't understand the rush to judgment and the in on this important topic let me be brief harvey in two thousand and five the first circuit court of appeals declared that synthetic materials unprocessed or gannet foods were not authorized by the or oppa the u s d a s responded exercising enforcement discretion while the industry debated the eventual and eventually obtained a change in the statute to correct the p s a that took nearly a year to do and during that time u s d a obviously did not remove products from the shelves until the despite the court ruling based on this if i can just respond to that mike my my concern is moving quickly and making their own decision instead of living with caution and making the right decision and allowing for a discretionary you know obviously is there based on the decision that was made in two thousand by my name is andrew waterhouse i'm a wine chemist and professor and chair of the department of a culturally knology and u c davis our wine program is considered perhaps to be the best in the world sulfites are very simple product made by taking elemental yellow sulfur powder the same stuff that sprayed on a can of crops and burning the simple process has been used for hundreds or thousands of years the tree then the traditional practice of burning software candles in barrels continues up to today and includes the makers about him acquiring an even organic one in many countries outside the u microbes normally associated with cheese kimchi pickle or yogurt or mentation and the aromas of those foods sulfites also reduce problems from oxidation that would make a wine taste like nuts sherry were cooked vegetables today these problems and these defects are never found commercial wines but i recently found consumer comments on our clinic winds that could be linked directly back to the faults i mentioned including references to other fermented foods and combinations oxidation with else sulfites wine is extremely perishable and should be refrigerated for its entire one year when your life cycle between harvest between harvest and then from the winery to consumer unfortunately this is impossible in today's national wine distribution system so one made without sulfides especially the white ones continue to show very serious flaws i'm convinced that these persistent clause of the reason  latest medical research by scientists studying sensitive asthmatic patients is now calling into question whether sulfites are the cause of these reactions some exciting new papers have suggested alternative hypotheses including the presence of was published in the new england journal of medicine or that wine grapes might have allergen components allergenic components themselves at this point it's clear that more read more work is needed to find the actual cause of the larger reactions to wine in closing i want to say classify mostly if not all warnings that actually let us state u s d a organic one label it seems to me you are not expert in market analysis that the market is rapidly abandoning the term as defined by this board perhaps develop all the recommendations and i know you will and already have listened to the public input for making any final thoughts my husband already have five children no organic theory cows on our farm in finance oregon we became certified in two thousand and four i just completed a six year term on the army board of directors on which i served as board chair for two years ma making the transition to organic farming we took understanding the regulations very seriously we wanted to really know what we were embarking on before we jumped in organic farming is more than just a business venture to us it is a way of life today i want to comment on the animal welfare stocking density recommendation i believe it is important for the organic regulations to have some rules in place for the welfare of our livestock my concern is not around the intent of the document but is some of the particular requirements in one section of the recommendation the committee suggests that my stock should always be on soil during the grazing season there grazing season cattle are let out to open their corrals and passes for grazing along with freshly water cannon do ne a feed and additional care and attention can all use places to congregate and clean concrete is much better than wet or dirty ground grade a theory inspectors want to see cattle clean and dry with good conditions for animals cows must be milked on smooth and clean of all surfaces it is easier for cattle to walk or stand on flat concrete then through through a door marked i also was surprised to see that that it square foot is for dairy cattle yourself with what that is before you vote anyways we have three selborne cattle leave a soft try and control place to lay down cows are cleaner and healthier is smaller controlled areas than in a larger area where did lay in their own  partly turned around and they can get stuck and in closing i would like to say that i strongly agree with the recommendations made by the food farmers and all be said it was twenty pages but i there are very good  written their concerns regarding the current regulatory process is every part of the economic impact from getting farmers any changes in the regulations are valid and real without organic farmers there are no organic products to sell thank you by the end of this meeting if some good aspects are considered to be two species specific or subject to debate we'd like to encourage you to address these aspects in the species specific guidance documents that are going to be developed does fall and i've actually given you copies of the sheep guidance document which is developed by our director bonnie weidman as an example of how this might be done our two main areas of concern with this proposed recommendations are at our access and soil and stocking rates we don't think that outdoor access must always soil as long as they have enough material to root in we didn't the culture should have contact with soil but that's all should be expected to grow pasture we also think that stocking rates for hard should be increased to the median requirements stocking rates for sheep and goats should be consistent with american sheep industry recommendation stocking rates for lang and should be increased consistent with the ac a recommendation finally we think the proposed livestock transport handling aflutter recommendations should be withdrawn and revised in particular we think that welfare at the slaughter plants should be covered under existing regular regulations and not duplicated by certifiers however some shelter is not covered under the humane slaughter act we would like to see humane poultry slaughter audit criteria defined for use by certifiers of plants that are not animal welfare certified finally we also don't think that our stock color should be sufficient should need to be certified were a family operation with my wife and my son as a full time partnership milk and two hundred fifty cows and we have about two hundred fifty half hours the side that we farm of all four hundred fifty acres who are proud to be organic since tool seven i also sit on the western organic very produce result lions board into portions of the animal welfare recommendations concerns me enough to make the drive out here to speak to you into this in person during the grazing season we send our cows out weather permitting whenever possible but we also get about thirty inches and thirty five inches of rainfall here in that rainfall happens between november and march and sometimes carries in april twenty eight to twenty nine inches through that period of time and the other five inches continues on for the rest of the remainder of the year when the ground is saturated in rainy and rainwater we send our animals out on our farm an exercise run that is available that animals are around it's optional whether to use it or not but when it's raining they're locked into that regulations of the country before making a blanket recommendation whether concern is the fifty square feet of bedding space in the barn which you've heard numerous times today where  and when you're out in the field they've got a numerous amount of square foot but i don't think it makes sense to have to measure the whole barn a divided by the number of polish to get the bedding space and i think that word should be changed or the three stalls already being used in our organic process the kind of to need to be allowed i agree that the review of these materials should be done the take them through the proper federal registration process and i also think that these materials should continue to be allowed while the process product petition process takes place taken this fortified products all to the store shelf could affect farmers livelihood and for one i don't want to see  happy milk make happy customers and if we're all organic in the same process we're all going to be happy hello my name is paul stanley i have been farming organically in oregon city oregon since two thousand and two i'm also a member and i thank you for allowing me to speak today there are several areas for several sections throughout our animal awful document that need clarification specifically stocking density and outdoor  galloping requirements some of our outdoor access is some math and some of it is soil for example our holding pen it is the man in reading the recommendations it sounds like all outdoor access needs to be soil we get approximately three feet of rain in the wintertime making outdoor areas extremely muddy sending cows out on the mud is a dangerous to both cows and people not to mention by malcolm spector wouldn't be happy to see the cows out in the mud and it's not a density inside the barn we have three stalls with thirty two square feet for animal to get fifty square feet per cows i would have to take out every other stall animal i strongly suggest the board reconsider the working wording of this chart to reflect this and maybe now it's freestyle bars that have beds for all cows but the beds are fifty square feet as for crop materials i would like to see that continue a listing of chlorine pocket all in pheromones and on a final note i would like to see fortified food continued to be allowed in organic products providing those nutrients go through the federal register process just like everything else on the national west to keep business flowing smoothly until our granite farmers to keep selling their melt please do call fortified foods from the fortified through the marketplace give companies time to petition and go through the proper process because taking products away doesn't just hurt big business it hurts me and my farm to think questions been around for over a hundred years in times when everything was still organic and now days it's mainly a byproduct of iodine production and also in itself it has significant traces of iodine we agree arguments in there one concern it was raised is that farmers we may become dependent on natural chili and nitrates we don't agree with this because at the end product is self regulating  clarify that's the public is not limited to the western u s just to share the sales figures of us we sell in twenty nine different states we also collected over three hundred farmers testimonials  forty states talking in favor of the product and finally we did we also did a petition and over five hundred forty farmers from twenty one states signed a petition to support the product and to support to stop this used in conventional agriculture because again cost wise compared to the alternatives standard sport in the early days and i want to recognize that you guys have an awesome responsibility here and so if you look at things in the grand philosophy of who we are and what we do and the impact that we have on consumer expectations but also the realities of life on the ground that you weigh them very very carefully and i want to say that i think sunset was probably the bad term i wish we had said we're going to have a sunshine rule that meant we'd china bright light on everything every five years and say is a good is it not is there an alternative hasn't been developed is there a holy natural substitute land to organic agriculture and eliminate and minimize pesticides around the world to be very big and important responsibility i mean i have no dog in the hunt here so i'm here i'm talking from an international trade perspective i'm the senior trade policy adviser now to the organic trade association the foreign agriculture service and i work closely with miles actually the last time i was at the n o s be meeting miles a and margaret made the presentations on aquatics piece so it's been a while but it's good to be back from an international perspective what the decisions that get made here impact not only domestic trade but international trade in a significant part of our contribution these days it's about eight percent of all over the organic trade and there are two things that have come up one is that lebanon softening as a work with the northwest horticultural society our council and with our other producers i would ask you to consider adding the annotation for pairs as a flotation agent prepared that would allow everyone who is