April 2018 Issue

Organics: Fallout From the Reversal of OLPP
By Chris Vogliano, MS, RDN
Today's Dietitian
Vol. 20, No. 4, P. 14

The Trump administration revoked a proposed rule that would have improved living conditions for farmed animals.

Recently, the Trump administration withdrew the Organic Livestock and Poultry Practices (OLPP) proposed final rule. More than 10 years in the making, the rule would have strengthened requirements to improve the welfare of USDA Certified Organic livestock animals. These animals would have enjoyed larger living spaces and greater access to the outdoors—a move welcomed by the majority of consumers and organic farmers. What did this ruling entail, and why was it struck down? To understand the full picture, let's first look at the current landscape of organic livestock.

Where We Are Today
Imagine free-roaming animals basking in sunshine while foraging for green grass on open pastures. While idealistic, this doesn't represent the typical lifestyle for most farm animals raised for food in America. According to the USDA,1 on an annual basis, the United States slaughters the following:

cattle: 30.7 million;
calves: 487,700;
hogs: 118.2 million;
sheep: 2.2 million; and
chickens: 9 billion.

To meet these massive demands, the vast majority of animal production moved from the field to indoor feeding operations. This style of large-scale animal agriculture is commonly referred to as concentrated animal feeding operations, or CAFOs. CAFOs are designed to be efficient—requiring less space while producing animals for food more quickly. While CAFOs may be effective at raising a large amount of meat on a small amount of land, they're associated with great concerns for the environment and the animals themselves. These operations are a leading cause of water and air pollution, according to the National Association of Local Boards of Health.2 And livestock raised in this manner often are given routine nontherapeutic antibiotics in their feed to promote growth and deter disease. This practice is linked to global antibiotic resistance, one of the world's most pressing health issues of our time.3

Currently, most Americans believe USDA certified organic livestock already has improved access to the outdoors with adequate space in which to move. However, this organic certification contains many loopholes regarding outdoor access and doesn't specify a minimum space requirement per animal.4,5 "The original organic standards do require outdoor access," says Grace Gershuny, author of Organic Revolutionary and previous staff member of the USDA Organic Program. "However, some players are skirting the rules by only providing chickens with enclosed porches, which doesn't allow for proper access to the outdoors." While porches technically meet the outdoor access standards, Gershuny says, "they do not meet the intended integrity of the USDA organic guidelines."

Many of the smaller-scale organic producers already follow the proposed OLPP guidelines. Yet, there are a small number of large-scale producers who don't, and these producers represent a great segment of the rapidly growing $47 billion organic market. The exploitation of these loopholes is what led to the creation of the OLPP ruling, which was intended to help preserve the integrity of USDA organic certification.

Closer Look at OLPP
The OLPP aimed to promote greater consistency or standardize organic farming practices for the welfare and handling of livestock and poultry, set maximum animal densities, further define outdoor access, and more.6 If passed, the OLPP would have required minimum living space accommodations for poultry birds both indoors and outdoors. The proposed ruling would have allowed for reasonable transition periods, giving farmers who aren't in compliance time to make upgrades and improvements to their practices.

Organic producers and consumers supported this legislation because many seek to improve the living standards of animals by strengthening the requirements behind the organic label. "Consumers are seeking improved transparency in the food system and prefer products that are more ethical," says Josh Balk, vice president of Farm Animal Protection at the Humane Society in Washington, D.C. "When people buy organic products, there's a trust that those items came from sources that match a high ethical criteria."

Transparency, or improved insight into how food is produced, has become a common theme for America's food system and is seen as a necessary ingredient for improving consumer trust.7 Many consumers are becoming increasingly concerned about current animal welfare practices and are seeking options for animals to ensure they're treated ethically.8 Many also are willing to pay higher prices for food produced in accordance with stronger ethical guidelines.9

Why the Withdrawal?
The Trump administration withdrew the proposed OLPP ruling, citing that the "Agricultural Marketing Service (AMS) notes that organic producers have already made significant investments in facilities and infrastructure to support the growing organic market under the current USDA organic regulations, and there has been significant growth in the organic market under the existing regulatory regime."10 The official statement also concluded that "the OLPP ruling may hamper market-driven innovation."

Large agricultural organizations such as the American Farm Bureau Federation and the National Pork Producers Council applauded the administration's moves. "This rule … has been about pushing an agenda rather than advancing food safety or animal welfare," says Zippy Duvall, president of the American Farm Bureau Federation.

However, the administration's decision reversed years of work by the USDA and numerous other organic food producers. AMS welcomed comments on this decision, the majority of which disapproved of the decision to withdraw the proposed rule. "The Trump administration's efforts to scuttle the Organic Livestock and Poultry Practices rule will certainly harm both tens of millions of animals and family farmers who treat their animals dramatically better than their factory farming counterparts," Balk says.

Gershuny adds, "There were large numbers of public comments—the vast majority in favor [of the ruling]—but the Trump administration has neglected the comments and [has withdrawn] the rule."

Organic Industry Fights Back
The organic industry isn't sitting idly with this recent move by the Trump administration. The Organic Trade Association has filed a lawsuit over failure to implement this rule, stating, "By the department's [USDA] own count, out of the more than 47,000 [public] comments received, 99% were in favor of the rule becoming effective without further delay." Of the more than 47,000 comments on the USDA website supporting the improved practices, only 28 supported the withdrawing of the rule.

Dozens of national organic brands joined forces in protest to purchase a full-page ad in the January 16 edition of The Washington Post. The ad asked Sonny Perdue, Secretary of Agriculture at the USDA, to reinstate the OLPP, stating the organic industry and the American people overwhelmingly support it. George Siemon, CEO of Organic Valley, a national farmer-owned cooperative, said, "The organic seal belongs to the farmers, handlers, processors, and consumers who choose organic for their families."

Organic Label Still Upholds Requirements
Despite this setback, the USDA certified organic label does ensure certain livestock practices. However, if consumers want assurance that the livestock was raised and treated in a humane manner, the USDA organic certification doesn't offer this guarantee. Until the guidelines behind the label are strengthened, third-party certifications that ensure animals are treated in an ethical manner will continue to inform consumers.

— Chris Vogliano, MS, RDN, is a researcher, speaker, and consultant with a vision to create a sustainable and waste-free food system that's healthful for both people and the planet. Vogliano has served as an agriculture, nutrition, and health research fellow for The Academy of Nutrition and Dietetics Foundation and currently sits on The Council on Future Practice. He was awarded "Young Dietitian of the Year" by the state of Washington in 2016. Vogliano is currently pursuing his PhD in public health at Massey University in Wellington, New Zealand.


1. US Department of Agriculture, National Agricultural Statistics Service. Livestock slaughter: 2016 summary. http://usda.mannlib.cornell.edu/usda/current/LiveSlauSu/LiveSlauSu-04-19-2017.pdf. Published April 2017. Accessed March 16, 2018.

2. Hribar C; National Association of Local Boards of Health. Understanding concentrated animal feeding operations and their impact on communities. https://www.cdc.gov/nceh/ehs/docs/understanding_cafos_nalboh.pdf. Published 2010. Accessed February 22, 2018.

3. National Antimicrobial Resistance Monitoring System for Enteric Bacteria (NARMS). Centers for Disease Control and Prevention website. https://www.cdc.gov/narms/faq.html. Updated November 8, 2017. Accessed February 22, 2018.

4. American Society for the Prevention of Cruelty to Animals. Research on consumer perceptions of organic food standards for treatment of animals. http://www.aspca.org/sites/default/files/aspca_organic_labeling_public_memo_4-10-14.pdf. Published April 2014. Accessed February 22, 2018.

5. Fanatico AC, Owens CM, Emmert JL. Organic poultry production in the United States: broilers. J Appl Poult Res. 2009;18(2):355-366.

6. National Organic Program: Organic Livestock and Poultry Practices; Withdrawal. Regulations.gov website. https://www.regulations.gov/document?D=AMS-NOP-15-0012-6686. Updated January 18, 2018. Accessed February 22, 2018.

7. Wognum PM, Bremmers H, Trienekens JH, van der Vorst JG, Bloemhof JM. Systems for sustainability and transparency of food supply chains — current status and challenges. Adv Eng Inform. 2011;25(1):65-76.

8. Clark B, Stewart GB, Panzone LA, Kyriazakis I, Frewer LJ. A systematic review of public attitudes, perceptions and behaviours towards production diseases associated with farm animal welfare. J Agric Environ Ethics. 2016;29(3):455-478.

9. Lagerkvist CJ, Hess S. A meta-analysis of consumer willingness to pay for farm animal welfare. Eur Rev Agric Econ. 2011;38(1):55-78.

10. National Organic Program (NOP); Organic Livestock and Poultry Practices-Withdrawal. Federal Register website. https://www.federalregister.gov/documents/2017/12/18/2017-27316/national-organic-program-nop-organic-livestock-and-poultry-practices-withdrawal. Updated December 18, 2017. Accessed February 22, 2018.


Animal products such as eggs often bear labels with claims that leave consumers confused. Some of these labeling claims have credible definitions, while others are simply marketing buzzwords. Below is a list of some of the most common labeling claims found on animal products and their definitions.1-3

1. Animal Welfare Approved. This is the most rigorous certification for animal welfare ethics. The label requires animals to be raised on a pasture in a way that's healthful for them and the environment.

2. Certified Humane Raised and Handled. This label is a third-party certification that comes from an independent nonprofit organization. It certifies that eggs, dairy, meat, and poultry are raised with sufficient space, shelter, gentle handling, fresh water, and no added antibiotics or hormones.

3. Organic. This label ensures the animal is raised without the use of antibiotics or added hormones and with organic feed. However, the label has limited specifications regarding animal welfare and ethics.

4. Hormone-free. The claim hormone-free technically is misleading, as all animals naturally contain hormones. However, this labeling claim is meant to suggest that the animal wasn't given hormones during its lifespan. Hormones are banned in poultry, pork, and goats.

5. Grass-fed. This term technically means that the cattle or lamb were fed grass diets from birth to slaughter. This term was withdrawn by the Agriculture Marketing Service of the USDA in January 2016.

6. Free-range. This USDA-regulated term means that producers must demonstrate that poultry is allowed access to the outdoors. Free-range eggs must be produced by cage-free hens housed in a building, room, or area that allows for unlimited access to food and water, and continuous access to the outdoors during their laying cycle.

7. Cage-free. This labeling claim suggests that animals are raised without being in cages. This doesn't mean birds have access to the outdoors or have a large living space.

8. Raised without antibiotics. This label suggests animals were raised without being given subtherapeutic doses of antibiotics. However, no third-party organization exists to support this claim.

9. Natural. The USDA allows the term "natural" to be used on meat and poultry packaging. "Natural" suggests the product contains "no artificial ingredient or added color and is only minimally processed." Minimal processing means the product was processed in a manner that doesn't fundamentally alter the product. The label must include a statement explaining the meaning of the term "natural," such as "no artificial ingredients; minimally processed."

— CV

1. Meat, eggs and dairy label guide. American Society for the Prevention of Cruelty to Animals website. https://www.aspca.org/shopwithyourheart/consumer-resources/meat-eggs-and-dairy-label-guide. Accessed February 22, 2018.

2. Meat and poultry labeling terms. US Department of Agriculture website. https://www.fsis.usda.gov/wps/portal/fsis/topics/food-safety-education/get-answers/food-safety-fact-sheets/food-labeling/meat-and-poultry-labeling-terms/meat-and-poultry-labeling-terms. Updated August 10, 2015. Accessed February 22, 2018.

3. US Department of Agriculture, Agricultural Marketing Service. United States standards for livestock and meat marketing claims, grass (forage) fed claim for ruminant livestock and the meat products derived from such livestock (withdrawn). https://www.ams.usda.gov/sites/default/files/media/Grass%20Fed%20Standard
. Updated January 12, 2016. Accessed February 28, 2018.