HP Hood LLC Six Kimball Lane Lynnfield, MA 01940 (617) 887-3000
May 29, 2008
Under Secretary Bruce Knight
Under Secretary for Marketing and Regulatory Programs
U.S. Department of Agriculture
1400 Independence Ave., S.W.
Washington, DC 20250
Dear Under Secretary Knight:
I write to you on behalf of HP Hood LLC and our more than 300 organic dairy farmers in support of the publication of a well-defined access-to-pasture standard under the USDA Organic certification program. As a manufacturer of organic milk products, we urge you to quickly issue and enforce a pasture standard to reflect the NOSB recommendations.
In addition to obtaining and maintaining organic certification through a USDA accredited certification organization, Hood and other leaders in the industry have already adopted pasture standards and we urge your administration to require that dairy animals over the age of 18 months be required to have a minimum of 120 days access to pasture during the growing season; that 30% of the total ration’s dry matter intake of lactating dairy animals be provided by grazing; and that dairy animals six months and older be required to have access to pasture in accordance with the region’s growing season.
HP Hood and other dairy manufacturers have responded to consumer requests for choice in the dairy aisle, including USDA Certified Organic milk and dairy products. Consumer trust and confidence remains a priority for the industry as consumers of organic dairy products must be assured that the products they consume are regulated under the most stringent guidelines of the program. Formalizing and enforcing an access-to-pasture standard will only help strengthen and preserve the integrity of the USDA Certified Organic program and its products.
Once again we urge you to expedite the publication and implementation of clearly defined access-to-pasture standards.
Thank you for your consideration.
Sincerely,
Mike Suever
Senior Vice President, R&D, Engineering and Milk Procurement
HP Hood LLC