“Intent” in Organics when it’s convenient: NOT

I was discussing with a certifier a substance that is being fed to some organic cows that is, lets just say, problematic. It’s components probably contain areas than fall into some grey areas in the organic rule. However, from a strict reading of the rule, certifiers have been allowing it. Some object to it’s use because it doesn’t meet “the intent”. Well now we have organic dairy farmers trying to meet the organic “grazing rule” dealing with the uncertainties of mother nature and when and how much it will rain, who have been putting their cows out on grass to pasture since in some cases late December. They have the full “intent” to get the cows out and graze. However, that early grazing with the poor regrowth of grass we are likely to see unless we get a lot more regular rain in the area, is creating situations where those producers will have a very hard time meeting the actual regulatory rule of 30% dry matter intake average being consumed as pasture for a minimum grazing season of a minimum of 120 days. For those who can’t meet the rule, and we really won’t know until at least May, will they get a break for their “intent”? Probably not, unless the Secretary issues a temporary variance. People hate to hear it but “Intent means nothing”. In other words if the intent does not match the regulation then change the regulation to meet the intent. But in the mean time you have to follow the regulation even if it doesn’t quite meet the intent.

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