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Comments submitted on Mar. 12, 2008 regarding Dairy Product Labeling
March 12, 2008
Mr. Robert Boggs, Director
Ohio Department of Agriculture
8995 East Main Street
Reynoldsburg, Ohio 43068
Dear Director Boggs,
On behalf of the Ohio Farm Bureau Federation, Ohioâ€™s largest farm organization, we wish to thank the Ohio Department of Agriculture for taking responsible measures and actions regarding the labeling of dairy products as it relates to the use of rbST by dairy farmers. We fully realize that the Department could have decided to adopt policy, but ultimately thought that the issue was important enough to be addressed through a rule making process, which if approved by the Joint Committee on Agency Rule and Review will protect and benefit all stakeholders with an interest in this particular issue.
Additionally, we wish to thank the Department for initially conducting a public meeting this past November to discuss dairy labeling issues and following the meeting, appointing a diverse committee to provide further guidance, advice and counsel to the Department of Agriculture regarding this issue.
The rule proposed by the Ohio Department of Agriculture and the executive order issued by Governor Strickland on February 7, 2008, is good for dairy farmers and consumers as it prohibits the mislabeling of dairy products and defines what constitutes false and misleading labels for dairy products. The emergency rule established acceptable, more consistent labeling practices for dairy marketing organizations and labeling entities.
Just as farmers have the choice whether or not to use rbST, we believe consumers deserve a choice as well. While some consumers may prefer to purchase dairy products derived from dairy farms that do not supplement their cows with rbST, for a variety of reasons there will remain a group of consumers who trust the science backing this technology, as well as other forms of technology that are currently used and those that will be developed and utilized in the future, and will base their dairy product purchasing decisions on price or other factors. The market place should provide retail marketing choices for both.
We believe the role of Ohioâ€™s Department of Agriculture is to protect both farmers and consumers through regulatory enforcement and compliance. To this end, we view the role of the Departmentâ€™s Dairy Division as one of protecting food safety throughout the production, transportation, processing, packaging, handling, distribution, and retail phases.Â The Department is also charged with the responsibility of ensuring that all dairy food product labeling is not false or misleading. We oppose all use of false and misleading labels, promotional materials or other advertising for food products, and believe that the Department and its Dairy Division should require that all dairy product labels must be able to substantiate their claims through sound scientific testing.
Currently, such a scientifically-reliable test is not available for rbST, and may not be available in the foreseeable future. Therefore, it is vitally important that dairy product labeling entities be able to validate claims made that their respective milk and dairy products originated from cows not supplemented with rbST. Additionally, we encourage dairy farmers to abide in good faith to the terms and conditions of agreements that they make with their marketing cooperative or company. Not doing so would jeopardize the integrity of the entire dairy industry, which is the most important economic segment of Ohioâ€™s livestock industry.
As we have shared with you in previous comments regarding this issue, we continue to be very concerned about the impact â€śabsenceâ€ť labeling is having on the ability of dairy farmers to remain competitive and viable while at the same time ensuring that dairy products meet consumer needs. We consider claims made regarding the composition of milk, such as â€śno hormones, hormone free, rbST free, rbGH free and bST-freeâ€ť, as well as statements that the absence of a compound not permitted by the U. S. Food and Drug Administration to be present in any dairy product, to be false and misleading. These claims are merely advertisements, not guarantees of health, quality or safety. Milk marketers who claim that an absence of farming technology is a positive thing are fooling themselves and their customers. Various forms of modern technology, including but not limited to the use of rbST, allows farmers to produce more milk with fewer cows and the result â€“ aside from the cheapest and safest food in the world â€“ is a smaller carbon footprint.
It is our organizationâ€™s position that labels should not be required to contain information on production practices that do not affect nutrition or safety of the product. We oppose negative labeling of food products as being derived from the use of biotechnology. Furthermore, we support the science-based labeling policies of the U. S. Food and Drug Administration, yet recognize that the U. S. Food and Drug Administrationâ€™s guidance does not have the power of law or rule; thus, the need for states, including Ohio, to review their laws and rules to make certain that they have the ability, when and where necessary, to enforce FDAâ€™s guidance regarding the labeling of dairy products.
Once again, we wish to thank the Department of Agriculture and Governor Strickland for issuing the proposed rule and executive order, and allowing us to provide input that represents our organizationâ€™s grassroots-driven policy process and the more than 2,800 dairy farmers who belong to our organization.
John C. Fisher