I know that a lot of small organic dairies (and many small organic farmers in general) accept the assumption that tighter standards protect them from the large scale bad guys, but it just ain't so. Certainly tighter standards translate into more paper work, but that is only one place where they advantage the larger, more mechanized (industrial) operations. It might be worthwhile to talk to some small (and large) farmers who choose not to be organic or who have opted out of the system. I know that in the Northeast, for example, local organic lamb is just not available because of the prohibition on any use of parasiticides, though there may be some who have figured out how to do this.

The point is that the important place for rigor is in enforcement - the strictest standards in the world are a joke if not properly enforced, but more flexibility (which is closer to what I would advocate) would allow those who are genuinely trying to do the right thing to make mistakes without being kept out altogether.

As I often like to say, all the problems of the food system cannot be solved by the organic label. Making it more difficult to be organic will only make it less likely to help those problems it can address.

And you are assuming that I'm standing with OCA/Cornucopia on this and I'm not. They way they took on Straus was appalling to me. Especially the message of methane digester = evil.

I couldn't agree more with JTE, and have said some very similar things elsewhere.

Gordon's comments serve to exemplify my point - the "fact" that you cite comes not from your knowledge of the regulation or how it is enforced, or of conditions on organic dairy operations, but from information disseminated by groups like OCA and Cornucopia. According to them it is a "fact" that corporate agribusiness tries to water down organic standards at every opportunity, which I know is a crock of dairy manure.

Please note that I fully support the requirement that organic ruminants (that means cows, sheep, goats and a few others) must be grazing as much as possible. Rather than a "one size fits all" requirement of a certain number of days and/or dry matter from grazing, I would rather see the requirement that every farm, no matter how good a job they are doing, show how they intend to further improve pasture quality so that more animals can graze on it for longer periods. As it stands now, as long as you have the animals out for at least 120 days you don't have to do better - in some regions that's barely adequate.