An Interview with Margaret Scoles
Organic Certification for Livestock
Margaret Scoles is the Executive Director of the Independent Organic Inspectors Association (IOIA), Broadus, Montana. IOIA is an international membership association of organic inspectors that provides inspector training globally.
She has inspected organic farms, livestock, and processing plants for 19 years. She spoke in Denver at the SGF Organic Grass Finished Production School in February 2006 on the topic, "Organic Certification What it Entails and How to get it Done."
Q: Where do I find the regulations for organic livestock?
A: The USDA organic regulation, 7 CFR 205, is available on-line at www.ams.usda.gov/NOP. Although the entire document is hundreds of pages long, the rules for livestock are only a few pages. The rules are very readable.
The livestock production standards are 205.236 through 205.239. The list of what is allowed is in 206.603 (list of allowed synthetic materials, long list) and not allowed is in 205.604 (list of prohibited naturals, very short list). Only one natural material is listed as prohibited (strychnine).
If you apply to any USDA accredited certification agency, they will send you a copy of the regulations in your application packet. It is important that you read and study the regulation.
Do not rely on what you heard from others, even your inspector. Ultimately it is what the rules say that count.
In this article, many exact quotes from the rules are shown in italics.
Q: Can the rules change?
A: Yes, although there have been very few changes.
One of the most recent changes was elimination of an 80/20% dairy herd conversion clause that allowed transitioning dairy farmers to feed 80% organic feed during the first 9 months.
The rules don't change without substantial opportunity for public comment first. “Latest News” on the NOP website is the best place to keep up with proposed rule changes.
A 15-member National Organic Standards Board recommends rule changes to the USDA National Organic Program (NOP).
Q: What types of materials are allowed in organic production?
A: It should be noted that most organic livestock producers use very few materials.
Some examples are aspirin (to reduce inflammation), glucose, iodine, hydrogen peroxide, and copper sulfate.
Some materials are allowed without restrictions. Others are allowed with an annotation, which means they are allowed for specific purposes.
It is important to read the rules and use materials according to those specific annotations. An example is mineral oil, which is allowed for topical use and as a lubricant but prohibited as a feed additive.
Mineral oil is not allowed as a dust suppressant in organic livestock feeds.
Another example is chlorhexidine, which is allowed for surgical procedures conducted by a veterinarian. It is allowed for use as a teat tip when alternative germicidal agents and/or physical barriers have lost their effectiveness.
Another is milk replacer, which is allowed if it has no antibiotics and as emergency use only, no non-milk products or products from BST treated animals.
An example of emergency use would be if a mother was down and you used non-medicated milk replacer for a day for the baby.
New producers are sometimes surprised to find that commonly used materials such as Bag Balm or other topicals are prohibited because of some of the synthetic ingredients.
Q: Can I convert my existing livestock to organic production?
A: Breeder stock can be converted to produce offspring that can be certified organic.
Dairy animals can be converted to organic production by managing them organically and feeding organic feed for one year prior to producing organic milk. A new rule allows a converting dairy farmer to feed 3rd year transition feed from their own farm. This allows a dairy farm to convert both the land and the herd in the same year.
Chickens must be managed organically from the 2nd day of life, so they are often purchased as chicks from non-organic sources. Non-organic layers cannot be converted to organic production.
Meat and fiber animals cannot be converted to organic production. They must be managed organically from the last third of the gestation period of the mother.
It is somewhat easier to transition livestock than land. Although land must be organic for 36 months before it can be certified, breeding stock can be converted in only a few months (the last third of gestation).
A producer might restrict livestock from grazing on pastures and fields that aren't organic, take their livestock to certified pasture, convert part of a herd, or buy in certified organic livestock.
Q: What are the basic requirements for organic livestock?
A: 1. Certified organic feed, including pasture.
2. Sufficient feed ration to meet nutritional requirements.
3. Access to outdoors, shade, shelter, exercise areas, fresh air, and direct sunlight suitable to the species, its stage of production, the climate, and the environment.
4. Access to pasture for ruminants.
5. Must not withhold treatment of an animal in order to preserve its organic status.
6. No antibiotics, growth hormones, or synthetics unless they are on the allowed List.
7. No genetically modified organisms. These are called excluded methods in the regulation.
8. Record keeping system to allow tracking of all livestock and livestock products.
9. An organic system plan. This includes a description of practices and procedures to prevent contamination of the certified livestock or livestock products, record keeping system, monitoring practices, and a list of all inputs used.
Each certification agency has a system plan form that covers these items.
Q: What feeds are allowed?
A: Organic animals must be fed 100% organic feed, and organic means certified organic.
Feed includes pasture.
Pasture is defined as land used for organic grazing that is managed to provide feed value and maintain or improve or improve soil, water, and vegetative resources (NOP Subpart A).
Q: What can I do if my fence line borders a neighbor's nonorganic field?
A: First, visit with your neighbor.
If the neighbor is not applying any prohibited materials such as herbicides, one option is to ask them to sign an affidavit saying that nothing is applied within XXX feet of your fence.
If there are materials being applied or they aren't willing to provide a written document, you need to restrict animals from grazing to the fence line.
Commonly, this is done with electric fencing to keep animals out of the buffer zone. The rules do not specify the distance from the non-organic field.
Distance just has to be far enough to prevent unintended contamination of the pasture your animals are grazing. Runoff diversions might also be needed.
Q: How about bedding?
A: If it is typically consumed by the species, it must be organic. For example, if cattle are bedded with straw, the straw must be organic.
Q: What kinds of feed additives and salt are allowed?
A: They must not contain any synthetics, unless they are on the List. They must not contain slaughter byproducts such as animal fat.
Urea, manure refeeding, and plastic pellets for roughage are all prohibited.
Trace minerals and vitamins that are FDA approved are allowed.
However, producers need to scrutinize the ingredient list and get approval from their certifier before use.
Problem ingredients to watch for include urea, preservatives such as ethoxyquin, artificial colors, and flowing agents. Producers have lost certification on their livestock for failing to read ingredient lists carefully to find ingredients like these.
Also, remember that a guaranteed analysis is not the same thing as an ingredient list.
Only one synthetic amino acid is approved (DL Methionine); it is allowed only for poultry.
Molasses in pelleted cattle feed or lick tubs would be considered a feed and would need to be organic. It is prohibited to use feed, feed additive, and feed supplements in violation of Federal Food, Drug, and Cosmetic Act.
Q: Can I use treated fence posts?
A: The livestock rules don't address treated wood, but the crop production rules state in 205.206 (f), The producer must not use lumber treated with arsenate or other prohibited materials for new installations or replacement purposes in contact with soil or livestock..
This means that treated fence posts already in place are grandfathered in, but an organic producer cannot use them after they are certified.
Q: Can I spot spray with herbicide for noxious weeds?
A: Not if you intend to graze the pasture.
Spot spray will eliminate a pasture from certification for 36 months.
Q: Can I poison gophers or prairie dogs in my pasture, as long as the material is only used underground in the burrows?
A: The only materials listed for rodent control are Vitamin D3 bait (cholecalciferol) or sulfur smoke bombs. Any other synthetic, even if it is used only underground in the burrows, is prohibited and would prevent certification of the pasture.
Some producers have used equipment that mixes oxygen and propane as it is delivered into the burrow, followed by a battery ignited spark. The rodents are killed by concussion.
Mark Bradley, Assistant Deputy Administrator of the NOP, recently announced at major meetings that the NOP considers this a prohibited practice unless it goes through the process to be added to the National List.
Q: Can I graze on my neighbor’s or buy hay if I know they don't use any prohibited materials?
A: Not unless the neighbor's pasture or hay is certified organic.
Q: Is access to pasture required?
A: Access to the outdoors is required for all animals. However, pasture is only required for ruminants, such as sheep, goats, and cattle.
The regulations are not specific about the number of days, the percent of the feed that must come from grazing, or whether daily, or seasonal access is required.
Q: Is confinement ever allowed?
A: Yes, temporary confinement is allowed for inclement weather, animal's stage of production, conditions in which the health, safety, or well being of the animal is jeopardized, or risk to soil or water quality. The key is the word temporary.
Q: Can I keep my milking cows in spacious dry lots during the production season and let them out on pasture when they are dry, and still meet the rules?
A: Currently there are some dairies that only provide pasture access during the dry period.
They have interpreted temporary confinement for the animal's stage of production so that lactation is a stage of production. This situation has been the topic of much recent controversy and press.
The NOSB has recommended a rule that would clarify that grazing animals must have more defined access to pasture and that 'stage of production' should be changed to “stage of life.” They also recommended a minimum of 120 days annually and specified a percentage of the feed that must come from grazing.
Q: Anything I need to know about manure?
A: Producers must manage manure in a manner than does not contribute to contamination of crops, soil, or water by plant nutrients, heavy metals, or pathogenic organisms and optimizes recycling of nutrients. (205.239.c)
The rules regulate the time interval between application of raw manure and harvest of human consumption crops, but there is no restriction for manure application on crops used for livestock.
Q: How is drinking water regulated?
A: It isn't specifically regulated in the organic regulations.
If contamination is suspected for a drinking source, the certifier might require a water test.
Q: Is pasture finishing required for organic meat?
A: There is a good emerging market for grass-finished, organic meat. However, grass finishing is not required by organic regulations.
All ruminants must have access to pasture, but temporary confinement is allowed for “stage of production.”
It is not uncommon to confine the animals for a finishing period, with the finishing stage considered a “stage of production.”
Q: Can I vaccinate?
A: Yes, in fact, vaccines are listed as a preventative livestock health care practice.
Both killed and live vaccines are allowed.
Q: Are there any parasiticides on the allowed list?
A: Ivermectin is currently the only one listed, with an annotation for emergency treatment of breeding stock or dairy animals.
It cannot be used on slaughter animals if they are to be sold as organic, even in an emergency situation.
Q: Can I use Ivomec after I wean, but before the last 1/3 of gestation?
A: The rule prohibits the use of routine use of parasiticide and defines that as the regular, planned, or periodic use of parasiticides.
So, no, you couldn't routinely treat on an annual basis and have the offspring produced be certified as organic.
Some producers have occasionally treated a flock or herd with Ivomec, after weaning but before the next third of gestation. For example, if a sheep flock becomes infested with keds, the ewes might be treated.
Q: If I want to sell organic wool, how long do my sheep need to be organic?
A: From the last third of the mother's gestation. Wool from brought-in non-organic animals, such as rams or animals that have been medicated must be segregated and sold as non-organic.
Q: What if I need to use a prohibited medication for one animal? What if one lamb out of the flocks needs antibiotics?
A: It is not infrequent that an organic producer will use antibiotic or other medication on a few animals. Examples are serious injury, C-section, illness that doesn't respond to the organic management, etc.
When this happens, the producer must carefully document the event and mark the animal to identify it, so that there is no chance of confusing it with the other animals. This is usually done by recording the eartag number.
Other methods include double tagging, using a different color tag, or physical earmarking.
Q: Can I brand? How about dehorning? Or tail docking?
A: Yes, provided that the physical alteration is done to promote the animal's welfare and in a manner that minimizes pain and stress.
For example, tail docking is allowed for lambs, but would not be allowed for dairy cattle. Dehorning is commonly allowed, but method and age at dehorning should be considered.
Q: Are hormones ever allowed?
A: Oxytocin is an example of a material that is allowed with an annotation. It is allowed only for use in postparturition therapeutic applications.
Although it is allowed by the regulation, some organic milk markets will not allow it, so it is important to communicate with the buyer.
Q: I don't have a certified organic slaughter plant in my area. What can I do?
A: Slaughter must occur in a certified organic processing plant. If organic animals are processed in a non-organic plant, they cannot be sold as organic.
Many producers pay for and maintain certification on a slaughter plant. There is no requirement for USDA inspection to be organic.
Organic plants are currently state or USDA inspected. However, most producers seek a USDA inspected plant, so they can market interstate.
Slaughter plants are not difficult to certify. Some key points to think about are carcass identification, insecticide use in and around the plant, and possible contamination with sanitation and cleaning products.
Usually, organic meat is cut and ground first run of the day. Producers who want to market all the way to the retail level must get their labels approved both by the government agency and by the organic certification agency.
Q: What records do I need to keep?
A: The producer of an organic livestock operation must maintain records sufficient to preserve the identity of all organically managed animals and animal products.
Larger animals are identified individually. Poultry and smaller animals are often identified as a whole flock.
A typical set of records for a beef operation would include a cow record (manually kept or computer list); a calving book that includes any medications used and dates of vaccination and weaning; a pasture record showing herd movements; purchase receipts and copies of organic certificates for any purchased feed or replacement animals; and a sales record or invoicing system. Records must be retained for 5 years.
Q: Do I have to use numbered eartags on my animals?
A: Numbered eartags are not specifically required. However, a system has to be in place to identify the animals.
Q: Can I take my heifers to non-organic pasture before their last third of gestation?
Q: Can I raise my young ewes on my non-organic brother's place and bring them back 2 months before they lamb?
Q: What if I treat a heifer calf with antibiotic and want to save her as a replacement? Can breeding animals be converted back and forth for organic production?
A: These are all really the same question. It is my opinion that this is not clear in the rule. Some certification agencies interpret it differently. It is important that the producer communicates with the certifier.
Some agencies would consider if a cow was treated while lactating, that calf would be designated as non-organic, but the next calf could be organic provided that the cow was managed organically for the last third of gestation.
Others interpret the rules more strictly, saying that all animals must be managed organically with the exception of dairy animals in the process of conversion.
The USDA has yet to clarify. Here is the actual text of the rule:
205.236(a) Livestock products that are to be sold, labeled, or represented as organic must be from livestock under continuous organic management from the last third of gestation or hatching (this clause is followed by the language about exceptions for dairy animals and poultry) 205.236(b)
(1) Livestock or edible livestock products that are removed from an organic operation and subsequently managed on a non-organic operation may be not sold, labeled, or represented as organically produced.
Q: Can I purchase replacement animals from non-organic operations?
A: Yes, breeding stock can be purchased from any source, provided they are managed organically for the last third of gestation.
Q: What can I do about flies?
A: Sanitation, appropriate species or breed selection, and frequent pasture rotation are the best approach.
Some producers use diatomaceous earth, walk-through fly traps, or homemade concoctions of vinegar and soap.
At least one allowed pyrethrum-based insecticide is registered for use on livestock. The rules are not so specific that they list things that are allowed or not allowed.
The basic rule is that if it is natural, such as diatomaceous earth, it is allowed unless it is on the prohibited list.
And if it is synthetic, it is not allowed, unless it is listed in 205.603.
Q: What should I expect from the organic inspector?
A: You should generally expect at least a week's notice before the inspector arrives.
Ask your certifier for more details about how the scheduling works as it varies. Depending on size of the operation, inspection should take from several hours to a whole day.
Inspectors should come to the inspection already familiar with your organic system plan. They will have a copy of the plan and a list of items that the certifying agency wants them to check out.
They are on-site to verify the accuracy and completeness of your plan. They will want to see most of the livestock, your handling facilities, and any inputs used.
They will verify the record keeping system by tracking a few animals and a few sales. They will audit any purchased feeds to see if the quantities bought make sense with the amount fed.
At the conclusion of the inspection, they will conduct an exit interview, which is required by the regulation. This covers all issues of concern and the need for any further information.
The inspector cannot find something serious wrong, fail to address it during the inspection or exit interview, and report it to the certifier.
Depending on the certifier, a brief summary form is usually completed on-site and cosigned by the inspector and the producer.
The inspector completes a more comprehensive report following the inspection and sends it to the certifier.
Hopefully, if all goes well, within a month or two, the producer receives a certification letter, an organic certificate, and a copy of the inspection report. The inspection must be repeated annually.
A few resources:
Organic Dairy Farming, Edited by Jody Padgham, Orang-Utan Press, 2006, 156 pgs.
Organic Livestock Handbook, Canadian Organic Growers, 2000, 179 pgs.
The Control of Internal Parasites in Cattle and Sheep, Jean Duval, Ecological Agricultural Projects, 1997, 24 pgs, also available online at www.eap.mcgill.ca/general/eap_ind.htm
© by The Stockman Grass Farmer
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