NCAT's Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices
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NCAT's Organic Livestock Workbook is designed to help organic and transitional livestock producers understand USDA organic regulations. It addresses allowed practices and materials to promote sustainability. The workbook can be shown to inspectors, who represent certifiers and ensure compliance. Annual inspections are required for ongoing certification. The workbook questions practices and documentation to aid certification and identify any issues. It aims to guide producers in meeting organic standards.
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NCAT’s Organic Livestock Workbook:
A Guide to Sustainable and Allowed Practices
So here’s the scoop…
The Purpose and Use of This Workbook
One of the greatest challenges in organic farming today is understanding and navigating the Organic
Regulations. This workbook3
is designed to help you in this regard. It addresses, among other things,
the wide range of practices and materials allowed under the National Organic Standard. Particular em-
phasis is placed on those farming strategies and practices that promote sustainability.4
This workbook
will be especially useful to producers contemplating conversion to organic production, and to those who
are in the early years of transition. If you are a beginning farmer or rancher, or are contemplating conver-
sion to organic production, we encourage you to read this workbook before completing your application
for certification. Please note that this is NOT a required document; it is a helpful guide that you may use
as you wish. Hint: Your certifier would love to know you are using this workbook for guidance; consider
showing it to your inspector.5
And speaking of organic inspectors, as you will learn in this workbook, organic inspection is an annual
process. The individual who conducts the inspection—the organic inspector—represents the certifying
agent. It is the inspector’s responsibility to look for documentation and indicators that bear out the
producer’s claim to organic status, as well as to look for any violations. To succeed at their job, organic
inspectors are trained to look critically at all aspects of an organic operation; few details escape their
notice. This workbook presents an inspector’s perspective and attempts to address all of the different
areas that inspectors investigate while visiting a livestock operation.
Much of the useful information in the workbook is presented as brief discussions. Numerous endnotes
are provided; most of these suggest further sources of information. You will also find a number of ques-
tions at the end of each section, which serve as a checklist for sustainable practices and for preserving
organic integrity. There are a number of questions that draw particular attention to areas that may affect
eligibility for certification. In most instances the pertinent section and paragraph of the Organic Regula-
tions will be shown in brackets, for example, [§205.203(c)].
Consider each of the questions carefully and place a check in the appropriate “Yes,” “No,” or “Not Appli-
cable (n/a)” box. Providing answers that accurately reflect your current circumstances will be the most
helpful to you—honesty will be your best policy. Ideally, you will have most of your checks in the “Yes”
boxes.
If you want to make optimum use of this workbook as a guide to information sources, try using the
electronic versions (.html and .pdf) of the workbook that can be found on the ATTRA website at <http:/
/www.attra.ncat.org>. The workbook is featured under the section on organic farming. The publica-
tions referenced in the endnotes are mostly free-of-charge resources accessible on the World Wide Web,
and are active hypertext links. Clicking on any of these links will “jump” you immediately to that re-
source. But be aware, electronic addresses can change. If a link does not work for you, submit your
request to the appropriate entity—State Cooperative Extension Office, ATTRA, or other. A contact list
for the primary information providers and Extension Publication Offices can be found toward the end of
the workbook.
Please note that some resources listed in the endnotes may not be fully consistent with the National
Organic Standard. For example, Cooperative Extension Publications on organically acceptable pesti-
cides often include nicotine, which is now specifically prohibited. When you have a question about
whether any practice or product is allowed in organic production, CONSULT YOUR CERTIFIER. This is
advice we will frequently give throughout this workbook.](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-4-320.jpg)
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NCAT’s Organic Livestock Workbook:
A Guide to Sustainable and Allowed Practices
I. Organic Agriculture in America
There are many notions of what organic agriculture is. In 1995, the National Organic Standards Board
defined it as “an ecological production management system that promotes and enhances biodiversity,
biological cycles and soil biological activity. It is based on minimal use of off-farm inputs and on man-
agement practices that restore, maintain and enhance ecological harmony.”
The legal definition, provided in the National Organic Program Regulations, states that “Organic pro-
duction [is] a production system that… respond[s] to site-specific conditions by integrating cultural,
biological, and mechanical practices that foster cycling of resources, promote ecological balance, and
conserve biological diversity” [§205.2]. While these definitions are helpful, they have more meaning
when one considers them in light of how organic farming and the organic marketplace evolved.
Contemporary American organic farming has its roots in the humus6
farming movements that prolifer-
ated in Great Britain and Continental Europe from the 1920s through the 1950s. These movements evolved
largely in response to the increasing use of synthetic fertilizers. The proponents of humus farming be-
lieved that the highest quality food and the sustainability of agriculture were achieved through systems
and techniques that built and enhanced the living organic or humus complex of the soil. Humus farming
was typified by mixed farms that had both livestock and crop enterprises; they featured cropping schemes
that included both food and feed crops, plus legume and grass forages and green manure crops. Humus
farming made little or no use of soluble commercial fertilizers or pesticides, in good part because they
were not needed and could even be counterproductive in systems so-modeled on nature.7
The 1960s and 1970s brought more visibility to organic farming as public concern over pesticide use
increased. The non-use of synthetic pesticides eventually became a major focus of organic agriculture as
demand for organic products grew, creating an industry out of a practical philosophic movement. Or-
ganic industry growth led to the establishment of standards and third-party certification to ensure con-
sistency and enhance credibility.
As the industry expanded during the 1980s, disparities among certifier standards, barriers to trade, and
incidents of fraudulent marketing led many to believe that more regulation was needed. Finally, in 1990,
Congress passed the Organic Foods Production Act (OFPA).8
The OFPA mandated creation of the Na-
tional Organic Program (NOP) and an advisory body, the National Organic Standards Board (NOSB).
The OFPA paved the way for creating a single set of US standards for organic production, labeling, and
marketing, which now exists in the form of the National Organic Program Regulations, a.k.a. the Na-
tional Organic Standard.9
Many other countries, such as the European Union and Japan, have their own
organic standards for products produced in or imported into their countries. US organic producers plan-
ning to export their products must take these standards into account when certifying their operations.](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-5-320.jpg)
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NCAT’s Organic Livestock Workbook:
A Guide to Sustainable and Allowed Practices
II. Certification
Certification under the National Organic Program is the license to label, represent, and market your
products as organic. Certification can be obtained from state or private certifiers that are accredited
through the National Organic Program and who act as its licensing agents. 10
Under the NOP Regulations, all operations or portions of operations that produce or handle agricultural
products that are intended to be sold, labeled, or represented as organic must be certified. Noncertified
producers who represent themselves or their products as organic risk prosecution and fines.
A three-year conversion period is required to achieve full organic status. In other words, no prohibited
substances may be applied to the land for 36 months prior to the harvest of any product that will be
labeled or otherwise represented as organic [§205.202(b)].
If you are purchasing or renting land that is not currently certified and you wish to document that it has
not had prohibited substances applied, you must obtain verification from the previous landowner or
manager.11
Annual inspections are part of the certification process. The inspector is an agent of the certifier. It is the
inspector’s responsibility to look for documentation and indicators that bear out the producer’s claim to
organic status, as well as to look for any violations. You must allow the inspector complete access to your
operation, including all production facilities and offices [§205.400(c)]. Additional inspections may be
announced or unannounced at the discretion of the certifier or the state organic program [§205.403(a)(2)(iii)].
Once certification has been granted, it is granted in perpetuity unless surrendered, suspended, or re-
voked. For certification to continue, annual certification fees must be paid, the Organic System Plan (see
section IV of this workbook) must be updated yearly, and previous non-compliances must be addressed
[§205.406].
Any action to suspend or revoke certification must be handled in the manner prescribed in the Standard
in §205.660–§205.664. If the status of your certification is threatened and you wish to dispute it, the
process for seeking mediation is specifically covered under §205.663. Further details of these provisions
will not be addressed in this workbook, but you should be aware that a formal grievance process exists.
Producers who market less than $5000 of organic products annually are not required to apply for organic
certification. They must, however, comply with the organic production and handling requirements of
the National Standard. The products from such noncertified operations cannot be used as organic ingre-
dients in processed products that are sold, labeled, or represented as organic by another operation; such
noncertified products are also precluded from displaying the USDA organic seal.
It is important to recognize that organic certification addresses the process involved in producing and
handling a product. Organic certification assures the consumer that the product was grown using or-
ganic methods, that harmful or dangerous pesticides, fertilizers, and genetically engineered organisms
were not used in production, and that precautions were taken to prevent contamination from the outside.
It does not guarantee that the product is completely free of all pesticide residues or GMO contamination.
(The vast proliferation of pesticides and GE crops precludes virtually everyone from making such a
claim.) Organic certification also does not ensure that the products are nutritionally superior.12
How-
ever, organic farmers and consumers firmly believe that organic food and feed is healthier, and that
organic production is better for the environment.](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-6-320.jpg)
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NCAT’s Organic Livestock Workbook:
A Guide to Sustainable and Allowed Practices
2.1 Do you have a copy of the National Organic Standard13
and/or the
standards of your certifying agency readily accessible as hardcopy or
“bookmarked” on your web browser?
2.2 Is/Are your certifier(s) accredited by the National Organic Program?
2.3 Did you advise your certifier(s) of any previous applications for certification,
including the names of the certifiers, dates of application, and the outcomes of
those applications [§205.401(c)]?
2.4 If you are updating your certification, have you addressed any and all non-
compliance issues and conditions previously noted by the certifying body
[§205.401(c)]?
2.5 Have you discussed any previous suspensions or denials of organic certi-
fication with your certifier [§205.401(c)]?
Notes on Certification
III. Overview of Organic Livestock Systems
Traditional Organic Livestock Systems. Historically, livestock have always played a key role in organic
production systems. During the formative years of the organic movement (the 1920s through the 1950s),
the typical organic farms of Great Britain, Continental Europe, and North America integrated livestock
production with the growing of both food and feed crops. Livestock provided manure, which is one of
nature’s best fertilizers and a good means for recycling nutrients within a crop rotation. Growing live-
stock feed alongside food crops diversified rotations; since forage legumes and sod-forming grasses are
among the best feeds for ruminant livestock, these soil-building crops naturally became part of long
sustainable cropping sequences. In such systems, livestock could also be fed cull vegetables, weather-
damaged crops, crop residues, “alternative” grains and forages, and cash crop grains during years of low
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-7-320.jpg)
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NCAT’s Organic Livestock Workbook:
A Guide to Sustainable and Allowed Practices
prices. Traditional organic farming systems such as
these migrated to the US and remain today. They are
common throughout the upper Midwest, with beef,
hogs, and dairy cattle as the principal livestock compo-
nents, and corn, soybeans, small grains, and hay as the
principal crop enterprises. Such traditional farms have
been the subject of much study over the past few de-
cades. When contrasted with comparable conventional
farms they were found to use less fossil fuel energy, lose
less soil to erosion, generate fewer groundwater pollut-
ants, and have less impact on global warming—all char-
acteristics of a more sustainable approach to agricul-
ture.14
In this traditional organic model as it is practiced today,
ruminant livestock have access to pasture, and confine-
ment is allowed only on a temporary basis. Non-rumi-
nants (hogs, for example) might be pastured, and vary-
ing degrees of limited and temporary confinement are
commonly used. In most instances, these traditional
models adhere easily to the National Organic Program
Regulations.
Grazing systems might also be considered traditional
organic livestock systems. Grazing systems exist in stark
contrast to conventional confinement systems where all
feedstuffs are harvested, transported, and bunk-fed to
the livestock. In grazing systems, livestock go where
the feed grows and harvest it themselves. This typically
yields savings in both energy and equipment expense.
Since most planned grazing systems are legume and
grass forage-based, they also have less erosion and lower production input costs. Because grazing sys-
tems naturally afford livestock access to the outdoors, sunlight, fresh air, and exercise, and because ma-
nure is distributed naturally, grazing systems generally have few problems complying with the NOP
Regulations. The principal challenge appears to be successful organic management of internal parasites.
While most grazing systems might be classed as traditional, noteworthy contemporary strategies include
management intensive (rotational) grazing15
and pastured poultry production.16
Alternative Organic Livestock Systems—Semi-Confined. Nontraditional models of organic livestock
production featuring limited confinement have evolved in recent years. Among these alternatives are
specialized semi-confined production systems with little or no landbase. Such systems resemble conven-
tional confinement production, but are typically less crowded and allow the livestock access to the out-
of-doors, to fresh air, and to sunlight. Semi-confined/non-landbase systems are allowed under the NOP
Regulations for non-ruminant livestock production and may be used for ruminants on a temporary basis
(see below).
A major challenge faced by semi-confined/non-landbase systems is the handling of manure. According
to the NOP Regulations, manure must be managed “in a manner that does not contribute to contamina-
tion of crops, soil, or water by plant nutrients, heavy metals, or pathogenic organisms and optimizes
recycling of nutrients” [§205.239(c)]. Production systems that do not have growing crops to fertilize must
dispose of manure in an environmentally sound manner that ensures recycling of the nutrients it con-
tains.
Text Box 3A
When Pasture is Pasture… or Not
The National Organic Standard defines pas-
ture as “[l]and used for livestock grazing that
is managed to provide feed value and main-
tain or improve soil, water, and vegetative
resources” [§205.2]. Dry lots, which have
little or no vegetation, do not meet the NOP
definition of pasture; neither does over-
grazed pastureland, since overgrazing de-
grades “soil, water, and vegetative re-
sources.” Since §205.239(a)(2) requires that
ruminants have access to pasture, the NOP
definition of pasture works to ensure that
farms and ranches not exceed the carrying
capacity of their land because the resulting
overgrazing risks damage to the natural re-
source base. It is OK to provide certified
organic green chop, hay, and other
feedstuffs, but this does not preclude the
need to provide pasture access to ruminant
stock. Certifiers and their inspector repre-
sentatives are likely to question the
certifiability of any system that maintains
more ruminant stock than can be sustained
on the available grazing acreage, under typi-
cal seasonal constraints.](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-8-320.jpg)
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NCAT’s Organic Livestock Workbook:
A Guide to Sustainable and Allowed Practices
Another major challenge for semi-confined/non-landbase systems is the acquisition of sufficient quanti-
ties and variety of organic feeds17
and bedding, since these are not produced on-farm. It is hoped that
this problem will solve itself as organic production of feed grains and hay expands nationally.
Temporary Confinement. Full confinement of livestock is allowed ONLY on a temporary basis in organic
production [§205.239(b)]. The circumstances under which temporary confinement is permitted are spe-
cific:
• to protect animals from inclement weather
• to accommodate the needs of a particular stage of production
• to ensure the health, safety, and well being of the animal
• to protect soil and/or water quality
Text Box 3B
A Pattern for Health and Sustainability
As organic agriculture moves into the mainstream of commerce and culture in the United States and
growing emphasis is placed on issues of compliance and marketing, we often lose sight of those
aspects of organics that make it attractive and worthy of pursuit. One of the most compelling aspects
is system health. It is well-known that most organic farmers and ranchers take pride in the health of
their livestock and brag openly about how much they save on veterinary costs. Health management
is not relegated solely to medical treatment of sick animals, but to the creation of a whole system that
draws from the lessons of nature and optimizes livestock welfare; a system that not only minimizes
the hazards of disease, but supports a strong natural immune response in those instances where
stress and pathogens occur.
The strategies that support this arise from an organic philosophy that traces human and animal
health back to the soil and sees it as the foundation on which a healthy system must be built (see
Figure 1 in this section). Furthermore, organic management does not seek maximum production; it
does not push livestock above and beyond the natural and healthy levels of performance. Rather,
organic husbandry seeks its payoff as a benefit from enhancing and optimizing the health of the
flock, the herd, the soil—the whole farm system. Traditional organic systems—as described in the
main text—reflect these strategies and philosophy. In the hands of good stewards, traditional or-
ganic systems are essentially healthy, though they can always be improved upon—a good example
being the integration of improved pasture grazing management.
Major problems in organic livestock production tend to appear when producers attempt to adapt
confinement livestock production to organics by merely “tweaking” the system. These folks might
meet the minimum regulatory requirements, but they will always be challenged by animal health
issues and the associated costs of treating sick livestock or sustaining high death losses.
The health of a good organic system is not only reflected in the economic sustainability of the opera-
tion, but also in its environmental sustainability. This is especially true as regards manure manage-
ment and nutrient recycling. Figuring out what to do with all that manure is much less of a problem
when the production system is land-based; there is not only a place for it to go, but all that waste
becomes valuable fertilizer.](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-9-320.jpg)
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NCAT’s Organic Livestock Workbook:
A Guide to Sustainable and Allowed Practices
3.1 Does your production system allow access to the out-of-doors, sunlight,
fresh air, and exercise space for all your livestock [§205.239(a)(1)]?
3.2 Does your production system allow access to pasture for all ruminant
livestock under usual conditions [§205.239(a)(2)]?
3.3 If you use temporary confinement, does it meet the criteria of the
National Standard [§205.239(b)]?
Notes on Livestock Systems
n/a
Yes No
n/a
Yes No
n/a
Yes No
The Organic Concept of Animal Health through the Eyes
of a Veterinarian. Adapted from Ann Wells, DVM
(NCAT), 2003. Originally adapted from Johnson, in Benson
& Zirkel’s Organic Dairy Farming, 1995.
Figure 1.
Medications
Equipment
Housing
Breeding
Water
Pastures and Grazing Management
Soil Life and Balance](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-10-320.jpg)
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NCAT’s Organic Livestock Workbook:
A Guide to Sustainable and Allowed Practices
IV. Organic System Plan
In comparison to many of the industry standards that preceded it, the National Organic Standard is
much less prescriptive—that is, it tends to characterize what an organic operation should be like in gen-
eral terms and leaves the details for producers and certifiers to work out. The principal tool for working
out such details is the Organic System Plan.
Under the National Organic Standard, each certified organic farm or ranch must have an Organic System
Plan (OSP), also referred to as the organic farm systems management plan or the organic production and han-
dling system plan. The OSP is a detailed outline that explains how you intend to operate your farm or
ranch to satisfy the requirements of the NOP Regulations. According to §205.201(a) of the National
Standard, the OSP must contain:
• a description of farm practices and procedures to be performed and maintained, including
the frequency with which they will be performed;
• a list of each substance to be used as a production or handling input, indicating its composi-
tion, source, location(s) where it will be used, and documentation of commercial availabil-
ity, as applicable;
• a description of the monitoring practices and procedures to be performed and maintained,
including the frequency with which they will be performed, to verify that the plan is effec-
tively implemented;
• a description of the record keeping system implemented to comply with the requirements
established in §205.103; (See Text Box 4A in this section.)
• a description of the management practices and physical barriers established to prevent
commingling (see Text Box 4B in this section) of organic and nonorganic products on a split
operation and to prevent contact of organic production and handling operations and prod-
ucts with prohibited substances; and
• additional information deemed necessary by the certifying agent to evaluate compliance
with the regulations.
Text Box 4A
Requirements for Recordkeeping
§205.103 deals with the requirements for recordkeeping by certified operators. The records must:
1) be well-adapted to the business being conducted,
2) disclose all activities and transactions in adequate detail,
3) be maintained for not less than five years beyond their creation, and
4) be sufficient to demonstrate compliance with federal regulations.
Your records must also be available for inspection and copying during normal business hours by
authorized representatives of the Secretary of Agriculture, the State Organic Program, and/or the
certifying agent [§205.103(c)].](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-11-320.jpg)
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NCAT’s Organic Livestock Workbook:
A Guide to Sustainable and Allowed Practices
The OSP must be written by the producer and agreed to by the certifier. It must reflect all current produc-
tion methods and all materials that will be used. Producers should use the OSP to explain and rationalize
practices they feel they need to manage effectively—especially those which may not have clear accep-
tance in the National Standard. For example, physical alterations (castration, ear notching, nose rings,
branding, beak trimming, etc.) are not provided blanket approval, though some organic producers may
have used them for years. These producers can use the OSP to make their case for such practices, explain-
ing why each practice is necessary, how it affects the animal’s welfare, and how it will be done to mini-
mize stress and suffering. The certifier can then decide whether each practice complies with the Federal
Standard.
The OSP should also address future intentions and improvements. The OSP can be a vital tool for good
organic management while ensuring compliance with the National Standard.
Should you need to deviate from the OSP that you have agreed upon with your certifier, it is imperative
that the certifier be advised [§205.406(a)(1)(i)]. It is required that you consult your certifier about planned
changes in advance [§205.406(a)(1)(ii)]. An annual update of the plan is a requirement for continuation of
certification [§205.406(a)(1)].
Text Box 4B
Coming to Terms
Contamination can be defined as contact or pollution with a prohibited substance; for example, con-
ventional pesticides, GMO pollen.
Commingling is the physical contact and possible mixing of an organic product with a similar con-
ventional product.
Transitional land is acreage that has been managed organically for less than 36 months. Because the
term “transitional” does not have legal status in the National Organic Standard, crops harvested
from transitional land may not be sold, labeled, or represented as “transitional;” neither may live-
stock that have been fed transitional feeds. The status of such crops and livestock is, for all intents
and purposes, conventional.
Split production farms are those that produce both organic and nonorganic products (nonorganic
includes transitional products).
Parallel production is essentially a subset of split production. The term is used to describe a situation
where the same crop or type of animal is produced both organically and nonorganically on the same
farm operation.
Paddock is a grazing unit in management intensive or rotational grazing systems. However, for the
purposes of this workbook, paddock will simply refer to any pasture, field, or range unit where any
form of grazing is practiced.
Grazier is the term used to refer to one who manages grazing animals. Grazer (note the slight differ-
ence in spelling) is used to describe the grazing animal itself.](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-12-320.jpg)
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NCAT’s Organic Livestock Workbook:
A Guide to Sustainable and Allowed Practices
It is standard practice for the OSP to be incorporated in the application for certification, which is required by
certifiers at the outset. In other words, you are completing your OSP at the same time you are filling out
your application for certification. In such instances, a separate System Plan document is not required.
There may also be some instances in which plans submitted to qualify for federal aid or assistance pro-
grams may satisfy the requirement for an Organic System Plan [§205.201(b)].18
An accurate map of all farm or ranch acreage and production units is typically required as part of the
OSP.19
Important map features:
• consistent scale (Farm Service Agency photo maps may be used)
• permanent field, pasture, or paddock numbers or names
• permanent housing unit numbers
• feed storage areas
• buildings, roadways, and similar features
• hydrologic features: wells, rivers, ponds, irrigation ditches, springs, major drainages, water-
ways
• field boundaries and adjoining land use
• buffer zones
• contiguous non-production areas under your ownership or management (for example, wild-
life habitat, woodlot, etc.)
Field or rangeland histories are also required as part of the OSP. Field histories should document:
• field or paddock size
• vegetation, crops and/or cover crops for current and previous years (three-year minimum)
• all inputs used for current and previous years (three-year minimum)
• field or paddock status (Organic, Transitional, Conventional) for previous years (three-year
minimum)
One of the realities of organic farming under the Federal Standard is the expected increase in the number
of operations that feature both organic and conventional production. The terms split and parallel are
commonly used to describe such farms (see Text Box 4B in this section). Many certifiers require that field
histories and other records cover conventional as well as organic management on split and parallel op-
erations. It is important that the OSP addresses all hazards of contamination and commingling that may
arise. Prior to the development of the National Organic Program Standard, a number of certifiers re-
quired that split operations have a long-term plan for full conversion to organic. There is no such re-
quirement in the National Organic Program Regulations.
4.1 Have you completed your Organic System Plan (OSP) [§205.201(a)]?
4.2 Has your OSP been approved by your certifying agent(s) [§205.201(a)]?
4.3 Is your farm or ranch map complete and accurate?
4.4 Have you completed a field/rangeland history sheet?
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-13-320.jpg)
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NCAT’s Organic Livestock Workbook:
A Guide to Sustainable and Allowed Practices
• formal notification. Written notification is provided to neighbors, utilities, and authorities
that manage adjoining lands and rights-of-way requesting cooperation to reduce contamina-
tion. You may need to assume responsibility for weed control on roadsides and rights-of-way
as part of any resulting agreement. Copies of formal notification letters must be kept on file.21
• verification of adjoining land use. A signed statement by the owner or manager of adjoining
land serves as acceptable documentation.22
The use of buffer zones has a long history in certified organic production. Traditionally, such buffers
were defined by width only, with 25 feet being the common distance specified in most certifier stan-
dards. The National Organic Program Standard does not specify the required width for a buffer zone, it
speaks only to the need to minimize contamination. Therefore, the width (and height, in some instances)
of buffers may need to be adjusted for individual circumstances, for example, a more significant buffer is
needed where adjacent land is sprayed by plane or helicopter.
If your certifier suspects that your pastures or feed crops are contaminated, residue testing may be re-
quired. If residue levels exceed 5% of the EPA tolerance levels, the feed can no longer be considered
organic [§205.671]. Note that residue testing is not an accepted substitute for buffer zones or other strat-
egies to prevent contamination. It can, however, serve as an indicator that those strategies are effective.
.
Text Box 5A
Genetic Engineering (GE) and Genetically Modified Organisms (GMOs)
Genetic engineering is considered an excluded method in the National Standard. §205.2 defines ex-
cluded methods as
a variety of methods used to genetically modify organisms or influence their growth and
development by means that are not possible under natural conditions or processes and
are not considered compatible with organic production. Such methods include cell
fusion, microencapsulation and macroencapsulation, and recombinant DNA technology
(including gene deletion, gene doubling, introducing a foreign gene, and changing the
positions of genes when achieved by recombinant DNA technology). Such methods do
not include the use of traditional breeding, conjugation, fermentation, hybridization,
in vitro fertilization, or tissue culture.
Genetic engineering is a new feature of the agricultural landscape, and the organic community is still
coming to grips with it. Clearly, organic producers are not allowed to market genetically engineered
animals as organic, and genetically engineered biopesticides, probiotics, medications, and the like
may not be used in organic production. Organic livestock feed may not be derived from GE crops.
Since genetically engineered crops are not allowed in organic crop production, organic feed, ostensi-
bly at least, is non-GMO by default. However, there is a danger of GMO contamination of organic
feed crops. At the time of this writing there are no genetically engineered forage crops on the market,
so pasture-based production is not unduly affected. Organic grains—especially corn—are the most
heavily contaminated. While this has become a serious issue in export of organic food grain products,
it is not a top-drawer concern with respect to domestic organic livestock feed at the present. That may
change in the future and producers should be aware of it. If you grow grain crops as organic feed, you
must take steps to prevent contamination. Guidelines for preventing genetic drift from GM crops to
organic fields are being evaluated.](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-15-320.jpg)
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5.1 Are all fields and paddocks well isolated or provided with buffers to
prevent contamination [§205.202(c)]?
5.2 If there is danger of contamination from adjoining land use, are you taking
steps to minimize the risk [§205.202(c)]?
5.3 Have you notified your certifier(s) of any drift or misapplications of pro-
hibitedsubstances to any field, production unit, site, facility, livestock, or
product that is part of the organic operation [§205.400(f)(1)]? If serious
drift contamination occurs, you should also contact your State Department
of Agriculture, which has (or should have) the responsibility to follow up
on such matters.23
5.4 Have you consulted your certifier to learn if there are specific requirements
for buffer zones or other matters relating to adjoining land use?
Notes on Adjoining Land Use
VI. Supporting BioDiversity
The National Organic Standard defines organic production as a production system that “respond(s) to
site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of
resources, promote ecological balance, and conserve biodiversity” [§205.2]. Aside from an additional
mention of “biological diversity” in the definition of crop rotation, the practice standards do little to
highlight biodiversity as something to be measured and monitored.
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7.1 Have you taken the time to learn about your soil resource? Do you know
its classification(s)? Erodability potential? Have you studied NRCS soil
maps?
7.2 Do you test your soils on a regular basis?
7.3 Do you keep your current and past soil test results on file and use them to
monitor the effects of your farming practices?
7.4 Do you make fertility management decisions based on soil test, tissue test,
or other nutrient test results [§205.601(j)(6)]?33
Remember, application of
concentrated micronutrients (sulfates, chelates, etc.) may be made only if
the need is documented by soil or tissue tests.
7.5 Is there little or no evidence that your forage yield or quality suffers due to
soil fertility problems?
7.6 Do you use approved cultural practices and materials to maintain or im-
prove soil organic matter/humus content [§205.205(a) and §205.203]? Al-
lowed practices and materials typically include but are not limited to the
following:
• rotational grazing and other forms of good grazing management
• animal manures34
, composts, or other organic fertilizers35
• crop rotation (in mixed crop and livestock systems)36
• cover crops and green manures (in mixed crop and livestock
systems)37
• minimizing tillage and length of time that soil remains bare
• esoteric practices (See Text Box 7A)
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Text Box 7A
What Are Esoteric Practices?
Esoteric practices are metaphysical methods for crop management and animal health that are not
generally accepted in the conventional scientific community, nor are they easily explained using
common scientific terminology. Those esoteric practices that are often applied to soil and plant
management include radionics, dowsing, the use of biodynamic preparations, and astrological plant-
ing. Most esoteric practices are allowed in organic production.38](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-20-320.jpg)
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7.7 Do you use approved cultural practices and materials to manage soil
fertility and crop nutrition [§205.205(c) and §205.203]? Allowed practices
and materials typically include but are not limited to the following:
• use of deep-rooted forage species to capture nutrients from the subsoil
• use of catch crops in mixed crop and livestock systems39
• rock mineral fertilizers and amendments40
• use of mineral-rich organic fertilizers, manures, and/or composts41
• foliar fertilization42
• esoteric practices (see Text Box 7A)
7.8 Do you use approved cultural practices and materials to provide
nitrogen to your forages [§205.205(c) and §205.203]? Allowed practices
and materials typically include but are not limited to the following:
• forage legumes in hay/pasture43
• rhizobial inoculation of legume seed
• legumes in rotation in mixed crop and livestock systems44
• livestock manures or composts45
• N-rich organic fertilizers46
7.9 Do you use approved cultural practices and materials to conserve soil and
water [§205.205(d) and §205.203]? Allowed practices typically include but
are not limited to the following:
• avoiding over- and under-grazing (See Text Box 7B)
• controlling livestock access to riparian areas
• appropriate conservation structures such as buffers, grass
waterways, and terraces
• contour cultivation and strip cropping in mixed crop and
livestock systems
• cover crops and conservation tillage in mixed crop and
livestock systems
7.10 Are you making best use of the available solar energy that reaches your farm
or ranch (see Text Box 7B)? Allowed practices that optimize the capture of
solar energy include but are not limited to:
• interseeding/overseeding annual forages
• leaving enough forage height for rapid re-growth47
• selecting forage varieties best-adapted to your region
• maintaining a diversity of forages, for example, warm- and
cool-season grasses, legumes, and forbs, etc.
• silvopasture
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Text Box 7B
Grazing as Solar Agriculture
All agriculture ultimately runs on the energy of the sun. It may be the sunlight captured today in a
growing crop through photosynthesis, or it may be the sunlight captured eons ago by primitive
plants and stored as oil, coal, or natural gas—and eventually converted to nitrogen fertilizer, pesti-
cides, and tractor fuel. Conventional agriculture is driven by reliance on the stored solar energy in
fossil fuels, causing environmental problems, increasing the vulnerability of the food system, and
spending the inheritance of future generations. Organic agriculture works to reverse the energy
equation—reducing reliance on petroleum and focusing on the use of ambient renewable solar en-
ergy.
In contrast to systems that rely primarily on grain and mechanically harvested forages, pasture-
based production is certainly much more solar-driven. Far less fuel is consumed by letting animals
do their own harvesting and manure-spreading, and pasture-based production generally requires
less imported fertilizer—much of which is energy intensive.
The challenge for the grazier is to optimize the capture of solar energy. This is exemplified through
management strategies that support densely growing forage that wastes little-to-no sunlight on bare
ground. It involves selecting forage species that keep pastures green for as long as possible through-
out the year. It also involves optimizing the use of legumes to fix nitrogen and deep-rooted broadleaves
to extract subsoil minerals as a means of reducing outside fertilizer needs.
Like all forms of organic farming, good organic grazing is very management intensive. In fact, what
is popularly called management intensive grazing (MIG) or rotational grazing is well suited to organic
systems. Fortunately, many good sources of information are available.48
7.11 Do you use allowed fertilizers and soil amendments (see Text Box 7C in
this section) [§205.105 and §205.203]?
Allowed fertilizers and amendments typically include but are not limited
to the following:49
• rock dusts; includes most mined minerals, such as aglime50
• animal by-products
• livestock manures
• composts
• plant materials and extracts
• marine products and by-products
• microbial inoculants and enzymes
• natural soluble fertilizers with restrictions:
υ potassium chloride (muriate of potash): allowed only if it is
derived from a mined source and is applied in a manner
that precludes buildup of chlorides in the soil [§205.602(g)].
Note that most commercial sources of potassium chloride
are synthetic and NOT allowed in organic production.
υ sodium nitrate (Chilean nitrate): allowed only if its use con-
stitutes no more than 20% of the crop’s total nitrogen re-
quirement [§205.602(h)].
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Prohibited fertilizers and amendments include but are not limited to the following:
x most synthetic or “artificial” commercial fertilizers, such as anhydrous ammonia, urea,
ammonium nitrate, superphosphate, ammoniated phosphates, calcium nitrate, etc.
[§205.105(a)]
x biosolids; also known as municipal waste, sewage sludge [§205.105(g)]
x most industrial by-products, especially if contaminated with heavy metals
[§205.203(d)]
x ash from manure burning [§205.602(a)]
7.12 Do you keep records of all fertilizer and amendment purchases, along with
product labels?
7.13 If you are applying manure, compost, or another acceptable fertilizer or
amendment, are you taking care to avoid contamination of surface and
groundwater [§205.203(c)]?52
Text Box 7C
What Inputs Can I Use On Organic Pastures and Range?
One of the greater difficulties that organic producers face on a regular basis is determining whether
or not a particular product or material may be used in organic production. Sad to say, the problems
are real, but some basic clarifications will help. First of all, all natural or nonsynthetic materials can
be assumed to be acceptable in organic production. There are a few exceptions, however, which will
be explained shortly.
Most organic producers and prospective producers have heard about the National List. The National
List comprises §§205.600-205.619 of the National Standard; §205.601 and §205.602 are those sections
directly pertinent to crop production, which includes forages. §205.601 includes synthetic materials
allowed in organic crop production—for example, sulfur, insecticidal soap, etc.; §205.602 addresses
natural, or nonsynthetic, materials that are prohibited, for example, ash from manure burning, nico-
tine sulfate, etc.
When considering commercial products, it is important that the grower be aware of all ingredients to
determine that none are prohibited. If a full disclosure of ingredients is not found on the label, details
should be obtained from the distributor or manufacturer and kept in the grower’s files. Note that
such details should extend to inert ingredients. When in doubt about the acceptability of any material
or product for certified organic production, contact your certifier.
An important organization to know about is the Organic Materials Review Institute (OMRI).51
OMRI
is a non-profit organization that evaluates products for suitability in organic production and process-
ing. OMRI does not have status as a regulatory body. However, its decisions with regard to the
acceptability of commercial products are highly respected and accepted by most certifiers. OMRI
Listed products can be purchased and used with a high degree of confidence. Producers should be
aware, however, that there are many acceptable products in the marketplace that have not been evalu-
ated by OMRI and do not carry the OMRI Listed seal. Again, it is important to contact your certifier to
verify whether a particular product or material can be used.
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NCAT’s Organic Livestock Workbook:
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Text Box 8A
Weed and Pest Management Decisions
§205.206—the Crop pest, weed, and disease management practice standard—requires that produc-
ers use a three-level hierarchical approach in deciding how to deal with these problems. This can
most easily be explained by designating these levels A, B, and C.
Level A: The first line of defense in managing weed, insect, and disease pests generally comprises
the most sustainable and systems-based practices. It emphasizes the fact that a well-designed and
healthy organic system will naturally have fewer pest problems.
Level A practices specifically include:
• crop rotation and nutrient management [§205.206(a)(1)]
• sanitation measures to remove disease vectors, weed seeds, etc. [§205.206(a)(2)]
• cultural practices such as resistant or tolerant varieties, timing of planting, etc.
[§205.206(a)(3)]
Level B: Level B is the second line of defense, to be chosen if the basic systemic practices of level A
are not sufficient to control the weed, insect, or disease problem. Level B practices generally include
mechanical and physical practices that are traditional in organics, and the use of nonsynthetic or
“natural” materials.
Level B weed control options include:
• mulching with fully biodegradable materials [§205.206(c)(1)]
• mowing [§205.206(c)(2)]
• grazing [§205.206(c)(3)]
• cultivation and hand weeding [§205.206(c)(4)]
• flame, heat, or electrical weeding [§205.206(c)(5)]
• plastic mulches [§205.206(c)(6)]
Level B insect/animal pest control options include:
• introducing or augmenting predators and parasites [§205.206(b)(1)]
• developing habitat for beneficial predators and parasites [§205.206(c)(2)]
• nonsynthetic lures, traps, and repellents [§205.206(c)(3)]
Level B crop disease control options include:
• management practices (for example, fire, flooding) [§205.206(d)(1)]
• application of nonsynthetic biological, botanical, or mineral inputs [§205.206(d)(2)]
Level C: Level C is the third line of defense, to be chosen if the level of pest control required is not
achieved after A and B control options are applied [§205.206(e)]. In such instances, you are allowed
the wider use of biologicals and botanicals to control pests. You also have the option to use those
materials included on the National List under §205.601—Synthetic substances allowed for use in
organic crop production.
If you anticipate the need for level C control measures, be sure that you indicate this in your OSP. Be
specific about the control materials you might be using. Outline the indicators or thresholds you
monitor that will trigger the use of those materials.](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-26-320.jpg)
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NCAT’s Organic Livestock Workbook:
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8.1 Does your production system keep weeds at manageable levels?
8.2 Do you use approved practices or materials to control weeds [§205.206]?
Allowed practices and materials typically include but are not limited to
the following:
• rotational grazing
• grazing in a timely manner
• multi-species grazing
• competitive forage types and varieties
• adjusting soil fertility, pH, etc.
• interseeding/overseeding
• higher seeding rates
• mowing/bushhogging
• allowed herbicides
• flaming59
• hand weeding or chopping
• machinery sanitation to prevent the spread of weed seed and
rhizomes
• release of biological control agents60
• use of crop rotation, nurse crops, smother crops, and cultivation
in mixed forage and row-crop production systems
• esoteric practices (See Text Box 7A)
Prohibited materials typically include but are not limited to the following:
x most synthetic herbicides [§205.105(a)]
x heavy metal herbicides
x soap-based herbicides—these may only be used in non-crop areas
of an organic farm [§205.601(b)(1)]
x micronutrient-based herbicides [§205.601(j)(6)
Notes on Weed Management
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NCAT’s Organic Livestock Workbook:
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IX. Pest and Disease Management in Pasture and Hay
Crops
Pests and diseases play a vital role in natural selection by removing sick and unthrifty plants. Organic
proponents argue that sickness in plants can be traced largely to poor nutrition and other stresses that
result from poor crop and soil management.61
Organic producers maintain that organic soil-building
practices will produce crops that are properly nourished and thereby less susceptible to attack by pests
and diseases. Furthermore, organic producers and ecologists agree that natural biological pest control
arises in a healthy organic system in the form of an active complex of natural predators and parasites that
suppress pest populations.
In actual practice, most managers of organic pasture and range rarely take additional action to control
insect and disease pests. Where organic forages are concerned, maintaining a biodiverse ecosystem and
using good fertility and cultural practices naturally keep pests and diseases from becoming a manage-
ment problem. In such systems, pests are not eliminated but damage levels are low enough to be toler-
ated. There are exceptions, of course—grasshopper plagues in the West and armyworm invasions in
humid climes are good examples of circumstances where more pest control may be required.62
High-value organic hay crops can also have special pest problems. Alfalfa weevil is a good example of a
pest that may well require additional attention.63
Insect and disease pest management is addressed in
considerable detail in NCAT’s Organic Crops Workbook; it contains information that is not duplicated here.64
The National Organic Standard requires that pest management decisions be made in a hierarchical fash-
ion. See Text Box 8A in Section 8 for details on how pest and disease control decisions must be made in
organic systems.
9.1 Does your production system keep disease and insect pests at manageable
levels?
9.2 Do you use approved practices to control plant disease and insect pests
[§205.206]? Allowed practices typically include but are not limited to the
following:
• Integrated Pest Management (IPM) monitoring65
• animal predators (birds, bats, ducks, guinea fowl, etc.)
• establishing and maintaining beneficial insect and wildlife
habitats66
• resistant and tolerant crop varieties
• sanitation
• burning
• crop rotation
• flaming
• mass trapping of insect pests
• release of beneficial insects67
• application of allowed pesticides
• esoteric practices (See Text Box 7A)
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NCAT’s Organic Livestock Workbook:
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9.3 Do you use allowed insect pest and disease control materials to manage
forage pests [§205.206]? Allowed inputs typically include but are not
limited to the following:68
• beneficial insects and other organisms69
• biological pesticides70
• botanical pesticides71
• insecticidal soaps72
• mineral-based pesticides
• pheromones
Prohibited pest and disease control materials include but are not limited
to the following:
x most synthetic insecticides, fungicides, miticides, etc. [§205.105(a)]
x heavy metal-based pesticides
x synthetic wetting agents [§205.105(a)]
x nicotine sulfate and other tobacco products [§205.602(f)]
x strychnine [§205.602(e)]
9.4 Do you keep records of all pest and disease control materials used, along
with the product labels?
9.5 If you apply natural pesticides, do you do so in a manner that minimizes risk
to non-target organisms and aquatic systems?
Notes on Insect and Disease Pest Management
X. Seeds and Planting Stock
An entire section of the Federal Regulations—§205.204—addresses seeds and planting stock in organic
production. This section is as applicable to hay and pasture crops as it is to vegetables and row crops.
The first basic rule is this: organic seeds and planting stock MUST be used for organic production.73
When an equivalent organic crop variety is not commercially available, untreated conventionally grown
seeds and planting stock may be used. See Text Box 10A for an explanation of planting stock; for clarifi-
cation of equivalency and commercial availability, see Text Box 10B.
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The second basic rule is one that has little relevance to forage systems, but needs to be mentioned any-
way. It relates to annual transplants, which MUST be organically grown for organic production.74
The third basic rule is: seeds, annual seedlings, and planting stock used in organic production may NOT
be treated with prohibited substances. There is one exception. Treatment with prohibited substances is
allowed when the application of those substances is a requirement of Federal or State phytosanitary
regulations [§205.204(a)(5)].
Conventional seed treatments are usually fungicidal; most fungicides used for this purpose are prohib-
ited in organic production. Allowed treatments include natural materials—such as biological inocu-
lants—and synthetic substances that are on the National List—such as seaweed extracts. The most com-
mon example of allowed seed treatment is the inoculation of legume seeds with rhizobium bacteria.
Since some rhizobium products can be genetically engineered or contain GE ingredients, it is important
to make that determination in advance and obtain an allowed product.
Organic growers must make certain that the seeds, transplants, and planting stock they use are not ge-
netically engineered. Purchasing these items from a certified organic producer should guarantee that the
propagation materials are not genetically modified and have a minimal degree of GMO pollen contami-
nation.
There is a particular provision in the Seeds and Planting Stock standard that may be relevant to you,
especially if you establish or interplant any of your fields with perennial planting stock. Examples of
perennial planting stock include grass sprigs, root pieces, and tree seedlings. §205.204(a)(4) reads
“[n]onorganically produced planting stock to be used
to produce a perennial crop may be sold, labeled, or rep-
resented as organically produced only after the plant-
ing stock has been maintained under a system of organic
management for a period of no less than 1 year…” The
popular interpretation of this section has been that pe-
rennial planting stock may be obtained from nonorganic
sources, but it must be under organic management for
twelve months before the first harvest of an organic crop.
This interpretation is consistent with many organic cer-
tifier standards prior to federal regulation. If you read
this provision carefully, however, it suggests an alter-
nate interpretation. The alternative interpretation is that
the twelve-month requirement applies to the sale of pe-
rennial planting stock, not to its use once it has been
placed in production. In other words, it is possible that
this provision is pertinent to nursery production and
not to the production of fruits, nuts, produce, or forage.
The way your certifier chooses to interpret §205.204(a)(4)
of the Standard can have implications if you are estab-
lishing a Bermuda grass pasture, interplanting comfrey
as a forage plant, or establishing an agroforestry sys-
tem—especially one with forage trees such as locust. In
many of these examples, there is a lag time of one year
or more to allow for establishment, which removes much
of the concern. However, the question of whether you
Text 10A
About Planting Stock
The National Organic Standard lumps
plant propagation materials into three ba-
sic categories: seeds, annual seedlings, and
planting stock. Seeds is self-explanatory.
Annual transplants are seedlings of annual
crops that have been removed from their
original place of production and replanted
elsewhere [§205.2]. Planting stock is defined
as “[a]ny plant or plant tissue other than
annual seedlings but including rhizomes,
shoots, leaf or stem cuttings, roots, or tu-
bers, used in plant production or propaga-
tion [§205.2].” The most likely example of
planting stock you might use in pasture or
hay production is sprigs. Sprigs are clumps
of stolons or rhizomes that are used to veg-
etatively propagate certain grasses—espe-
cially some warm-season species like Ber-
muda grass.](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-30-320.jpg)
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need to seek an organic source for perennial planting stock and document that search remains. Be certain
to contact your certifier in advance of purchasing perennial planting stock to learn in full detail what
your constraints might be.
10.1 Is all seed used either:
• organically produced and/or
• conventionally produced, non-GMO seeds that have NOT been
treated with prohibited substances [§205.204(a)]?
10.2 Are only NON-genetically engineered seeds and planting stock used
[§205.105(e)]?
10.3 If seeds and sprigs are produced on-farm, are they grown using organic
methods and approved inputs [§205.204(a)]?
10.4 Where pasture is being established using perennial planting stock, such as
sprigs, have you determined what your certifier requires with regard to
sourcing [§205.204(a)(4)]?
Text Box 10B
Equivalency and Commercial Availability
Equivalent variety is generally understood to mean a cultivar of the same type and similar plant
characteristics when compared to the original preferred variety. For these purposes, type refers to
the basic plant type (for example, there is a type of soybean called a haybean that is harvested as a
forage. This is different from the standard food type and feed type of soybean that most farmers are
familiar with); characteristics refers to factors such as color, pest resistance, and maturation.
According to the National Organic Standard, an equivalent variety of seed or planting stock would
be considered commercially unavailable if you could not locate an organic supplier. It might also be
considered commercially unavailable if the organic supplier could not provide you with the quan-
tity of seed you need, or if the available seed quality is substandard. Factors that might make seed
quality substandard include the presence of seed-borne disease, very low germination percentages,
high noxious weed seed content, and the like. The higher cost of organic seed and propagation
materials is NOT considered an acceptable reason for using nonorganic seed or planting stock.
Ultimately, the certifier must make the final decision on whether the use of nonorganic seed or
planting stock is justified. You will need to present ample documentation to support any use of
nonorganic seed, including a record of your attempts to locate organic seed sources. This usually
entails making a record of phone calls, letters, or e-mails to and from seed suppliers documenting
attempts to find an organic source. Most certifiers want clear indication that you have contacted at
least three suitable suppliers.75
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-31-320.jpg)
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NCAT’s Organic Livestock Workbook:
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10.5 Do you retain documentation of all seeds, seed treatments (including
rhizobial inoculants), and planting stock purchases?
10.6 Do you keep seed tags and empty packets on file?
10.7 If seed or plant treatments are used, have you determined that they are
allowed and not genetically modified [§205.105(e)]? It is advisable to re-
tain all documentation that proves a substance is allowable in organic pro-
duction.
Notes on Seed and Planting Stock
XI. Field Equipment
Equipment used for pasture management and for hay production and hauling must not be a source of
contamination or a means by which organic and conventional products are commingled.
11.1 If harvesting, hauling, and crop handling equipment is also used for
conventional crops, are cleanout protocols established and cleanout
logs maintained?
11.2 If split or parallel production is done, is separate spraying equipment
designated and clearly marked?
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-32-320.jpg)
![Revised February 2004 Page 34
NCAT’s Organic Livestock Workbook:
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XII. Hay and Haylage Harvest
Conventional hay harvesting sometimes involves the use of materials that might not be accepted in or-
ganic production. Some preservatives and mold inhibitors, for example, may be prohibited in organic
production. Individual products should be checked to determine whether they are natural (nonsynthetic)
or are listed as an allowed synthetic input (See §205.601 of the National Standard for the list of allowed
synthetics). Use of fungicide-treated twine might be prohibited; check with your certifier.
12.1 Are you harvesting your forages at an optimum stage to ensure high feed
quality and continued viability of the stand? This question concerns good
overall management and is not related to organic certification. Many pro-
ducers sacrifice forage quality for quantity by harvesting when the crop is
too mature.
12.2 If harvest-aid products are used, are they approved for organic production
[§205.105]?
Notes on Hay and Haylage
XIII. Monitoring Your Pasture’s Performance
The following questions highlight several indicators that can help you determine how well your organic
management system is functioning; they can be reviewed annually and used to monitor your progress.
Also included are additional questions that address special environmental concerns.
13.1 Does your pasture consist predominantly of desirable, well-adapted
legumes, forbs, and grasses?
n/a
Yes No
n/a
Yes No
n/a
Yes No](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-34-320.jpg)
![Revised February 2004 Page 35
NCAT’s Organic Livestock Workbook:
A Guide to Sustainable and Allowed Practices
13.2 Are your forages usually at or near their optimum quality when you graze
or harvest them? It is undesirable (and unprofitable) for pasture species
to become rank and overly mature. Over-mature plants are not only
low-quality livestock feed, they tend to shade out new seedlings, particularly
clover, leading ultimately to bare ground between plants. (See Text Box 15A
in Section XV of this workbook.)
13.3 Are your pastures generally free of subsurface compaction?76
Unless the
pasture is located in a natural wetland, standing water is often an indicator
of subsurface compaction.
13.4 Are your organic matter/humus levels stable or increasing [§205.203(c)]?77
13.5 If used, are tillage operations becoming easier under organic management
from year to year?
13.6 Are earthworms and earthworm burrows evident in the soil?78
There are
some circumstances where earthworms will not be found, even in well
managed soils. Soils that routinely flood in spring, very arid soils, and
some heavily glaciated soils in the northern tier of states may not have
earthworms.
13.7 Does your soil emit a rich, earthy smell when tilled or dug?
13.8 Is dung beetle activity evident?79
Dung beetle activity should be vigorous
on well-managed, organic permanent pastures and range. Less activity will
be seen on pastures that are part of a mixed crop rotation, because tillage
disrupts the life cycle of this insect. However, dung beetles are mobile and
should still be active on rotation pasture. Note: the synthetic worming
agent, ivermectin—allowed in organic production on a limited and
emergency basis—is especially harmful to dung beetles [§205.603(a)(12)].
Where native dung beetle populations have been wiped out, they may be
replenished with commercially available species.
13.9 Are your forages free of nutrient deficiencies under average conditions?
Symptoms of nutrient deficiencies include chlorosis (yellowing), other
discolorations of the leaves and stems, stunted growth, and consistently
low yields.
13.10 Are your livestock free of disease conditions caused by excess soil nitrogen?
Problems that may be caused or worsened by excessive nitrogen fertilization
include grass tetany,80
prussic acid poisoning,81
nitrate toxicity,82
and fescue
toxicity in high-endophyte fescue.83
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-35-320.jpg)
![Revised February 2004 Page 36
NCAT’s Organic Livestock Workbook:
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13.11 Are your livestock free of disease conditions caused by deficiencies or im-
balances of mineral nutrients? Some problems that may occur include grass
tetany, which can be brought on by imbalances of magnesium and potas-
sium as well as by excess nitrogen.
13.12 Is there an abundance of beneficial predatory and parasitic insects (lady
bugs, lacewings, mantids, small wasps, etc.) under normal conditions?
13.13 Is erosion controlled on all your fields, paddocks, and access lanes
[§205.203(a)]?
13.14 Are the riparian areas (stream banks) on your farm or ranch stabilized and
protected?84
13.15 Are natural wetlands on your farm or ranch protected?
13.16 Are waterways on your farm or ranch protected from livestock and live-
stock wastes [§205.239(c)]? It is a good idea to use fencing and water tanks
to restrict stock from fouling natural streams.
Notes on Pasture Performance
XIV. The Organic Approach to Livestock Health
The basic strategy to sustain livestock vitality in organic systems is the same as in crop production—that
is, to identify and optimize those elements and conditions in nature that support health. Essentially,
there are three elements that must be provided: optimum nutrition, low stress living conditions, and a
reasonable level of biosecurity. There are a number of key ways in which these three elements are
expressed in organic practice—especially in mixed production and pasture-based systems. These in-
clude:
n/a
Yes No
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Yes No
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Yes No
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Yes No
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Yes No](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-36-320.jpg)
![Revised February 2004 Page 37
NCAT’s Organic Livestock Workbook:
A Guide to Sustainable and Allowed Practices
• Providing balanced nutrition. This is reflected in the National Organic Program Regulations
requiring organic feed [§205.237(a)]. Just as organic proponents argue that organic food is
healthier for people, they likewise maintain that organic feed is healthier for animals. In
mixed crop and livestock systems, the requirement for crop rotation results in a rich diversity
of feeds. Similarly, in organic pasture-based systems, the absence of synthetic nitrogen fertil-
izers encourages the growing of legumes alongside grasses, and the absence of synthetic her-
bicides allows the growth of mineral-rich forbs; these contribute to the diversity of livestock
diet. Note that artificial feedstuffs like synthetic urea are explicitly prohibited in organic pro-
duction because they are found to be unhealthy for the animals.
• Restricting exposure to toxins. Restricting toxin exposure is another reason for requiring
organic feed. Residual pesticides and their breakdown products are additional sources of
stress on livestock health—particularly to the liver, kidneys, and other systems responsible
for eliminating poisons.
• Excluding performance enhancers. Synthetic hormones and antibiotics are not allowed in
organic production [§205.238(c)(3) and §205.238(c)(1)]. They are viewed as food contaminants
by the organic community, and there are concerns over the development of antibiotic-
resistant pathogens. These inputs push livestock to unnatural performance levels and mask
the effects of unhealthy production systems.
• Providing healthy and “natural” living conditions. [§205.239(a)] Living conditions are espe-
cially important to livestock health. Buildings and facilities that are overcrowded, unsani-
tary, lacking in fresh air movement, or are otherwise stressful to animals invite disease and
injury. Living conditions for livestock must:
! permit livestock to exercise and to exhibit natural behaviors
! allow access to the outdoors
! provide access to pasture for ruminants
! offer animals protection from severe weather
! be safe and sufficiently sanitary
! not cause pollution
• Avoiding excessively stressful management practices. All forms of stress increase suscepti-
bility to injury and disease. Good organic managers strive to limit stressful handling of ani-
mals as much as possible. This also applies to physical alterations—castration, ear notching,
beak trimming, branding, etc. See Section XVIII of this workbook for more information on
physical alterations.
• Preventive practices. Good organic livestock management also involves the use of standard
preventive practices, including sanitation, vaccinations, feeding of probiotics, quarantine of
sick and newly purchased animals, and other biosecurity precautions to prevent difficult pest
and disease problems from infecting organic stock.
Your OSP should reflect a holistic health management plan that uses these principles and measures as a
foundation. You must also indicate what practices, procedures, and materials will be used to deal with
those animals that do become ill. These options are discussed in Section XIX of this workbook, “Treat-
ment of Sick or Injured Livestock.”
Finally, one aspect of organic animal health seldom discussed is the relationship between type and breed
of livestock and its suitability for organic production in given climates and circumstances. The National
Organic Standard addresses this concern in §205.238(a)(1). This section requires that producers choose
livestock species and types suited to the site-specific conditions of the farm and those with natural resis-
tance to prevalent diseases and parasites.](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-37-320.jpg)
![Revised February 2004 Page 39
NCAT’s Organic Livestock Workbook:
A Guide to Sustainable and Allowed Practices
The National Organic Program Regulations allow one exemption to the 100% feed requirement—if an
entire, distinct dairy herd is under conversion to organic management, producers are permitted to feed
up to 20% conventional feedstuffs for the first nine months of the transition, followed by 100% organic
feed thereafter. See Section XXIII of this workbook for more details.
The National Standard does not address the quality of water provided to livestock. However, it goes
without saying that adequate quantities of clean water are essential to livestock health and to good pro-
duction. One particular concern is excessively high nitrates—a growing problem in groundwater sources—
that can cause reproductive problems.86
15.1 Do your livestock graze only certified organic pastures or rangelands
[§205.237(a)]?
15.2 Are all farm-produced feeds and forages certified organically grown
[§205.237(a)]?
15.3 Are all purchased feeds and forages certified organic [§205.237(a)]?
15.4 Are all your feed supplements and additives allowed in organic production?
The following are specifically prohibited as livestock feed or feed supplements:
x animal drugs and synthetic hormones [§205.237(b)(1)]
x plastic pellets [§205.237(b)(3)]
x urea [§205.237(b)(4)]
x manure (including poultry litter) [§205.237(b)(4)]
x slaughter by-products (including bone meal, blood meal, feather meal) [§205.237(b)(5)]
x excessive amounts of feed supplements or additives [§205.237(b)(2)]87
x synthetic amino acids
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
Text Box 15 B
What Inputs Can I Use in Organic Livestock Production?
The constraints on inputs for organic livestock production are similar to those for pastures and crops
(see Text Box 7C). Natural (or nonsynthetic) materials can be assumed to be allowed. Exceptions
will be discussed shortly.
§205.603 of the National Standard is that portion of the National List that deals with synthetic sub-
stances allowed for use in organic livestock production. §205.604 deals with natural (or nonsynthetic)
substances prohibited for use in organic livestock production. §205.603 is a fairly lengthy and de-
tailed list, which has a large number of individual entries; at the time of this writing, §205.604 only
lists strychnine—a botanical—as prohibited.
A few terms in the National List should be clarified. Feed supplements—one sub-category of allowed
synthetics—refers to “[a] combination of feed nutrients added to livestock feed to improve the nutri-
ent balance or performance of the total ration and intended to be: (1) Diluted with other feeds when
fed to livestock; (2) Offered free choice with other parts of the ration if separately available; or (3)
Further diluted and mixed to produce a complete feed” [§205.2]. Feed supplements are considered
different from feed additives, which are defined as “…substance[s] added to feed in micro quantities
to fulfill a specific nutritional need; i.e., essential nutrients in the form of amino acids, vitamins, and
Continued on page 40](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-39-320.jpg)
![Revised February 2004 Page 40
NCAT’s Organic Livestock Workbook:
A Guide to Sustainable and Allowed Practices
15.5 Do you retain all feed tags and feed purchase records?
15.6 Do you retain all purchase records and labels from feed supplements
and additives?
15.7 Do you have a backup plan in case of an on-farm feed shortage emergency,
and is it outlined in your Organic System Plan? It is a good idea to include
the names of feed brokers you would contact should the need arise.
15.8 Do your livestock have free access to fresh, clean water?
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
Text Box 15B continued
and minerals” [§205.2]. At the time of this writing, the only feed supplement listed is conventional
milk replacer. The accompanying annotation indicates that replacers are for emergency use only
and must not contain antibiotics, non-milk products, and may not come from livestock treated with
bovine somatotrophin (BST), a.k.a. bovine growth hormone (BGH) [§205.603(c)]. To our knowledge,
no organic milk replacers are currently on the market and the restrictions in the annotation eliminate
most conventional products. Therefore, it is obvious that the intent of this provision is to discourage
use of milk replacers and to encourage the feeding of whole organic milk from the herd or flock.
Allowed feed additives, at this time, include several trace minerals and vitamins; no synthetic amino
acids have yet been listed. An issue of special interest to the organic poultry community is the status
of one particular feed additive, the synthetic amino acid methionine. Synthetic methionine has his-
torical use in non-pasture based organic poultry production prior to the implementation of federal
regulation. Supplemental methionine is not generally needed for the production of range- or pas-
tured poultry in which the birds can balance their nutritional needs with insects, worms, and other
wild foods that are naturally rich in this amino acid. In October 2003, the National Organic Program
amended the National List, ruling that synthetic methionine may be used in organic poultry only
until October 21, 2005 [§205.603(d)(1)]. This sunset provision was recommended by the National
Organic Standards Board to allow producers time to find alternative natural sources before the com-
plete ban on synthetic methionine goes into effect.
Organic livestock producers can expect a considerable degree of confusion with regard to allowed
synthetics—much more, in fact, than they will see with organic crop production. It is critical that
you work closely and establish good lines of communication with your certifier. This begins with
the development of a clear and detailed OSP, in which you outline all of the inputs you might use in
all anticipated circumstances.
It is also helpful for you to know about the Organic Materials Review Institute (OMRI).88
See Text
Box 7C for a description of OMRI.](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-40-320.jpg)
![Revised February 2004 Page 41
NCAT’s Organic Livestock Workbook:
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XVI. Livestock Living Conditions, Facilities, and Handling
According to the Regulations, organic livestock producers must establish and maintain living conditions
that accommodate the health and natural behavior of their animals. The requirements reflect concerns
for animal welfare and sustainability of production as well as for environmental quality. The means
used to meet these requirements appear to be flexible at this time and accommodate a wide range of
production philosophies.
While adjustments may be made to accommodate stage of production, climatic conditions, and the envi-
ronment, the Regulations [§205.239(a)(1)] require that all livestock have access to:
• outdoor areas
• shade
• shelter
• space for exercise
• fresh air
• direct sunlight
Shelter must be designed to allow animals
• opportunity to exercise [§205.239(a)(4)(i)]
• protection from temperature extremes [§205.239(a)(4)(ii)]
• adequate ventilation [§205.239(a)(4)(ii)]
• comfort behaviors [§205.239(a)(4)(i)]
• natural grooming and maintenance [§205.239(a)(4)(i)]
• a low-hazard environment to prevent injury [§205.239(a)(4)(iii)]
• bedding as appropriate to the species; must be organic if typically consumed [§205.239(a)(3)]
Full confinement of livestock is permitted on a tempo-
rary basis only. The circumstances that permit tempo-
rary confinement of organic livestock are:
• inclement weather [§205.239(b)(1)]
• specific health and safety needs of the
animal [§205.239(b)(3)]
• risk to soil or water quality [§205.239(b)(4)]
• the animal’s stage of production
[§205.239(b)(2)] (see Text Box 16A)
NOP requirements for living conditions highlight a
number of conflicts with practices in use before federal
organic standards were in place. A good example is
the use of hoop houses for swine production. This al-
ternative production system, which originated in Swe-
den, is noted for being exceptionally humane. It does
an exceptional job of allowing natural behavior while
providing good sanitation and protection from severe
weather. The drawback of this system—from an or-
ganic perspective—is that current designs do not al-
low for outdoor access.89
There is also a clash with some conventional biosecurity
concerns. The most notable conflict involves outdoor
Text Box 16A
Temporary Confinement for Stage of
Production
An example of stage of production con-
finement would be the final finishing of
beef cattle. The National Organic Stan-
dards Board recommends a finish stage of
no more than 120 days of confinement. It
is interesting to note, however, that re-
search has shown that beef cattle can be
fattened in a confinement-free pasture en-
vironment if high-energy grain is provided
to them—cattle typically prefer grain to
forages. Producers might also consider
that there is a growing market for grass-
finished beef, which uses no supplemen-
tal grains. Producing high-quality grass-
finished beef requires excellent grazing
management, however. Be sure to do your
homework in advance.](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-41-320.jpg)
![Revised February 2004 Page 43
NCAT’s Organic Livestock Workbook:
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16.1 Are all your livestock given access to the out-of-doors, fresh air, sunlight,
space to exercise, and shelter from inclement weather [§205.239(a)(1)]?
16.2 Are all your livestock provided with sufficient quantity and quality of feed
and water to meet their health and welfare needs [§205.238(a)(2)]?
16.3 Are all your ruminant stock provided with pasture [§205.239(a)(2)]?
16.4 Do you feed hay or other feeds to ruminants when pasture or range forage
is not available [§205.238(a)(2)]? Allowing animals to starve in order to save
on costs or to preserve organic status is not allowed.
16.5 Do your animals on pasture or range have access to some form of protection
from severe weather [§205.239(a)(1)]?
16.6 Are all wooden livestock buildings, corrals, handling facilities, fence posts,
gateposts, board fencing, etc., constructed either with untreated wood or
with other allowed materials [§205.206(f)]? If prohibited materials are
present in older buildings, they must not present a contamination hazard.
Prohibited materials may be used in circumstances where they cannot
contaminate organic agricultural soil or livestock.
16.7 Do you use allowed materials and processes92
to control structural pests
in livestock production buildings [§205.271(c) and §205.271(d)]? See Text
Box 16B.
n/a
Yes No
n/a
Yes No
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Yes No
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Yes No
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Yes No
n/a
Yes No
n/a
Yes No
Continued on page 44
Text Box 16B
Structural Pest Management Decisions
Structural pests include a wide range of organisms that can damage structures, such as termites; use
structures as habitat and a food source, like mice and grain weevils; or exploit the structural environ-
ment to infect or infest another host animal, as mites and lice do. Like pasture weed, pest, and
disease management, you are required to use a multi-level hierarchical approach in deciding how to
deal with structural pests. In this case, there are four levels, which will be referred to as A, B, C, and
D.
Level A: The first line of defense generally comprises preventive measures.
These Level A practices specifically include:
• removal of pest habitat, food sources, and breeding areas [§205.271(a)(1)]
• prevention of pest access [§205.271(a)(2)]
• management of environmental factors [§205.271(a)(3)]](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-43-320.jpg)
![Revised February 2004 Page 44
NCAT’s Organic Livestock Workbook:
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16.8 Do you provide adequate bedding for temporary- and semi-confined live-
stock when and where needed [§205.239(a)(3)]? Note: in circumstances
where livestock typically consume a portion of the bedding, the bedding
materials must be certified organic.
16.9 Do you store prohibited materials where they pose no danger of contami-
nation to livestock?
16.10 Is housing cleaned and manure removed often enough to protect livestock
health [§205.238(a)(3)]?
16.11 Do you use allowed materials to clean and sanitize housing units
[§205.271(c) and §205.271(d)]?
16.12 Is your feeding equipment adequately maintained and cleaned to prevent
injury to livestock and to prevent the spread of disease?
16.13 Are your watering systems adequately maintained and sanitized for the
purpose of preventing disease or the spread of disease?
Text Box 16B continued
Level B: Level B is the second line of defense, to be chosen if the preventive practices of Level A are
not sufficient to control pests. Level B practices generally include mechanical and physical practices.
Level B practices include:
• traps, light, sound, and similar physical controls [§205.271(b)(1)]
• natural and allowed synthetic lures and repellents [§205.271(b)(2)]
Level C: Level C is the third line of defense, to be chosen if the level of pest control required is not
achieved after A and B control options are applied [§205.271(c)]. In such instances, you are allowed
the wider use of nonsynthetic and allowed synthetics provided for on the National List.
Level D: In the event that pest control actions A, B, and C do not adequately prevent or control
facility pests, a synthetic substance not on the National List may be applied PROVIDED THAT the
producer and the certifier agree on the substance, method of application, and measures to be taken to
prevent contact with organic livestock, feed, or other organic products [§205.271(d)]. If Level D
action is taken, you must update your OSP to reflect the application, how it was made, and the
contamination control measures used [§205.271(e)].
If use of a prohibited pesticide is required by federal, state, or local laws or regulations, this does not
compromise your organic status as long as measures are taken to prevent contamination of the live-
stock, livestock feed, and other organic products [§205.271(f)].
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-44-320.jpg)
![Revised February 2004 Page 45
NCAT’s Organic Livestock Workbook:
A Guide to Sustainable and Allowed Practices
16.14 Do you use allowed materials and processes to clean watering and feeding
systems [§205.271(c) and §205.271(d)]?
16.15 If livestock must be transported long distances, are they provided with feed
and water en route?
16.16 When moving, working, or otherwise handling your livestock, do you use
methods that minimize stress to the animals?
16.17 Do you have a strategy for disposal of dead livestock that does not pose
a health risk to other livestock, contaminate organic products, or
pollute the environment [§205.238(a)(3)]? 93
Organic producers need to
understand and follow state regulations regarding dead animal disposal.
Composting is a desirable option in areas where it is permitted.
16.18 Are your production buildings and areas adequately protected from
pesticide drift and/or infiltration by contaminated runoff water?
16.19 Are plastics and other wastes from the operation properly disposed of
to prevent contamination or livestock health problems? See Text Box 16C.
16.20 Is all water runoff from production areas controlled or contained so that it
does not contaminate surface waters or cause soil erosion [§205.239(c)]?
16.21 If you produce organic and conventional animals, do you segregate the animals
or use some form of identification to ensure that commingling does not occur?
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
Text Box 16C
Recycling and Waste Management
Though it strives to be more environmentally friendly, organic farming, like conventional farming, will
still generate waste materials that cannot be recycled on-farm. Common examples include plastic bale
wrappers and natural pesticide containers. Recycling is the preferred option for plastic, aluminum,
and glass wastes; landfilling should be used if recycling is not an option.
Burning of plastics is strongly discouraged. If you must burn plastics, be certain that you do not burn
them with wood or other materials that you plan to return to the field. Ash that has been contaminated
with plastics is prohibited in organic crop production [§205.203(d)(4)].
n/a
Yes No
n/a
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NCAT’s Organic Livestock Workbook:
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16.22 Do you use organically approved methods and materials to manage weeds
around facilities and buildings? Allowed practices and materials typically
include but are not limited to the following:
• thermal weeding (for example, flaming)
• hoeing or hand-pulling
• mowing/string trimming
• herbicidal soaps [§205.601(b)(1)]
16.23 Are your buildings and production lots numbered and records maintained
that document management history?
Notes on Livestock Facilities
XVII. Manure Management
Manure is one of the most valued fertilizers on an organic operation. Capturing the full value of manure
requires attention to how it is collected, stored, and spread on the field. This workbook section will focus
on matters that relate to collection and storage. NCAT’s Organic Crops Workbook and other ATTRA pub-
lications address its use as a fertilizer and soil amendment.94
National Organic Program Regulations state that organic producers “must manage manure in a manner
that does not contribute to the contamination of crops, soil, or water by plant nutrients, heavy metals, or
pathogenic organisms and optimizes recycling of nutrients” [§205.239(c)]. This has implications not only
for how manure is applied to the field, but also for how it is handled and stored prior to spreading.
Contamination is not the only issue. Unless properly handled, manure can also be a health issue for
livestock and humans. Accumulating manure can breed flies, generate high levels of ammonia gas, and
spread disease.
The Regulations do not specify handling procedures, only that the system used not compromise organic
integrity. Therefore, in theory and in fact, you have a number of alternatives for how you may manage
manure.
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NCAT’s Organic Livestock Workbook:
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Composting is one of the most reliable and time-honored means of conserving and recycling manure
nutrients and is highly recommended for organic farming. It stabilizes the nutrients in manure, protect-
ing them against volatilization and leaching. At the same time, it aids in the control of plant and animal
diseases, flies, and weeds.95
Should you choose to compost your manure, there are a few constraints you should know about if you
intend to sell compost to other organic producers or plan to use it yourself in the production of food
crops. §205.203(c)(1) of the Regulations places strict limitations on how and when raw uncomposted
manure can be applied. Uncomposted manure may not be used on food crops less than 120 days prior to
harvest if the edible portion has contact with the soil; it may not be used less than 90 days before harvest
on food crops where the edible portion does not have soil contact. Composted manure does not have
these restrictions; however, the National Standard is very specific in its definition of compost.
For compost to meet National Organic Program specifications, the initial carbon:nitrogen ratio of the
beginning compost feedstocks must be between 25:1 and 40:1. A temperature between 131º F and 170º F
must be maintained for 3 days when using an in-vessel or static aerated pile system. The temperature
must be maintained between 131º F and 170º F for 15 days when using a windrow composting system;
during that 15 days, the materials must be turned a minimum of five times [§205.203(c)(2)].
Further restrictions on compost-making also apply. These relate to the addition of other feedstock mate-
rials. Allowed materials include bedding, food wastes, ground rock powders, Biodynamic™ prepara-
tions, and those materials otherwise allowed as organic fertilizers or soil amendments. Materials that
may NOT be added to the compost pile if it is to be used in organic production include most synthetic
fertilizers [§205.105(a)], biosolids (sewage sludge) [§205.105(g)], pesticide-contaminated materials
[§205.203(c)], materials contaminated with heavy metals [§205.203(c)], and plastics [§205.203(e)(1)].
No matter what system of manure management you elect to use, be certain that you do not use any
prohibited materials in the process. Two specific examples can be cited. If you are using a barn lime or
other rock powder to absorb and deodorize animal wastes, be aware that hydrated lime is specifically
prohibited in §205.603(b)(3); superphosphate is also prohibited [§205.105(a)]. In conventional lagoon
systems, stabilizing chemicals are frequently added. Be certain you are using an allowed stabilizer for
organic management. Consult your certifier when in doubt.
Controlling manure flies is another issue. The great majority of synthetic insecticides and synthetic in-
secticidal baits are prohibited in organic production. Good sanitation procedures, composting, and some
common sense management can go a long way in reducing the manure fly problem. These fundamental
steps can be backed up with biological and allowed insecticidal controls. Refer to Text Box 16B for guid-
ance in how to make decisions for controlling these pests.
17.1 If manure is stockpiled or lagoon-stored, do you take measures to avoid
leaching and contamination of surface waters[§205.239(c)]?
17.2 If a lagoon system is used to store manure, is the capacity of your system
sufficient to eliminate the hazards of dike failure or overflow during heavy
rains[§205.239(c)]?
17.3 Is your production facility, including all lots and pens, managed to prevent
contamination of ground and surface waters by manure leaching and runoff
[§205.239(c)]?
n/a
Yes No
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Yes No
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NCAT’s Organic Livestock Workbook:
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17.4 Do you use organically acceptable means to control manure-breeding flies
[§205.105(a)]? Allowed options include but are not limited to:
• sanitation
• manure composting
• odor management
• parasitic wasps, hister beetles, beneficial nematodes, or other
introduced biological controls96
• flying insect traps97
• diatomaceous earth
• botanical pesticides
17.5 Do you use organically acceptable means for odor management
[§205.105(a)]? Allowed options include but are not limited to:
• manure composting
• microbial inoculants (source must be GMO-free)
• botanical extracts
• manure drying
• rock powders
17.6 If you produce and stockpile compost, do you take precautions to ensure
that surface and groundwater contamination does not occur[§205.239(c)]?
17.7 Do you keep your compost free from contamination by prohibited
substances?
17.8 If you use your compost for food crop production or sell it to other organic
producers, do you keep compost production records that include daily tem-
perature readings and frequency of windrow turnings?98
Notes on Manure Management
n/a
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Yes No
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NCAT’s Organic Livestock Workbook:
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XVIII. Physical Alterations
Physical alterations refer to irreversible procedures that alter the natural appearance or function of ani-
mals. They are typically used for five reasons in livestock management:
1) for purposes of identification, for example branding, tattooing, ear tags, ear notching
2) to prevent injury from fighting or cannibalism among animals, for example debeaking,
dehorning, tail clipping, castration
3) to prevent damage to pastures, for example nose rings in hogs
4) to improve product quality and marketability, for example castration, caponization; and
5) for livestock health, for example tail docking in sheep.
According to the National Organic Standard, physical alterations are permitted “as needed to promote
the animal’s welfare.” Convenience for the producer should not be construed as “animal welfare.” For
example, the docking of tails on dairy cattle may serve the convenience of the dairyman by removing the
irritation occasioned by being slapped in the face by a wet tail. However, a cow’s tail has definite pur-
pose in fighting off flies and its removal is not likely to be in the animal’s best interests.
A further requirement of the Organic Standard is that physical alterations be done “in a manner that
minimizes pain and stress” [§205.238(a)(5)]. For example, it is desirable to castrate male calves at a very
young age, as opposed to later in life when the pain and stress is much greater. Another example is the
use of freeze branding using dry ice, which is considered more humane than fire branding using electri-
cally- or fire-heated metal. 99
Since the Regulations are not specific about which practices are and are not acceptable, there is no consis-
tent agreement among certifying bodies (or even among animal welfare advocates) as to what alterations
should be allowed. If you are planning to use any physical alterations on your livestock, clearly outline
in your OSP WHAT you plan to do, HOW you plan to do it, and WHEN it will be done. Be especially
clear in explaining WHY you plan to do the alteration. These alterations should be justified in the plan
with regard to their necessity for livestock welfare, product quality, and audit control. It is also wise to
indicate whether the planned alterations will be a routine practice or a contingency in the event of ex-
treme animal behavior. You are strongly advised to confer closely with your certifier to determine what
is and is not an acceptable practice for your operation.
18.1 Have you discussed all planned and contingency physical alterations with
your certifier and outlined them in your OSP?
18.2 Are you selecting physical alteration methods and performing them in a
manner that causes the least amount of pain and stress to your animals
[§205.238(a)(5)]?
Notes on Physical Alterations
n/a
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NCAT’s Organic Livestock Workbook:
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XIX. Treatment of Sick or Injured Livestock
Despite the best efforts of organic management, some livestock will inevitably get sick or injured and
require treatment. At the time of this writing, many routine veterinary medicines—most notably antibi-
otics—are prohibited. Animals treated with prohibited medications cannot be sold as organic. This
sometimes leaves the producer in a quandary—should an animal be treated at the cost of its organic
status, or should one gamble on hopes of recovery without treatment, even if the animal suffers? In fact,
the National Organic Regulation does not allow you that choice—§205.238(c)(7) states that the producer
of organic livestock must not “[w]ithhold medical treatment from a sick animal in an effort to preserve its
organic status. All appropriate medications must be used to restore an animal to health when methods
acceptable to organic production fail…”
Because few conventional medications are allowed, organic producers have been encouraged to explore
complementary and alternative veterinary medicine (CAVM)100
treatment options, such as herbalism,
homeopathy, radionics, acupuncture, chiropractic, and other non-traditional modalities. CAVM treat-
ments can certainly be viewed as “appropriate medications” as long as they provide needed relief and
care for the animal. Keep in mind that no treatment, conventional or alternative, will always be success-
ful.
On a practical level, one of the wisest things you can do is to find a veterinarian who understands and
supports your choice to be organic. With such a vet as your “herd health partner,” it is much easier to
develop treatment strategies that are holistic and NOP compliant, and that avoid the accidental use of
prohibited medicines when suitable alternatives are available.101
Of course, this is easier said than done.
Currently, the number of practicing veterinarians that both understand the NOP Regulations and are
trained in alternative modalities are still few and far between. When working with conventionally minded
veterinarians, you must take extra precautions. Many vets will give antibiotic injections without asking
or even explaining what they are doing. You will need to clarify your situation at the outset. You may
need to provide the alternative medication and even administer it yourself. Keep in mind that many
alternative therapies work slowly and are more effective with chronic conditions than acute ones. Fi-
nally, if the alternative treatments you try should fail, you will need to resort to conventional treatments
and accept the loss of organic status for that animal.
It is expected that many new-to-organic producers will attempt to adapt conventional confinement pro-
duction systems to organic. This raises a specific concern: that some producers might design production
systems to “sacrifice” a high percentage of livestock to disease, thus circumventing the intent of the
Regulations, which is that the production system itself be healthy. For example, a producer might plan
on raising too many animals in semi-confinement with the idea that he or she will treat any visibly sick
animals with antibiotics, and sell the untreated “survivors” as organic. Such Plans are not considered
acceptable. Producers are warned against developing OSPs that anticipate high culling percentages and
subsequent conventional sales as a health management strategy.
19.1 Are you using organically acceptable strategies and techniques to treat,
control, and/or prevent diseases and injuries in livestock [§205.105]?
Allowed options include but are not limited to:
• selective breeding
• quarantine of newly purchased, injured, or diseased animals
• nutritional therapy
• aseptic protocols during vaccinations, physical alterations, and
surgical procedures
n/a
Yes No](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-50-320.jpg)
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NCAT’s Organic Livestock Workbook:
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• use of electrolytes, glucose, dextrose
• vitamin therapy
• probiotics (includes colostrum—must not be from a genetically
engineered source)
• iodine
• hydrogen peroxide
• vaccination102
• herbal remedies103
• homeopathy104
• flower essences, and related therapies
• acupuncture105
• chiropractic
• aromatherapy
• radionics106
• reiki107
Prohibited materials and techniques include but are not limited to:
x antibiotics [§205.238(c)(1)]
x genetically modified probiotics [§205.105(e)]
x most conventional veterinary medications
19.2 Do you keep records of all animal health products used, along with their
purchase receipts and labels?108
19.3 Do your herd/flock health records accurately document all health
treatments given and/or procedures performed?109
19.4 Are your herd/flock health records adequate to track animals treated with
prohibited materials to ensure that they are NOT sold as organic [§205.236(c)]?
19.5 If livestock become sick or injured, do you take action and apply the
necessary medications to restore health regardless of the consequences
to the animal’s organic status [§205.238(c)(7)]?
19.6 Are you using allowed medications solely for the purposes of restoring
animal health [§205.238(c)(2)]? This is not a trick question—you may not
administer any animal drug to enhance growth or performance. Medications
are allowed only for the treatment of injury or disease.
19.7 Do you have a working relationship with a veterinarian?
n/a
Yes No
n/a
Yes No
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Yes No
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Yes No
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Yes No
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NCAT’s Organic Livestock Workbook:
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20.1 Are you using organically acceptable strategies and techniques for
preventing and controlling internal parasites in livestock [§205.105]? 110
Among the preventatives and treatments for internal parasites are a
number of modalities that might be considered unconventional and
experimental. They are, however, allowed for use in organic production
systems. Options include but are not limited to:
• pasture rotation (see Text Box 20A in this section of the workbook)
• controlled grazing (see Text Box 20A in this section of the workbook)
• multi-species grazing (see Text Box 20A in this section of the workbook)
• dragging or clipping pasture to disperse manure piles
• fecal sampling as a monitoring tool
• selective breeding for resistant stock
• sanitation
• herbal treatments (see Text Box 20B in this section of the workbook)
• diatomaceous earth (see Text Box 20B in this section of the workbook)
• ivermectin (see Text Box 20B in this section of the workbook)
• electrotherapies111
• radionics112
Prohibited materials and techniques include but are not limited to:
x most synthetic worming agents [§205.105(a)]
x ionophores—antibiotics that control protozoan parasites [§205.238(c)(1)]
Text Box 20A continued
• by rotating pastures on a timely basis, internal parasites are allowed to hatch
and die before the host livestock return to the field—a self-cleaning process
• since most internal parasites are not shared across species, both multi-species
grazing or rotational grazing with different species are viable strategies for reducing
parasite loads
• allowing younger, more parasite-susceptible stock to graze first on fresh pasture; older,
less susceptible stock can follow when forage is shorter and the parasite hazard
increases
• following cattle with pastured or ranged chickens is a strategy for reducing both inter-
nal and external parasites—particularly flies. Poultry “disassemble” manure pats,
destroying eggs and feeding on larvae.
Continued on page 54
Text Box 20B
About Organically Acceptable Dewormers
If you farm or ranch in a region with high internal parasite pressure, then you have a particularly
difficult challenge. As you will see, there are very few organically acceptable products available to
assist you.
Diatomaceous earth (or DE) is often touted as a parasiticide and is commonly used by organic
producers. DE is manufactured from the fossilized remains of tiny sea organisms called diatoms,
n/a
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NCAT’s Organic Livestock Workbook:
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Text Box 20B continued
which are mined and ground to make a fine “shell flour.” The particles of the flour have sharp edges
that pierce the exoskeleton of parasites and insect pests, causing damage that leads to their deaths.
The sharp edges are apparently small enough that they cause no damage to the intestinal tracts of
livestock. When used, DE is often mixed with feeds, with free-choice supplements, or is provided as
free choice on its own. The only direct physical hazard comes from breathing too much DE; silicosis
and related lung conditions can result. An indirect—and possibly more serious hazard—may result
from failure to control a significant parasite problem.
While heavily promoted as a dewormer, the efficacy of DE is open to question. Some veterinarians
believe that the positive effects attributed to DE actually arise from other aspects of good organic
management and diatomaceous earth is accorded more credit than it deserves. However, the jury is
still out on this matter and DE should not be entirely discounted as a deworming agent. If you
choose to use DE, make certain that it is part of a more comprehensive parasite management plan.
Also, be certain that you are using an organically acceptable form of diatomaceous earth. There are
formulations of diatomaceous earth intended for use in swimming pool filters and similar applica-
tions. These forms are not allowed.
Several herbal agents113
are also reputed to be useful for deworming livestock. Garlic is most often
mentioned, though other plants and plant extracts have also been used. It has even been suggested
that raw garlic be added to the feed. If you choose such a strategy, be certain to consult with your
certifier. The garlic or other plants used in this manner may need to be organically grown. Unless
“home-grown,” herbal dewormers are likely to be expensive and their efficacy is not well docu-
mented as yet.
At the time of this writing, one synthetic parasiticide—ivermectin—is allowed for limited use in
organic production. Ivermectin is prohibited in slaughter stock, but is allowed for emergency treat-
ment of dairy and breeder stock when management strategies do not prevent infestation. Milk or
milk products from a treated animal cannot be marketed as organic for 90 days following treatment.
In breeder stock, treatment cannot occur during the last third of gestation if the progeny will be sold
as organic and must not be used during the lactation period of breeding stock [§205.603(a)(12)].
One of the principal concerns surrounding the use of synthetic dewormers is their effect on the
ecology of soil life—especially those organisms involved in the breakdown and incorporation of
manure. Ivermectin is known to decimate dung beetles, one of the main organisms involved in
manure recycling. It is wise, therefore, to make limited use of this material. 114
The National Organic Standards Board has brought up the possibility of removing ivermectin from
the National List at some time in the near future. It may or may not be replaced with another syn-
thetic option.](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-54-320.jpg)
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NCAT’s Organic Livestock Workbook:
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20.2 Are you using organically acceptable strategies and techniques to control
or prevent flies, mosquitoes, and external parasites [§205.105]? Options
include but are not limited to:
• pasture rotation
• multi-species grazing (see Text Box 20A in this section of the workbook)
• dragging or clipping pasture to disperse manure piles
• manure management (see Section XVII of this workbook)
• sanitation115
• ventilation and moisture control
• screening
• fly parasites and other beneficials116
• bat conservation117
• purple martins118
• walk-through fly traps119
• sticky traps
• flying insect traps120
• electric bug zappers
• biological pesticides
• diatomaceous earth
• botanical pesticides and preparations
Prohibited materials and techniques include but are not limited to:
x most synthetic insecticides and acaricides121
[§205.105(a)]
x synthetic insecticidal ear tags [§205.105(a)]
Notes on Parasites
XXI. Assessing the Vitality and Health of Your Organic
Livestock
The following questions can assist you in assessing the effectiveness of your organic production system
with regard to livestock health.122
It is highly advisable to also utilize the services of your veterinarian.
Arrange for routine herd health checks to be done and give serious consideration to your veterinarian’s
advice and observations. See Section XIX of this workbook for more background.
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Assessment Notes
XXII. Predator Management
Wild and domestic predators can be a problem in almost any livestock system, causing costly injuries
and death losses. However, looks can sometimes be deceiving. Producers should first determine whether
the animal carcass being devoured was actually killed by the suspected predator or whether it died from
another cause, making the “suspect” nothing worse than a scavenger. Such assessment can prevent
unnecessary expense and reduce negative impacts on wildlife diversity and neighbor relations.
22.1 Are you using organically acceptable strategies and techniques to control
predation of your livestock124
[§205.105]? Options include but are not limited to:
• night confinement of stock
• lambing in secure sheds and lots
• guard animals125
• noise, light, and visual devices
• fencing
• live trapping and relocation
• proper disposal of dead animals (see Text Box 22A in this section of the workbook)
Prohibited materials and techniques include but are not limited to:
x poison baits—§205.604(a) specifically prohibits strychnine
n/a
Yes No
Text Box 22A
Disposing of Dead Livestock
Dead livestock and unmanaged livestock processing wastes can be a source of disease and can at-
tract scavengers and predators that can become a danger to live animals. Furthermore, the potential
exists for highly valued scavengers, such as bald eagles, to become infected with the diseases of
domestic stock; it may also disrupt their natural feeding behaviors.
Composting is a desirable means of disposal. Most Cooperative Extension offices have information
on composting dead livestock.126](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-57-320.jpg)
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Notes on Predator Control
XXIII. Source of Animals
Compared with most organic standards across the globe, the USDA’s National Organic Standard is
more strict with regard to the source of livestock. The history of each animal is a major determining
factor in whether it can eventually be sold or represented as organic. Some animals obtained from
nonorganic sources can be transitioned into organic production under certain conditions and if specific
criteria are met [§205.236].
Please refer to Figure 2 “Origin of Livestock.” It is a flowchart published by the National Organic Pro-
gram on April 11, 2003 to help producers understand the requirements of the Regulation. Further detail
and elaboration follow:
• Mammalian livestock (cattle, sheep, hogs, goats, rabbits, etc.) raised for meat production must
be under full organic management beginning no later than the third trimester of gestation.
For example, bred cows from conventional sources must be under full organic management
at least three months prior to calving for the offspring to be considered organic.
• Livestock used as breeder stock may be obtained from a nonorganic operation. However,
while they may be used to produce organic offspring, the breeder animals themselves may
not be sold as organic slaughter stock.
• Poultry chicks from conventional sources are allowed for the production of organic meat and
eggs only if raised organically beginning the second day of life, that is, as “day-old chicks.”
Older birds grown under conventional management are only allowed as breeder stock for
production of hatching eggs.
• Dairy animals from conventional sources must be maintained under organic management
for a minimum of one year prior to selling, representing, or using their milk or milk products
as organic.
• If an entire, distinct dairy herd is under conversion to organic management, you are allowed
to feed up to 20% conventional feedstuffs for the first nine months of the transition, followed
by 100% organic feed thereafter. Dairy offspring whose dams receive less than 100% organic
feedstuffs during the final trimester of pregnancy may not be marketed as organic meat ani-
mals. Note that there are several ways to interpret the 80/20 Rule. Contact your certifier!
• Once a dairy herd has been fully transitioned into organic status under the 80/20 Rule, all of
the herd’s milk-producing animals must be under organic management from the third trimes-
ter of gestation.](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-58-320.jpg)
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There is considerable confusion on how to interpret the National Standard regarding replacement dairy
animals. As stated in §205.236(2), one year of organic management is all that is required for dairy animals
before their milk may be marketed as organic. This suggests that conventional heifers may be acquired
and “transitioned” as needed for replacement or herd expansion. However, §205.236(2)(iii) states that
once an entire herd has been converted, all dairy animals must be organic from the last third of gesta-
tion—the same as the requirement for slaughter stock—implying that you cannot acquire further con-
ventional heifers and convert them to organic production. The two sections are clearly contradictory.
A resolution for the “replacement heifer” conundrum will likely require a change in the regulations,
though this could take considerable time to come about. The NOSB is currently recommending a conser-
vative interpretation. The language they recommend as a change in the Regulation states: “On existing
organic dairy farms all replacement or expansion dairy animals shall be under continuous organic man-
agement from the last third of gestation.” If the conservative interpretation is enforced, it has significant
implications for the raising of dairy replacements.
No matter what interpretation is chosen, the National Standard varies considerably from what some
producers were accustomed to prior to Federal Regulation. To retain organic status, dairy calves may not
receive antibiotics or any other prohibited medicines at any time. They may not be fed conventional milk
replacers, except in emergencies (see Text Box 15B for details). Organic producers also may not sell or
“farm out” their organic heifer calves, ewe lambs, or doe kids to a conventional operation with the intent
of re-acquiring and re-integrating those animals into the organic dairy herd at a future date.
In light of all the uncertainties surrounding replacement dairy animals, it is most important that you
clarify your strategy in your OSP and consult with your certifier in advance.
Finally, it should be mentioned that artificial insemination (a.i.) is permitted in organic production. An-
tibiotics used to preserve a.i. semen are allowed at the recommendation of the NOSB. However, the use
of hormones to synchronize estrous cycles for breeding is not allowed.
23.1 If livestock have been acquired from an organic source, do you have verifi-
cation of their organic status [§205.236(c)]?
23.2 Do you retain purchase records for all acquired livestock?
23.3 Do you keep adequate feed and management records to document the tran-
sition of conventional dairy animals to organic status [§205.236(c)]?
23.4 Do you keep adequate records to document the organic management of
breeder stock to ensure the organic status of their offspring [§205.236(c)]?
23.5 If you are raising organic livestock (other than poultry) for slaughter or for
production of other non-dairy livestock products, have the animals been
under continuous organic management from the last third of gestation
[§205.236(a)]?
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-60-320.jpg)
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23.6 If you are raising organic poultry, have the birds been under continuous
organic management beginning no later than the second day of life
[§205.236(a)(1)]?
23.7 If you are producing organic milk or milk products, is the milk coming
from animals that have been under continuous organic management for
no less than 12 months [§205.236(a)(2)]?
23.8 If you chose to convert your entire dairy herd to organic production at one
time, have you provided a minimum of 80% organic feed for the first 9
months of the 12-month conversion period [§205.236(a)(2)(i)]?
23.9 If you chose to convert your entire dairy herd to organic production at one
time, have you provided a minimum 100% organic feed for the last 3
months of the 12-month conversion period and continued to provide 100%
organic feed thereafter [§205.236(a)(2)(ii)]?
Notes on Source of Animals
XXIV. Feed Storage
There are several areas of concern regarding feed storage. The first involves preserving feed quality. In
large part this necessitates sound design and construction of bins, cribs, barns, and other storage struc-
tures, followed by good maintenance. Feed quality also involves controlling pests. All pest control must
be done using organically acceptable methods and materials. See Text Box 16B for more information on
facility pest management.
A second concern of feed storage is contamination. Care must be taken that feed not become contami-
nated by prohibited materials like fuels, lubricants, and cleaning agents. Wood treated with prohibited
chemicals must not be used where it can contact stored feeds. A contamination hazard can also be pre-
sented by baling twine that has been treated with a fungicide to prevent rotting. Be certain to check with
your certifier—they may not even allow you to use treated twine. Treated twine—and plastic twine for
that matter—must be properly disposed of. Used twine should not be left where animals can chew it or
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-61-320.jpg)
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24.9 Are stored feeds reasonably free of pest problems?
24.10 Do storage facilities meet farm/ranch needs for capacity and the ability
to segregate feeds as needed?
24.11 If some feeds are stored off-farm, are these storage units either certified
organic or included in your farm’s inspection and certification?
24.12 If you are using plastic bale wrappers, plastic silage bags, plastic baling
twine, or are allowed to use treated baling twine, are the wastes properly
disposed of to ensure organic integrity and to protect the environment?
See Text Box 16C for additional information.
Notes on Feed Storage
XXV. On-Farm and Custom Feed Processing or Handling
The National Organic Program Regulations make use of the term handling to denote processing and
related activities. §205.2 specifically defines a handler as “[a]ny person engaged in the business of han-
dling agricultural products, including producers who handle crops or livestock of their own produc-
tion…” It defines a handling operation as “[a]ny operation or portion of an operation…that receives or
otherwise acquires agricultural products and processes, packages, or stores such products.” Therefore,
when the Regulations refer to handlers, they are referring to a varied group of individuals and businesses
that include both specialized organic food processors and farmers who do value-added processing. It
should be noted that retailers (such as grocers) that do not process or re-package the organic goods they
sell need not be certified.
Feed processing/handling scenarios can range from very simple to very complex, depending on the
nature of the operation. In the simplest of cases, producers purchase commercial organic feeds from
certified suppliers. In such instances there are very few concerns about contamination or commingling.
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-63-320.jpg)
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posed of in a number of ways. It may be sold on the conventional market, fed
to conventional livestock in split or parallel production, fed to draft animals,
or used as a soil amendment, etc.
25.6 If you use an off-farm custom feed handler, is he or she certified organic? The
National Organic Program Regulations prohibit handling of organic feed at
mill sites that have not been certified [§205.237(a)].
Notes on Feed Processing
XXVI. On-Farm and Custom Livestock Processing or
Handling
It is not enough merely to raise animals organically. In order for livestock products to bear the organic
label, all processing and handling of the products must be done by certified operators. This includes (but
is not limited to) all slaughtering, packing, and milk processing.
The typical handling operations this section is concerned with are butchering, cheese making, the clean-
ing and packaging of eggs, etc. Because of their innate complexity, most of these handling/processing
components will likely require the submission of an organic handling system plan129
in addition to the
OSP that you prepare as a production plan. Be prepared to pay additional inspection and certification fees
in this instance.
One of the major concerns in organic processing, regardless of scale, is identifying and sourcing ap-
proved ingredients. All allowed nonorganic ingredients (with the exception of water and salt, which are
considered natural and allowed) are addressed in the National List. §205.605 of the National List deals
with non-agricultural substances that are allowed in organic processing, both natural (nonsynthetics)
and synthetics. §205.606 deals with nonorganically produced agricultural products that are allowed.
As with organic production, OMRI has an valuable role to play in the evaluation of products for organic
processing. OMRI Listed products can be purchased and used with a high degree of confidence. As a
reminder, however, there are many acceptable products in the marketplace that have not been evaluated
by OMRI and do not carry the OMRI Listed seal. When in doubt, contact your certifier to verify whether
a particular product or material can be used.
Another question surrounds processing technologies. At present, only ionizing radiation and genetic
engineering are specifically prohibited [§205.105(e) and §205.105(f)].
n/a
Yes No](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-65-320.jpg)
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Water quality is a particular concern in organic processing. Microbial contamination is the primary
issue. Hydrogen peroxide, ozone, and chlorine are among the synthetic materials allowed in organic
processing that are effective in controlling microbial contamination. The use of chlorine requires addi-
tional clarification.
§205.605(b)(9)—the portion of the National List that outlines non-agricultural synthetics allowed in or-
ganic processing—says that chlorine materials are allowed for “disinfecting and sanitizing food contact
surfaces,” and that “residual chlorine levels in the water shall not exceed the maximum residual disinfec-
tant limit under the Safe Drinking Water Act.” (Currently the residual chlorine limit under the Safe
Drinking Water Act is 4 parts per million, or ppm.) The language of this section has caused a great deal
of misunderstanding and has led to a wide disparity of interpretation among certifiers. Some have as-
sumed that this language means that chlorinated water greater than 4 ppm chlorine may not come in
contact with organic food products and may be used only for sanitizing food preparation surfaces. Oth-
ers have assumed that the language requires that food products be washed only with water that contains
no more than 4 ppm chlorine—a level that is virtually ineffectual for sanitizing. Still other certifiers have
believed that the Safe Drinking Water Act criterion allows highly chlorinated water to be used, but that
the wastewater leaving the organic facility be less than 4 ppm chlorine.
The most rational interpretation (that we have heard, at least) is that the notation in the regulation was
improperly written; that the intent of the provision was that the rinse water that makes final contact with
the organic product contain less than 4 ppm chlorine. In other words, a food product such as whole
chickens may be bathed in water containing a high concentration of chlorine for sanitation purposes.
However, that product must receive a thorough final rinse of water that contains less than 4 ppm chlo-
rine.
The producer should be aware that full clarification of the regulation regarding chlorine has not been
made at the time of this writing. Therefore, be certain to consult with your certifier if you are using
chlorine products for organic processing.
Further issues in on-farm processing include avoiding contamination and commingling and the manage-
ment of waste products, among others. Unfortunately, the scope of this workbook is limited with regard
to processing and we are not covering those details in any depth. If you are planning a complex process-
ing operation, you are encouraged to consult someone in the industry with first-hand experience as well
as your certifier.
26.1 Are all the technologies you use for on-farm processing or in custom
processing allowed in organic production [§205.270(a)]? Allowed
technologies include but are not limited to:
n/a
Yes No
• baking
• boiling
• canning
• chilling
• churning
• cooking
• curing
• cutting
• dehydrating
• distilling
• drying
• eviscerating
• extracting
• fermenting
• freezing
• grinding
• heating
• jarring
• mixing
• packaging
• preserving
• separating
• slaughtering
• smoking
• washing](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-66-320.jpg)
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26.2 Are you avoiding the use of ionizing radiation or ingredients that have been
treated with ionizing radiation [§205.105(f)]?
26.3 Has a flow chart of all on-farm processing steps and procedures been
developed and is it available for review by the certifying body and its
inspectors?
26.4 Are all purchased raw commodities and ingredients used in on-farm
processing or in hired custom processing certified organic or otherwise
allowed for use in organic processing [§205.105 and §205.270]?
26.5 Do you take care to determine that all ingredients are NOT genetically
engineered and do not result from a process that uses genetically modified
organisms [§205.105(e)]?
26.6 Do you keep labels, invoices, and descriptions of all ingredients, processing
aids, and cleaning agents on file?
26.7 Do you use proper sanitation protocols in on-farm processing?
26.8 Do you use food-grade equipment and inputs in processing?
26.9 Where both organic and conventional products are handled and processed,
do you have protocols for segregation of product and clean-up clearly
established and are they adequate to prevent contamination and commingling
[§205.272(a)]?
26.10 Where both organic and conventional products are handled and processed,
are your logs of processing runs and clean-outs up-to-date?
26.11 Do you store prohibited substances away from processing equipment,
processing inputs, raw products, and finished products?
26.12 Do you maintain processing equipment to prevent contamination of organic
products with lubricants or other contaminants?
26.13 If you do on-farm meat processing, do you have a strategy for disposal of
offal and other waste products that does not pose a health risk to livestock,
contaminate organic products, or pollute the environment?
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-67-320.jpg)
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26.14 Is wastewater from processing managed in a way that does not cause pol-
lution or a health hazard?
26.15 Are packaging wastes managed so they do not contaminate organic prod-
ucts and do not create a pollution problem? See Text Box 16C for more
information on waste management.
26.16 Are coliform tests completed for all water used in food processing and wash-
ing? Annual testing is advisable and may be required by the certifier.
26.17 If you are using chlorine for sanitation purposes in on-farm processing, do
you have a clear understanding of your certifier’s expectations with
regard to meeting the National Standard for residual chlorine levels
[§205.605(b)(9)]? See the text in this section for clarification.
26.18 Have you performed any and all additional water analyses as requested by
your certifier?
26.19 If water treatment technologies are needed or required, have they been in-
stalled and are they fully functional?
26.20 Are you satisfied that your water sources are free of contamination by pro-
hibited substances?
26.21 If you are producing both organic and nonorganic eggs, are protocols in
place to prevent the commingling of products [§205.272(a)]?
26.22 If you are producing both organic and conventional meats, are protocols in
place to ensure that commingling of meat products does not occur
[§205.272(a)]?
26.23 If you are producing both organic and nonorganic milk and/or milk prod-
ucts, are protocols in place to prevent commingling [§205.272(a)]?
26.24 If you are producing both organic and conventional animal fiber and/or
fiber products, are protocols in place to prevent commingling [§205.272(a)]?
26.25 If commercial trucking is used to haul animal products from your opera-
tion, is care taken to ensure that organic products are not contaminated or
commingled with conventional products [§205.272(a)]?
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-68-320.jpg)
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27.1 Are all packaging materials free of impregnated pesticides or other
prohibited substances [§205.272(b)(1)]?
27.2 Are all packaging materials stored where they will remain free from
contamination or infestation by pests?
27.3 If you are re-using any bags or containers, are you taking measures to
ensure that there is no risk of commingling with nonorganic products
or of contamination with prohibited substances [§205.272(b)(2)]?
27.4 Is all labeling in compliance with the National Organic Program Regulations
[§205.300, §205.301, §205.302, §205.303, §205.304, §205.305, and §205.306]?
Be sure to read the appropriate sections of the Regulations and confer with
your certifier.
27.5 Where sales of both organic and conventional products occur, do adequate
labeling and protocols exist to ensure segregation?
27.6 Are all product lots sold from your farm assigned lot numbers that permit
traceability through your record keeping system [§205.236(c)]? Generally
this would not be considered necessary for products such as freezer beef
that are marketed directly to the end consumer. Further information on lot
numbers is provided in Section XXIX.
Notes on Packaging and Labeling
XXVIII. Marketing
Organic certification and regulation have arisen largely in response to a growing organic marketplace130
in which the producer and the end consumer never meet face-to-face. This marketplace is similar in
many ways to the conventional marketplace, though the players are different and the infrastructure is
not as well developed (as a rule).
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-71-320.jpg)
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• outgoing bills of lading
• weight records
• storage records
• equipment and storage unit cleanout logs
• slaughter and processing records
• sales receipts and/or invoices
• sales records
• complaint log139
29.1 Is there an adequate animal identification system in place [§205.236(c)]?
29.2 Does your lot numbering and audit control system permit accurate track-
ing of animals and animal products through processing and marketing
[§205.236(c)]?
29.3 Are records of sales maintained to ensure a complete audit trail?
29.4 Are you maintaining a complete set of operation records covering the pro-
duction and handling of all agricultural products that you intend to be
sold, labeled, or represented as organic [§205.103(a)]?
29.5 Is your record keeping system appropriate and well adapted to the needs
of your organic operation [§205.103(b)(1)]?
29.6 Does your record keeping system fully disclose all activities and transac-
tions in sufficient detail so as to be readily understood and audited
[§205.103(b)(2)]?
29.7 Have you retained or are you preparing to retain all records applicable to
your organic operation for at least 5 years [§205.400(d) and §205.103(b)(3)]?
29.8 Is the record keeping system sufficient to demonstrate compliance with
organic regulations and the Organic Foods Production Act [§205.103(b)(4)]?
29.9 Are your records available for inspection and copying during normal busi-
ness hours by authorized representatives of the Secretary of Agriculture,
the State organic program, and/or the certifying agent [§205.103(c)]?
29.10 If you have a split operation, are there adequate records to demonstrate
that no commingling occurs?
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No
n/a
Yes No](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-74-320.jpg)
![Revised February 2004 Page 89
NCAT’s Organic Livestock Workbook:
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80
For more information on grass tetany, see the University of Nevada’s Grass Tetany in Beef Cattle at
<http://www.forages.css.orst.edu/Topics/Pastures/Species/Grasses/Animal_issues/Tetany.html>.
81
For more information on prussic acid poisoning, see Purdue University’s Minimizing the Prussic Acid
Poisoning Hazard in Forages at <http://www.forages.css.orst.edu/Topics/Pastures/Species/Grasses/
Animal_issues/Prussic_Minimizing.html>.
82
For more information on nitrate poisoning see the University of Nevada’s Nitrate Poisoning at
<http://www.forages.css.orst.edu/Topics/Pastures/Species/Grasses/Animal_issues/Nitrate.html>.
83
For a discussion of endophyte toxicity in fescue, see The Tall Fescue Endophyte Story at <http://
www.caf.wvu.edu/~forage/fescue_endophtye/story.htm>.
84
See the Kerr Center for Sustainable Agriculture’s Riparian Area Management Techniques at <http://
www.kerrcenter.com/kerrweb/publications/riparian.pdf>.
85
For more information, see ATTRA’s Sustainable Pasture Management at <http://attra.ncat.org/attra-
pub/PDF/sustpast.pdf>, Rotational Grazing at <http://attra.ncat.org/attra-pub/PDF/rotgraze.pdf>,
Matching Livestock and Forage Resources in Controlled Grazing at <http://attra.ncat.org/attra-pub/
matchlandf.html>, and Introduction to Paddock Design and Fencing-Water Systems for Controlled Grazing at
<http://attra.ncat.org/attra-pub/PDF/paddock.pdf>. Also see the Kerr Center for Sustainable
Agriculture’s Management Intensive Grazing at <http://www.kerrcenter.com/kerrweb/publications/
MIG/mangmnt_intense_graze.htm> and Cell Grazing: Getting Started on Your Place at <http://
www.kerrcenter.com/kerrweb/publications/2002_proceedings/cell_grazing.pdf>.
86
For additional information on water quality for livestock, see Colorado State’s Livestock Drinking Water
Quality at <http://www.ext.colostate.edu/pubs/livestk/04908.html>.
87
To be more precise, §205.237(b)(2) reads: “The producer of an organic operation must not…[p]rovide
feed supplements or additives in amounts above those needed for adequate nutrition and health mainte-
nance for the species at its specific stage of life.”
88
Contact information for OMRI can be found in the Resources Section of this workbook.
89
See ATTRA’s Hooped Shelters for Hogs at <http://attra.ncat.org/attra-pub/PDF/hooped.pdf>.
90
See ATTRA’s Organic Alternatives to Treated Lumber at <http://attra.ncat.org/attra-pub/PDF/
lumber.pdf>.
91
Moving ‘Em by Burt Smith and Stockmanship by Bud Williams are both considered leading works on the
subject. Both books are available through The Stockman Grass Farmer (see Resources Section). Also rec-
ommended is Dr. Temple Grandin’s webpage <http://www.grandin.com/> and Colorado State’s Live-
stock Handler’s Safety at <http://www.ext.colostate.edu/pubs/livestk/01813.html>.
92
An excellent reference book for structural and household pest management is Common-Sense Pest Con-
trol by Olkowski, Daar, and Olkowski. This book is available from Acres, USA.
93
See Ohio State’s “Composting Livestock Mortalities” at <http://www.oardc.ohio-state.edu/fabe/
composting.htm>, the University of Minnesota’s “Composting Is The Natural Way To Dispose Of Dead
Animals” at <http://www.extension.umn.edu/extensionnews/1997/JN1329.html>, and Penn State’s
“Dead Pig Composting” at <http://www.penpages.psu.edu/penpages_reference/28901/
28901209.HTML>. In addition, the Water Quality Program of the University of Missouri Outreach and
Extension has guide sheets on dead animal regulation and composting. Request guide sheets WQ 205-
WQ 211, WQ 216 and WQ 225 at <http://www.fse.missouri.edu/waterquality/wqprograms/
composting.htm>.
94
NCAT’s Organic Crops Workbook can be found at <http://attra.ncat.org/attra-pub/PDF/
cropsworkbook.pdf>. Also see ATTRA’s Manures for Organic Crop Production at <http://attra.ncat.org/
attra-pub/PDF/manures.pdf>. Also helpful is North Carolina State’s Components of a Complete Manure
Management Plan at <http://www.bae.ncsu.edu/bae/programs/extension/publicat/wqwm/
ebae185_93.html>.](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-89-320.jpg)
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95
See ATTRA’s Farm-Scale Composting Resource List at <http://attra.ncat.org/attra-pub/PDF/
farmcompost.pdf>, the University of Missouri’s Making and Using Compost at <http://
muextension.missouri.edu/xplor/agguides/hort/g06956.htm>, the University of Maine’s How Compost
Happens at <http://www.umext.maine.edu/onlinepubs/htmpubs/1159.htm>, and Louisiana State’s Basic
Principles of Composting at <http://www.lsuagcenter.com/Communications/pdfs_bak/compost.PDF>.
96
Sources of biological control agents and information include Peaceful Valley Farm Supply at <http://
www.groworganic.com/>, 530-272-4769; and The Source at <http://www.sourcebiofly.com/>.
97
See the University of Florida’s Insect Attractants and Traps at <http://edis.ifas.ufl.edu/BODY_IN080>.
98
See ATTRA’s Organic Livestock Documentation Forms at <http://attra.ncat.org/attra-pub/PDF/
livestockforms.pdf> for an example of a compost production record.
99
See Oklahoma State University’s Freeze Branding Cattle at <http://www.ansi.okstate.edu/exten/beef/
FS3250.PDF>.
100
To learn more about CAVM, the Complementary and Alternative Veterinary Medicine website at
<http://www.altvetmed.com/> is recommended.
101
To find a list of practicing holistic veterinarians, state-by-state, visit the American Holistic Veterinary
Medical Association website at <http://www.ahvma.org/> or contact them at 2218 Old Emmorton Road,
Bel Air, MD 21015, Tel: 410-569-0795 Fax: 410-569-2346. Other useful resources include the Academy of
Veterinary Homeopathy at <http://www.theavh.org/>, or contact them at P.O. Box 9280, Wilmington,
DE 19809, Tel: 866-652-1590; the International Association of Veterinary Homeopathy, 2707 76th Av-
enue, SE, Mercer Island, WA 98040, Tel: 206-232-7667, website <http://www.iavh.at/>; and the Veteri-
nary Botanical Medicine Association, 334 Knollwood Lane, Woodstock, GA 30188, website <http://
www.vbma.org/>.
102
Vaccines are the only inputs that might derive from genetic engineering and still be allowed in organic
production [§205.105(e)].
103
Several books on treatment of livestock using herbs can be found at the 7mFarm & Herbals website at
<http://www.7mfarm.com/books.html>. Another excellent source is Acres, USA. One classic book on
herbal treatments is Juliette de Bairacli Levy’s The Complete Herbal Handbook for Farm and Stable, available
from both Acres U.S.A. and 7mFarm.
104
Several books on treatment of livestock using homeopathy can be found at the 7mFarm & Herbals
website at <http://www.7mfarm.com/books.html> and at the Homeopathic Educational Services website
at <http://www.homeopathic.com/>. Another excellent source for books on homeopathy for livestock
is Acres, USA.
105
A brief description of acupuncture as used by a veterinarian can be found at <http://
www.risingsunvet.com/acupun.htm>. Several books on treatment of livestock using acupuncture can
be found at the 7mFarm & Herbals website at <http://www.7mfarm.com/books.html>.
106
Radionics is one of many esoteric practices permitted in organic production. For information on radi-
onics see Radionics in Agriculture at <http://home.earthlink.net/~gkuepper/index/Radionics.htm>.
107
Some brief descriptive information can be found at Reiki for Animals at <http://www.adoredbeast.com/
july00_2.shtml>.
108
See ATTRA’s Organic Livestock Documentation Forms at <http://attra.ncat.org/attra-pub/PDF/
livestockforms.pdf> for a Health Care Products: Product Inventory form.
109
See ATTRA’s Organic Livestock Documentation Forms at <http://attra.ncat.org/attra-pub/PDF/
livestockforms.pdf> for examples of an Individual Organic Animal Health Record and an Organic Poul-
try Flock Health Record.
110
See ATTRA’s Integrated Parasite Management for Livestock at <http://attra.ncat.org/attra-pub/PDF/
livestock-ipm.pdf>. Also see Iowa State’s Gastrointestinal Parasites: Natural and/or Old-time Treatments at
<http://www.pfi.iastate.edu/OFR/Anthelmintics.htm>.
111
Electrotherapies include controversial modalities and tools like the Hulda Clark zapper. For informa-
tion pro and con see Zapper: General Information at <http://www.lifedevice.com/Zapper.htm> and Fasci-
olopsis buski at <http://www.biosci.ohio-state.edu/~parasite/fasciolopsis.html>.](https://image.slidesharecdn.com/atx156-140526182635-phpapp02/85/NCAT-s-Organic-Livestock-Workbook-A-Guide-to-Sustainable-and-Allowed-Practices-90-320.jpg)
NCAT's Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices
- 1. NCAT’s Organic Livestock Workbook A Guide to Sustainable and Allowed Practices NCAT NCAT’s Organic Livestock Workbook is designed for use by organic and transitional producers with livestock or mixed crop and livestock operations. Producers having certified or transitional cropping enterprises should also utilize NCAT’s Organic Crops Workbook.1 This workbook series is intended to be consistent with the requirements of the National Organic Standard. This document was developed by the National Center for Appropriate Technology (NCAT) with funds provided by the USDA/National Organic Program (NOP), and the USDA/CREES Sustainable Agriculture Research and Education (SARE) Program. Distribution is provided by NCAT’s ATTRA Project, the National Sustainable Agriculture Information Service. Rotational Grazing with Holstein dairy cattle, Washington County, Virginia. By Jeff Vanuga. 2002. USDA Natural Resources Conservation
- 2. Revised February 2004 Page 2 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Contents Acknowledgements ........................................................................................................................................................... 3 The Purpose and Use of This Workbook........................................................................................................................ 4 Fundamentals I. Organic Agriculture in America .................................................................................................................... 5 II. Certification ...................................................................................................................................................... 6 III. Overview of Organic Livestock Systems...................................................................................................... 7 IV. Organic System Plan ..................................................................................................................................... 11 V. Adjoining Land Use ...................................................................................................................................... 14 VI. Supporting BioDiversity ............................................................................................................................... 16 Pastures and Hay Crops VII. Organic Soil Management for Pasture and Hay Crops ............................................................................ 18 VIII. Weed Management in Pasture and Hay Crops ......................................................................................... 24 IX. Pest and Disease Management in Pasture and Hay Crops...................................................................... 28 X. Seeds and Planting Stock .............................................................................................................................. 29 XI. Field Equipment............................................................................................................................................. 32 XII. Hay and Haylage Harvest ............................................................................................................................ 34 XIII. Monitoring Your Pasture’s Performance.................................................................................................... 34 Livestock Health and Management XIV. The Organic Approach to Livestock Health .............................................................................................. 36 XV. Organic Feed .................................................................................................................................................. 38 XVI. Livestock Living Conditions, Facilities, and Handling ............................................................................ 41 XVII. Manure Management .................................................................................................................................... 46 XVIII. Physical Alterations ....................................................................................................................................... 49 XIX. Treatment of Sick or Injured Livestock....................................................................................................... 50 XX. Internal and External Parasite Management ............................................................................................. 52 XXI. Assessing the Vitality and Health of Your Organic Livestock ................................................................ 55 XXII. Predator Management .................................................................................................................................. 57 Organic Integrity and Related Matters XXIII. Source of Animals .......................................................................................................................................... 58 XXIV. Feed Storage ................................................................................................................................................... 61 XXV. On-Farm and Custom Feed Processing or Handling ............................................................................... 63 XXVI. On-Farm and Custom Livestock Processing or Handling ....................................................................... 65 XXVII. Packaging and Labeling................................................................................................................................ 70 XXVIII. Marketing ....................................................................................................................................................... 71 XXIX. Documentation, Record Keeping, and Audit Trail ................................................................................... 72 Finding Referenced Information Sources ..................................................................................................................... 75 Cooperative Extension Publications Offices and Websites ....................................................................................... 79 Endnotes............................................................................................................................................................................ 84
- 3. Revised February 2004 Page 3 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Acknowledgements NCAT wishes to thank the Independent Organic Inspectors Association (IOIA)2 for permission to adapt its materials in developing this workbook series. Particular mention should be made of the publication IFOAM/IOIA International Organic Inspection Manual, compiled and edited by Jim Riddle and Joyce Ford. NCAT also wishes to acknowledge the members of the stakeholder team that guided the creation of this document. The stakeholder team includes: • Harriet Behar, farmer, organic inspector, and OMRI, Gays Mills, WI • Diane Bowen, IFOAM, Milwaukee, WI • Emily Brown-Rosen, Organic Materials Review Institute, Titusville, NJ • Lisa Cone, Waterfall Hollow Farm, Berryville, AR (co-author) • John Foster, organic inspector, OMRI, and Seven Spoke Farm, McMinnville, OR • Keith Jones, Director of Program Development, National Organic Program • Mark Keating, Agricultural Marketing Service, USDA, Washington, DC • Rose Koenig, Rosie’s Organic Farm and NOSB, Gainesville, FL • Nick Maravell, Nick’s Organic Farm, Potomac, MD • Miles McEvoy, Washington State Department of Agriculture, Olympia, WA • Jim Riddle, Organic Independents and NOSB, Winona, MN • Maria Rosmann, Rosmann Family Farms, Harlan, IA • Kelly Shea, Director of Organic Agriculture, Horizon Organic, Penrose, CO • Francis Thicke, Radiance Dairy, Fairfield, IA NCAT staff that participated in the development of this workbook include: • Katherine Adam, Fayetteville, AR • Cynthia Arnold, Fayetteville, AR • Janet Bachmann, Fayetteville, AR • Rex Dufour, Davis, CA • Lance Gegner, Fayetteville, AR • Gail Hardy, Fayetteville, AR • George Kuepper, Fayetteville, AR (project leader) • Nancy Matheson, Helena, MT • Teresa Maurer, Fayetteville, AR • Cathy Svejkovsky, Butte, MT • Ann Wells, Fayetteville, AR NCAT does not recommend or endorse products, companies, or individuals. NCAT has offices in Fayetteville, Arkansas; Butte, Montana; and Davis, California. For additional copies of this publication, contact: ATTRA, P.O. Box 3657, Fayetteville, AR 72702; 1-800-346-9140.
- 4. Revised February 2004 Page 4 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices So here’s the scoop… The Purpose and Use of This Workbook One of the greatest challenges in organic farming today is understanding and navigating the Organic Regulations. This workbook3 is designed to help you in this regard. It addresses, among other things, the wide range of practices and materials allowed under the National Organic Standard. Particular em- phasis is placed on those farming strategies and practices that promote sustainability.4 This workbook will be especially useful to producers contemplating conversion to organic production, and to those who are in the early years of transition. If you are a beginning farmer or rancher, or are contemplating conver- sion to organic production, we encourage you to read this workbook before completing your application for certification. Please note that this is NOT a required document; it is a helpful guide that you may use as you wish. Hint: Your certifier would love to know you are using this workbook for guidance; consider showing it to your inspector.5 And speaking of organic inspectors, as you will learn in this workbook, organic inspection is an annual process. The individual who conducts the inspection—the organic inspector—represents the certifying agent. It is the inspector’s responsibility to look for documentation and indicators that bear out the producer’s claim to organic status, as well as to look for any violations. To succeed at their job, organic inspectors are trained to look critically at all aspects of an organic operation; few details escape their notice. This workbook presents an inspector’s perspective and attempts to address all of the different areas that inspectors investigate while visiting a livestock operation. Much of the useful information in the workbook is presented as brief discussions. Numerous endnotes are provided; most of these suggest further sources of information. You will also find a number of ques- tions at the end of each section, which serve as a checklist for sustainable practices and for preserving organic integrity. There are a number of questions that draw particular attention to areas that may affect eligibility for certification. In most instances the pertinent section and paragraph of the Organic Regula- tions will be shown in brackets, for example, [§205.203(c)]. Consider each of the questions carefully and place a check in the appropriate “Yes,” “No,” or “Not Appli- cable (n/a)” box. Providing answers that accurately reflect your current circumstances will be the most helpful to you—honesty will be your best policy. Ideally, you will have most of your checks in the “Yes” boxes. If you want to make optimum use of this workbook as a guide to information sources, try using the electronic versions (.html and .pdf) of the workbook that can be found on the ATTRA website at <http:/ /www.attra.ncat.org>. The workbook is featured under the section on organic farming. The publica- tions referenced in the endnotes are mostly free-of-charge resources accessible on the World Wide Web, and are active hypertext links. Clicking on any of these links will “jump” you immediately to that re- source. But be aware, electronic addresses can change. If a link does not work for you, submit your request to the appropriate entity—State Cooperative Extension Office, ATTRA, or other. A contact list for the primary information providers and Extension Publication Offices can be found toward the end of the workbook. Please note that some resources listed in the endnotes may not be fully consistent with the National Organic Standard. For example, Cooperative Extension Publications on organically acceptable pesti- cides often include nicotine, which is now specifically prohibited. When you have a question about whether any practice or product is allowed in organic production, CONSULT YOUR CERTIFIER. This is advice we will frequently give throughout this workbook.
- 5. Revised February 2004 Page 5 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices I. Organic Agriculture in America There are many notions of what organic agriculture is. In 1995, the National Organic Standards Board defined it as “an ecological production management system that promotes and enhances biodiversity, biological cycles and soil biological activity. It is based on minimal use of off-farm inputs and on man- agement practices that restore, maintain and enhance ecological harmony.” The legal definition, provided in the National Organic Program Regulations, states that “Organic pro- duction [is] a production system that… respond[s] to site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biological diversity” [§205.2]. While these definitions are helpful, they have more meaning when one considers them in light of how organic farming and the organic marketplace evolved. Contemporary American organic farming has its roots in the humus6 farming movements that prolifer- ated in Great Britain and Continental Europe from the 1920s through the 1950s. These movements evolved largely in response to the increasing use of synthetic fertilizers. The proponents of humus farming be- lieved that the highest quality food and the sustainability of agriculture were achieved through systems and techniques that built and enhanced the living organic or humus complex of the soil. Humus farming was typified by mixed farms that had both livestock and crop enterprises; they featured cropping schemes that included both food and feed crops, plus legume and grass forages and green manure crops. Humus farming made little or no use of soluble commercial fertilizers or pesticides, in good part because they were not needed and could even be counterproductive in systems so-modeled on nature.7 The 1960s and 1970s brought more visibility to organic farming as public concern over pesticide use increased. The non-use of synthetic pesticides eventually became a major focus of organic agriculture as demand for organic products grew, creating an industry out of a practical philosophic movement. Or- ganic industry growth led to the establishment of standards and third-party certification to ensure con- sistency and enhance credibility. As the industry expanded during the 1980s, disparities among certifier standards, barriers to trade, and incidents of fraudulent marketing led many to believe that more regulation was needed. Finally, in 1990, Congress passed the Organic Foods Production Act (OFPA).8 The OFPA mandated creation of the Na- tional Organic Program (NOP) and an advisory body, the National Organic Standards Board (NOSB). The OFPA paved the way for creating a single set of US standards for organic production, labeling, and marketing, which now exists in the form of the National Organic Program Regulations, a.k.a. the Na- tional Organic Standard.9 Many other countries, such as the European Union and Japan, have their own organic standards for products produced in or imported into their countries. US organic producers plan- ning to export their products must take these standards into account when certifying their operations.
- 6. Revised February 2004 Page 6 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices II. Certification Certification under the National Organic Program is the license to label, represent, and market your products as organic. Certification can be obtained from state or private certifiers that are accredited through the National Organic Program and who act as its licensing agents. 10 Under the NOP Regulations, all operations or portions of operations that produce or handle agricultural products that are intended to be sold, labeled, or represented as organic must be certified. Noncertified producers who represent themselves or their products as organic risk prosecution and fines. A three-year conversion period is required to achieve full organic status. In other words, no prohibited substances may be applied to the land for 36 months prior to the harvest of any product that will be labeled or otherwise represented as organic [§205.202(b)]. If you are purchasing or renting land that is not currently certified and you wish to document that it has not had prohibited substances applied, you must obtain verification from the previous landowner or manager.11 Annual inspections are part of the certification process. The inspector is an agent of the certifier. It is the inspector’s responsibility to look for documentation and indicators that bear out the producer’s claim to organic status, as well as to look for any violations. You must allow the inspector complete access to your operation, including all production facilities and offices [§205.400(c)]. Additional inspections may be announced or unannounced at the discretion of the certifier or the state organic program [§205.403(a)(2)(iii)]. Once certification has been granted, it is granted in perpetuity unless surrendered, suspended, or re- voked. For certification to continue, annual certification fees must be paid, the Organic System Plan (see section IV of this workbook) must be updated yearly, and previous non-compliances must be addressed [§205.406]. Any action to suspend or revoke certification must be handled in the manner prescribed in the Standard in §205.660–§205.664. If the status of your certification is threatened and you wish to dispute it, the process for seeking mediation is specifically covered under §205.663. Further details of these provisions will not be addressed in this workbook, but you should be aware that a formal grievance process exists. Producers who market less than $5000 of organic products annually are not required to apply for organic certification. They must, however, comply with the organic production and handling requirements of the National Standard. The products from such noncertified operations cannot be used as organic ingre- dients in processed products that are sold, labeled, or represented as organic by another operation; such noncertified products are also precluded from displaying the USDA organic seal. It is important to recognize that organic certification addresses the process involved in producing and handling a product. Organic certification assures the consumer that the product was grown using or- ganic methods, that harmful or dangerous pesticides, fertilizers, and genetically engineered organisms were not used in production, and that precautions were taken to prevent contamination from the outside. It does not guarantee that the product is completely free of all pesticide residues or GMO contamination. (The vast proliferation of pesticides and GE crops precludes virtually everyone from making such a claim.) Organic certification also does not ensure that the products are nutritionally superior.12 How- ever, organic farmers and consumers firmly believe that organic food and feed is healthier, and that organic production is better for the environment.
- 7. Revised February 2004 Page 7 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 2.1 Do you have a copy of the National Organic Standard13 and/or the standards of your certifying agency readily accessible as hardcopy or “bookmarked” on your web browser? 2.2 Is/Are your certifier(s) accredited by the National Organic Program? 2.3 Did you advise your certifier(s) of any previous applications for certification, including the names of the certifiers, dates of application, and the outcomes of those applications [§205.401(c)]? 2.4 If you are updating your certification, have you addressed any and all non- compliance issues and conditions previously noted by the certifying body [§205.401(c)]? 2.5 Have you discussed any previous suspensions or denials of organic certi- fication with your certifier [§205.401(c)]? Notes on Certification III. Overview of Organic Livestock Systems Traditional Organic Livestock Systems. Historically, livestock have always played a key role in organic production systems. During the formative years of the organic movement (the 1920s through the 1950s), the typical organic farms of Great Britain, Continental Europe, and North America integrated livestock production with the growing of both food and feed crops. Livestock provided manure, which is one of nature’s best fertilizers and a good means for recycling nutrients within a crop rotation. Growing live- stock feed alongside food crops diversified rotations; since forage legumes and sod-forming grasses are among the best feeds for ruminant livestock, these soil-building crops naturally became part of long sustainable cropping sequences. In such systems, livestock could also be fed cull vegetables, weather- damaged crops, crop residues, “alternative” grains and forages, and cash crop grains during years of low n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 8. Revised February 2004 Page 8 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices prices. Traditional organic farming systems such as these migrated to the US and remain today. They are common throughout the upper Midwest, with beef, hogs, and dairy cattle as the principal livestock compo- nents, and corn, soybeans, small grains, and hay as the principal crop enterprises. Such traditional farms have been the subject of much study over the past few de- cades. When contrasted with comparable conventional farms they were found to use less fossil fuel energy, lose less soil to erosion, generate fewer groundwater pollut- ants, and have less impact on global warming—all char- acteristics of a more sustainable approach to agricul- ture.14 In this traditional organic model as it is practiced today, ruminant livestock have access to pasture, and confine- ment is allowed only on a temporary basis. Non-rumi- nants (hogs, for example) might be pastured, and vary- ing degrees of limited and temporary confinement are commonly used. In most instances, these traditional models adhere easily to the National Organic Program Regulations. Grazing systems might also be considered traditional organic livestock systems. Grazing systems exist in stark contrast to conventional confinement systems where all feedstuffs are harvested, transported, and bunk-fed to the livestock. In grazing systems, livestock go where the feed grows and harvest it themselves. This typically yields savings in both energy and equipment expense. Since most planned grazing systems are legume and grass forage-based, they also have less erosion and lower production input costs. Because grazing sys- tems naturally afford livestock access to the outdoors, sunlight, fresh air, and exercise, and because ma- nure is distributed naturally, grazing systems generally have few problems complying with the NOP Regulations. The principal challenge appears to be successful organic management of internal parasites. While most grazing systems might be classed as traditional, noteworthy contemporary strategies include management intensive (rotational) grazing15 and pastured poultry production.16 Alternative Organic Livestock Systems—Semi-Confined. Nontraditional models of organic livestock production featuring limited confinement have evolved in recent years. Among these alternatives are specialized semi-confined production systems with little or no landbase. Such systems resemble conven- tional confinement production, but are typically less crowded and allow the livestock access to the out- of-doors, to fresh air, and to sunlight. Semi-confined/non-landbase systems are allowed under the NOP Regulations for non-ruminant livestock production and may be used for ruminants on a temporary basis (see below). A major challenge faced by semi-confined/non-landbase systems is the handling of manure. According to the NOP Regulations, manure must be managed “in a manner that does not contribute to contamina- tion of crops, soil, or water by plant nutrients, heavy metals, or pathogenic organisms and optimizes recycling of nutrients” [§205.239(c)]. Production systems that do not have growing crops to fertilize must dispose of manure in an environmentally sound manner that ensures recycling of the nutrients it con- tains. Text Box 3A When Pasture is Pasture… or Not The National Organic Standard defines pas- ture as “[l]and used for livestock grazing that is managed to provide feed value and main- tain or improve soil, water, and vegetative resources” [§205.2]. Dry lots, which have little or no vegetation, do not meet the NOP definition of pasture; neither does over- grazed pastureland, since overgrazing de- grades “soil, water, and vegetative re- sources.” Since §205.239(a)(2) requires that ruminants have access to pasture, the NOP definition of pasture works to ensure that farms and ranches not exceed the carrying capacity of their land because the resulting overgrazing risks damage to the natural re- source base. It is OK to provide certified organic green chop, hay, and other feedstuffs, but this does not preclude the need to provide pasture access to ruminant stock. Certifiers and their inspector repre- sentatives are likely to question the certifiability of any system that maintains more ruminant stock than can be sustained on the available grazing acreage, under typi- cal seasonal constraints.
- 9. Revised February 2004 Page 9 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Another major challenge for semi-confined/non-landbase systems is the acquisition of sufficient quanti- ties and variety of organic feeds17 and bedding, since these are not produced on-farm. It is hoped that this problem will solve itself as organic production of feed grains and hay expands nationally. Temporary Confinement. Full confinement of livestock is allowed ONLY on a temporary basis in organic production [§205.239(b)]. The circumstances under which temporary confinement is permitted are spe- cific: • to protect animals from inclement weather • to accommodate the needs of a particular stage of production • to ensure the health, safety, and well being of the animal • to protect soil and/or water quality Text Box 3B A Pattern for Health and Sustainability As organic agriculture moves into the mainstream of commerce and culture in the United States and growing emphasis is placed on issues of compliance and marketing, we often lose sight of those aspects of organics that make it attractive and worthy of pursuit. One of the most compelling aspects is system health. It is well-known that most organic farmers and ranchers take pride in the health of their livestock and brag openly about how much they save on veterinary costs. Health management is not relegated solely to medical treatment of sick animals, but to the creation of a whole system that draws from the lessons of nature and optimizes livestock welfare; a system that not only minimizes the hazards of disease, but supports a strong natural immune response in those instances where stress and pathogens occur. The strategies that support this arise from an organic philosophy that traces human and animal health back to the soil and sees it as the foundation on which a healthy system must be built (see Figure 1 in this section). Furthermore, organic management does not seek maximum production; it does not push livestock above and beyond the natural and healthy levels of performance. Rather, organic husbandry seeks its payoff as a benefit from enhancing and optimizing the health of the flock, the herd, the soil—the whole farm system. Traditional organic systems—as described in the main text—reflect these strategies and philosophy. In the hands of good stewards, traditional or- ganic systems are essentially healthy, though they can always be improved upon—a good example being the integration of improved pasture grazing management. Major problems in organic livestock production tend to appear when producers attempt to adapt confinement livestock production to organics by merely “tweaking” the system. These folks might meet the minimum regulatory requirements, but they will always be challenged by animal health issues and the associated costs of treating sick livestock or sustaining high death losses. The health of a good organic system is not only reflected in the economic sustainability of the opera- tion, but also in its environmental sustainability. This is especially true as regards manure manage- ment and nutrient recycling. Figuring out what to do with all that manure is much less of a problem when the production system is land-based; there is not only a place for it to go, but all that waste becomes valuable fertilizer.
- 10. Revised February 2004 Page 10 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 3.1 Does your production system allow access to the out-of-doors, sunlight, fresh air, and exercise space for all your livestock [§205.239(a)(1)]? 3.2 Does your production system allow access to pasture for all ruminant livestock under usual conditions [§205.239(a)(2)]? 3.3 If you use temporary confinement, does it meet the criteria of the National Standard [§205.239(b)]? Notes on Livestock Systems n/a Yes No n/a Yes No n/a Yes No The Organic Concept of Animal Health through the Eyes of a Veterinarian. Adapted from Ann Wells, DVM (NCAT), 2003. Originally adapted from Johnson, in Benson & Zirkel’s Organic Dairy Farming, 1995. Figure 1. Medications Equipment Housing Breeding Water Pastures and Grazing Management Soil Life and Balance
- 11. Revised February 2004 Page 11 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices IV. Organic System Plan In comparison to many of the industry standards that preceded it, the National Organic Standard is much less prescriptive—that is, it tends to characterize what an organic operation should be like in gen- eral terms and leaves the details for producers and certifiers to work out. The principal tool for working out such details is the Organic System Plan. Under the National Organic Standard, each certified organic farm or ranch must have an Organic System Plan (OSP), also referred to as the organic farm systems management plan or the organic production and han- dling system plan. The OSP is a detailed outline that explains how you intend to operate your farm or ranch to satisfy the requirements of the NOP Regulations. According to §205.201(a) of the National Standard, the OSP must contain: • a description of farm practices and procedures to be performed and maintained, including the frequency with which they will be performed; • a list of each substance to be used as a production or handling input, indicating its composi- tion, source, location(s) where it will be used, and documentation of commercial availabil- ity, as applicable; • a description of the monitoring practices and procedures to be performed and maintained, including the frequency with which they will be performed, to verify that the plan is effec- tively implemented; • a description of the record keeping system implemented to comply with the requirements established in §205.103; (See Text Box 4A in this section.) • a description of the management practices and physical barriers established to prevent commingling (see Text Box 4B in this section) of organic and nonorganic products on a split operation and to prevent contact of organic production and handling operations and prod- ucts with prohibited substances; and • additional information deemed necessary by the certifying agent to evaluate compliance with the regulations. Text Box 4A Requirements for Recordkeeping §205.103 deals with the requirements for recordkeeping by certified operators. The records must: 1) be well-adapted to the business being conducted, 2) disclose all activities and transactions in adequate detail, 3) be maintained for not less than five years beyond their creation, and 4) be sufficient to demonstrate compliance with federal regulations. Your records must also be available for inspection and copying during normal business hours by authorized representatives of the Secretary of Agriculture, the State Organic Program, and/or the certifying agent [§205.103(c)].
- 12. Revised February 2004 Page 12 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices The OSP must be written by the producer and agreed to by the certifier. It must reflect all current produc- tion methods and all materials that will be used. Producers should use the OSP to explain and rationalize practices they feel they need to manage effectively—especially those which may not have clear accep- tance in the National Standard. For example, physical alterations (castration, ear notching, nose rings, branding, beak trimming, etc.) are not provided blanket approval, though some organic producers may have used them for years. These producers can use the OSP to make their case for such practices, explain- ing why each practice is necessary, how it affects the animal’s welfare, and how it will be done to mini- mize stress and suffering. The certifier can then decide whether each practice complies with the Federal Standard. The OSP should also address future intentions and improvements. The OSP can be a vital tool for good organic management while ensuring compliance with the National Standard. Should you need to deviate from the OSP that you have agreed upon with your certifier, it is imperative that the certifier be advised [§205.406(a)(1)(i)]. It is required that you consult your certifier about planned changes in advance [§205.406(a)(1)(ii)]. An annual update of the plan is a requirement for continuation of certification [§205.406(a)(1)]. Text Box 4B Coming to Terms Contamination can be defined as contact or pollution with a prohibited substance; for example, con- ventional pesticides, GMO pollen. Commingling is the physical contact and possible mixing of an organic product with a similar con- ventional product. Transitional land is acreage that has been managed organically for less than 36 months. Because the term “transitional” does not have legal status in the National Organic Standard, crops harvested from transitional land may not be sold, labeled, or represented as “transitional;” neither may live- stock that have been fed transitional feeds. The status of such crops and livestock is, for all intents and purposes, conventional. Split production farms are those that produce both organic and nonorganic products (nonorganic includes transitional products). Parallel production is essentially a subset of split production. The term is used to describe a situation where the same crop or type of animal is produced both organically and nonorganically on the same farm operation. Paddock is a grazing unit in management intensive or rotational grazing systems. However, for the purposes of this workbook, paddock will simply refer to any pasture, field, or range unit where any form of grazing is practiced. Grazier is the term used to refer to one who manages grazing animals. Grazer (note the slight differ- ence in spelling) is used to describe the grazing animal itself.
- 13. Revised February 2004 Page 13 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices It is standard practice for the OSP to be incorporated in the application for certification, which is required by certifiers at the outset. In other words, you are completing your OSP at the same time you are filling out your application for certification. In such instances, a separate System Plan document is not required. There may also be some instances in which plans submitted to qualify for federal aid or assistance pro- grams may satisfy the requirement for an Organic System Plan [§205.201(b)].18 An accurate map of all farm or ranch acreage and production units is typically required as part of the OSP.19 Important map features: • consistent scale (Farm Service Agency photo maps may be used) • permanent field, pasture, or paddock numbers or names • permanent housing unit numbers • feed storage areas • buildings, roadways, and similar features • hydrologic features: wells, rivers, ponds, irrigation ditches, springs, major drainages, water- ways • field boundaries and adjoining land use • buffer zones • contiguous non-production areas under your ownership or management (for example, wild- life habitat, woodlot, etc.) Field or rangeland histories are also required as part of the OSP. Field histories should document: • field or paddock size • vegetation, crops and/or cover crops for current and previous years (three-year minimum) • all inputs used for current and previous years (three-year minimum) • field or paddock status (Organic, Transitional, Conventional) for previous years (three-year minimum) One of the realities of organic farming under the Federal Standard is the expected increase in the number of operations that feature both organic and conventional production. The terms split and parallel are commonly used to describe such farms (see Text Box 4B in this section). Many certifiers require that field histories and other records cover conventional as well as organic management on split and parallel op- erations. It is important that the OSP addresses all hazards of contamination and commingling that may arise. Prior to the development of the National Organic Program Standard, a number of certifiers re- quired that split operations have a long-term plan for full conversion to organic. There is no such re- quirement in the National Organic Program Regulations. 4.1 Have you completed your Organic System Plan (OSP) [§205.201(a)]? 4.2 Has your OSP been approved by your certifying agent(s) [§205.201(a)]? 4.3 Is your farm or ranch map complete and accurate? 4.4 Have you completed a field/rangeland history sheet? n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 14. Revised February 2004 Page 14 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 4.5 Are the numbers/names used on your map consistent with those used on field histories and other records? 4.6 If your production unit features a number of pens for segregating livestock, are those pens permanently numbered? 4.7 Do you have a complete map of your production facility featuring pen num- bers? Notes on Organic System Plan V. Adjoining Land Use Organic livestock—as well as the crops they eat—must be protected from contamination by prohibited substances used on adjoining lands. The most common concerns are pesticide drift and fertilizer runoff. In recent years, pollen drift from genetically engineered crops has also become an issue. See Text Box 5A in this section of the workbook. Contamination prevention for organic systems usually requires a multi-pronged approach. Strategies may include one or more of the following: • isolation. Fields, farms, and ranches that are remote or are located at substantial distances from conventional production, roadside spraying, or industrial uses are considered to be ad- equately protected. • barriers. Hedges and woods serve as barriers to air- and water-borne contaminants. • buffer zones. It is common practice for organic producers to designate a buffer zone along borders or property lines where adjoining land and livestock are conventionally managed. Crops harvested from buffer zones, even though organically grown, must be treated as con- ventional. Organic livestock may not graze buffer areas and may not be fed buffer zone crops. • drainage diversion • posting of property (for example, signage reading “Organic Farm: Do Not Spray,” etc.)20 n/a Yes No n/a Yes No n/a Yes No
- 15. Revised February 2004 Page 15 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices • formal notification. Written notification is provided to neighbors, utilities, and authorities that manage adjoining lands and rights-of-way requesting cooperation to reduce contamina- tion. You may need to assume responsibility for weed control on roadsides and rights-of-way as part of any resulting agreement. Copies of formal notification letters must be kept on file.21 • verification of adjoining land use. A signed statement by the owner or manager of adjoining land serves as acceptable documentation.22 The use of buffer zones has a long history in certified organic production. Traditionally, such buffers were defined by width only, with 25 feet being the common distance specified in most certifier stan- dards. The National Organic Program Standard does not specify the required width for a buffer zone, it speaks only to the need to minimize contamination. Therefore, the width (and height, in some instances) of buffers may need to be adjusted for individual circumstances, for example, a more significant buffer is needed where adjacent land is sprayed by plane or helicopter. If your certifier suspects that your pastures or feed crops are contaminated, residue testing may be re- quired. If residue levels exceed 5% of the EPA tolerance levels, the feed can no longer be considered organic [§205.671]. Note that residue testing is not an accepted substitute for buffer zones or other strat- egies to prevent contamination. It can, however, serve as an indicator that those strategies are effective. . Text Box 5A Genetic Engineering (GE) and Genetically Modified Organisms (GMOs) Genetic engineering is considered an excluded method in the National Standard. §205.2 defines ex- cluded methods as a variety of methods used to genetically modify organisms or influence their growth and development by means that are not possible under natural conditions or processes and are not considered compatible with organic production. Such methods include cell fusion, microencapsulation and macroencapsulation, and recombinant DNA technology (including gene deletion, gene doubling, introducing a foreign gene, and changing the positions of genes when achieved by recombinant DNA technology). Such methods do not include the use of traditional breeding, conjugation, fermentation, hybridization, in vitro fertilization, or tissue culture. Genetic engineering is a new feature of the agricultural landscape, and the organic community is still coming to grips with it. Clearly, organic producers are not allowed to market genetically engineered animals as organic, and genetically engineered biopesticides, probiotics, medications, and the like may not be used in organic production. Organic livestock feed may not be derived from GE crops. Since genetically engineered crops are not allowed in organic crop production, organic feed, ostensi- bly at least, is non-GMO by default. However, there is a danger of GMO contamination of organic feed crops. At the time of this writing there are no genetically engineered forage crops on the market, so pasture-based production is not unduly affected. Organic grains—especially corn—are the most heavily contaminated. While this has become a serious issue in export of organic food grain products, it is not a top-drawer concern with respect to domestic organic livestock feed at the present. That may change in the future and producers should be aware of it. If you grow grain crops as organic feed, you must take steps to prevent contamination. Guidelines for preventing genetic drift from GM crops to organic fields are being evaluated.
- 16. Revised February 2004 Page 16 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 5.1 Are all fields and paddocks well isolated or provided with buffers to prevent contamination [§205.202(c)]? 5.2 If there is danger of contamination from adjoining land use, are you taking steps to minimize the risk [§205.202(c)]? 5.3 Have you notified your certifier(s) of any drift or misapplications of pro- hibitedsubstances to any field, production unit, site, facility, livestock, or product that is part of the organic operation [§205.400(f)(1)]? If serious drift contamination occurs, you should also contact your State Department of Agriculture, which has (or should have) the responsibility to follow up on such matters.23 5.4 Have you consulted your certifier to learn if there are specific requirements for buffer zones or other matters relating to adjoining land use? Notes on Adjoining Land Use VI. Supporting BioDiversity The National Organic Standard defines organic production as a production system that “respond(s) to site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity” [§205.2]. Aside from an additional mention of “biological diversity” in the definition of crop rotation, the practice standards do little to highlight biodiversity as something to be measured and monitored. n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 17. Revised February 2004 Page 17 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Biodiversity is a principle of sustainable agriculture and an important indicator of a healthy organic farm or ranch.24 It plays a particularly crucial role in insect pest management. Diverse agricultural systems support strong populations of predators and parasites that keep pest populations at manageable levels. Pasture-based livestock systems, and those based on mixed crop and livestock production, possess the basic elements for developing a sound diverse agroecosystem. Specialized production systems with limited land base will have a more difficult time designing their systems to support biodiversity. One of the more common means through which farmers and ranchers promote biodiversity is by estab- lishing and maintaining forage diversity in their pastures and range. One of the more interesting varia- tions on this concept found in humid regions is herbal pastures or leys. Herbal pasturing differs sharply from the conventional notion that a productive pasture must feature only one or two useful forage plant species. Herbal pastures contain a number of non-traditional forage species and plants, many of which would be considered weeds in conventional systems. The majority of these plants—such as forage chicory—are broad-leaved, tap-rooted plants (sometimes referred to as forbs) that provide diverse nutri- tion to the livestock, capture and recycle nutrients from the subsoil, and draw beneficial insects to the field. A diversity of plant species also stabilizes the pasture ecosystem against environmental stress. If one or more of the forage species is wiped out by drought, disease, over-grazing, or another factor, the remaining species survive to ensure a source of feed and protect the soil.25 Properly grazed and managed pastures become increasingly biodiverse on their own. This is the natural process of succession as it would occur in a prairie environment grazed by buffalo or other wild herbi- vores. In mixed crop and livestock systems—where pasture and forage crops are grown as well as grains— strategies for biodiversity include crop rotation26 and the use of cover crops.27 Organic producers who manage such systems also seek to reduce the frequency of tillage to aid in conserving the diversity of soil organisms.28 A diversity strategy that is drawing increased attention is agroforestry. Agroforestry is the integration of tree crops with livestock or crop production. The term silvopasture specifically describes agroforestry systems that combine grazing with tree farming.29 Further means by which organic livestock producers promote biodiversity include: • multi-species grazing30 • limiting the use of botanicals and other natural-but-broad-spectrum pesticides • introducing beneficial organisms in the form of soil or compost inoculants, as beneficial preda- tors and parasites, or as pollinators • establishing habitats for beneficial insects and wildlife31 • adjusting the timing and frequency of mowing and grazing to accommodate nesting birds and other wildlife • providing roosting, nesting, or sheltering structures such as bird or bat houses • diversification of farm enterprises 6.1 If you produce both livestock and crops, have you implemented a crop rotation that integrates your enterprises effectively with good nutrient cycling and pest management? §205.205 of the Regulations requires that crop rotation be used whenever annual crops are produced organically. 6.2 Are you providing non-crop areas as habitat for beneficial insects and wildlife? n/a Yes No n/a Yes No
- 18. Revised February 2004 Page 18 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 6.3 Have you considered adding more enterprises to your operation? Notes on Biodiversity VII. Organic Soil Management for Pasture and Hay Crops The discussion provided here is brief and does not make clear how fundamentally important soil management is to a working organic system. There are many excellent books on the subject, but to get a good perspective, see ATTRA’s Sustainable Soil Management at <http://www.attra.org/attra-pub/soilmgmt.html> and the University of California publications Soil Manage- ment and Soil Quality for Organic Crops at <http://anrcatalog.ucdavis.edu/pdf/7248.pdf> and Soil Fertility Management for Or- ganic Crops at <http://anrcatalog.ucdavis.edu/pdf/7249.pdf>. Organic agriculture is built around the notion that providing nutritious food and feed is the best way to improve and sustain the health of people and livestock, and that the best way to grow nutritious food is by emulating nature, which begins with feeding the organisms of the soil. Soil micro-and macro-organ- isms are the external digestive system that processes organic matter, delivering a smorgasbord of miner- als, vitamins, and other nutrients to the crop at a metered pace. This is in contrast to the conventional approach where crops are flooded with a limited number of soluble fertilizer nutrients, leading to “luxury consumption,” imbalanced plant nutrition, and a susceptibility to disease and attack by insect pests. The food that soil organisms need to do their job comes in the form of organic matter. Thus composting, manuring, green manuring, and similar activities are the standard practices of organic crop production. Good rotational grazing management provides comparable humus development, through the slough- ing-off of roots when plants are grazed or mowed, and through the natural deposition of manures. In addition, since there is little-to-no tillage, humus accumulation is encouraged. Nitrogen is the limiting nutrient on most organic farms. The most economical source of nitrogen is from legumes. Biological nitrogen fixation in legumes results from a symbiotic relationship between the plant and rhizobium bacteria. Rhizobium bacteria “infect” the roots of legumes, forming nodules. The bacte- n/a Yes No
- 19. Revised February 2004 Page 19 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices ria then fix nitrogen from the air as proteins, which are shared with the legume host and adjacent plants. In organic grain production, forage legumes are included in rotations because they fix enough nitrogen to supply the needs of one or more subsequent seasons of non-leguminous crops. In pasture-based systems, legumes are commonly intercropped with grasses, to provide them with nitrogen. In humid regions many producers adjust liming and fertilization to meet the needs of the legumes in their forage mixes. Thus, legumes become the primary source of nitrogen to drive the system; additional manures and other organic fertilizers may then be applied according to the need for other nutrients like phosphate and potash. This reduces the problem of soil nutrient overloading that frequently occurs when farms import and apply large quantities of manure over many years. The inoculation of legume seed may be necessary to optimize nitrogen fixation. If you have observed good nodulation on the same legume crop in the last three to five years, re-inoculation may not be neces- sary. If inoculation is required, rhizobium inoculant can be purchased for this purpose. Be certain you are requesting an inoculant appropriate to the kind of legume you are planting. Also, be certain that you specify a rhizobium product that does not contain genetically engineered material. Organic growers have also learned the value of providing additional mineral nutrition—commonly in the form of lime, gypsum, and other rock powders—where nutrient deficiencies are not fully addressed by humus building practices. In circumstances where specific micronutrient deficiencies are found, cer- tain forms of synthetic micronutrients may even be used. When synthetic micronutrients are applied, their use must be justified to the certifier. A soil test or audit is the most common means of determining and documenting that a deficiency exists. Note that this requirement for testing does not apply to mate- rials that are naturally rich in a spectrum of micronutrients (glacial gravel dust, greensand, kelp meal, etc.), though soil auditing is still advisable in guiding their use. The organic community is divided as to what constitutes a good soil test and good soil test recommenda- tions. There is general consensus that, at the very least, the primary nutrients phosphorus and potash, pH, and organic matter should be monitored, though additional specific testing is required to identify micronutrient deficiencies. There is a growing segment of organic producers—especially livestock pro- ducers—that feels a good analysis must include cation exchange capacity and cation base saturation; that lime and potash recommendations will not be accurate without them, and that animal health weighs in the balance.32 A degree of perspective is required when managing organic soil fertility. Many of the inputs organic market farmers might employ (seed meals, kelp meal, fish emulsion, etc.) are not likely to be economical for fertilizing most forages. New producers should not become confused and think that such costly materials are necessary and should not fall into the “input substitution” trap. Examples of practical and cost-effective tools and strategies are provided in the questions that accompany this section. Still, many farm and ranch operations will need or benefit from some purchased “natural” fertilizers and amend- ments, especially during transition. With time, however, well-designed organic systems become pro- gressively more self-reliant and require fewer off-farm inputs. This is true of all organic systems, but especially true of livestock systems, where manure recycling works to close the loop of nutrient supply and demand. Another factor that is not often discussed when it comes to organic soil management is compaction. Compaction can occur on the soil surface and is evident as crusting; it can also occur as a sub-surface problem and is often called plowpan. In cropping systems, compaction is usually a symptom of excessive tillage or field operations that were done when the soil was too wet. In pastures, compaction can also be caused by grazing or field operations when the soil is too wet. It is appropriate for graziers to tempo- rarily confine livestock when pasturing can lead to excessive soil compaction.
- 20. Revised February 2004 Page 20 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 7.1 Have you taken the time to learn about your soil resource? Do you know its classification(s)? Erodability potential? Have you studied NRCS soil maps? 7.2 Do you test your soils on a regular basis? 7.3 Do you keep your current and past soil test results on file and use them to monitor the effects of your farming practices? 7.4 Do you make fertility management decisions based on soil test, tissue test, or other nutrient test results [§205.601(j)(6)]?33 Remember, application of concentrated micronutrients (sulfates, chelates, etc.) may be made only if the need is documented by soil or tissue tests. 7.5 Is there little or no evidence that your forage yield or quality suffers due to soil fertility problems? 7.6 Do you use approved cultural practices and materials to maintain or im- prove soil organic matter/humus content [§205.205(a) and §205.203]? Al- lowed practices and materials typically include but are not limited to the following: • rotational grazing and other forms of good grazing management • animal manures34 , composts, or other organic fertilizers35 • crop rotation (in mixed crop and livestock systems)36 • cover crops and green manures (in mixed crop and livestock systems)37 • minimizing tillage and length of time that soil remains bare • esoteric practices (See Text Box 7A) n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No Text Box 7A What Are Esoteric Practices? Esoteric practices are metaphysical methods for crop management and animal health that are not generally accepted in the conventional scientific community, nor are they easily explained using common scientific terminology. Those esoteric practices that are often applied to soil and plant management include radionics, dowsing, the use of biodynamic preparations, and astrological plant- ing. Most esoteric practices are allowed in organic production.38
- 21. Revised February 2004 Page 21 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 7.7 Do you use approved cultural practices and materials to manage soil fertility and crop nutrition [§205.205(c) and §205.203]? Allowed practices and materials typically include but are not limited to the following: • use of deep-rooted forage species to capture nutrients from the subsoil • use of catch crops in mixed crop and livestock systems39 • rock mineral fertilizers and amendments40 • use of mineral-rich organic fertilizers, manures, and/or composts41 • foliar fertilization42 • esoteric practices (see Text Box 7A) 7.8 Do you use approved cultural practices and materials to provide nitrogen to your forages [§205.205(c) and §205.203]? Allowed practices and materials typically include but are not limited to the following: • forage legumes in hay/pasture43 • rhizobial inoculation of legume seed • legumes in rotation in mixed crop and livestock systems44 • livestock manures or composts45 • N-rich organic fertilizers46 7.9 Do you use approved cultural practices and materials to conserve soil and water [§205.205(d) and §205.203]? Allowed practices typically include but are not limited to the following: • avoiding over- and under-grazing (See Text Box 7B) • controlling livestock access to riparian areas • appropriate conservation structures such as buffers, grass waterways, and terraces • contour cultivation and strip cropping in mixed crop and livestock systems • cover crops and conservation tillage in mixed crop and livestock systems 7.10 Are you making best use of the available solar energy that reaches your farm or ranch (see Text Box 7B)? Allowed practices that optimize the capture of solar energy include but are not limited to: • interseeding/overseeding annual forages • leaving enough forage height for rapid re-growth47 • selecting forage varieties best-adapted to your region • maintaining a diversity of forages, for example, warm- and cool-season grasses, legumes, and forbs, etc. • silvopasture n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 22. Revised February 2004 Page 22 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Text Box 7B Grazing as Solar Agriculture All agriculture ultimately runs on the energy of the sun. It may be the sunlight captured today in a growing crop through photosynthesis, or it may be the sunlight captured eons ago by primitive plants and stored as oil, coal, or natural gas—and eventually converted to nitrogen fertilizer, pesti- cides, and tractor fuel. Conventional agriculture is driven by reliance on the stored solar energy in fossil fuels, causing environmental problems, increasing the vulnerability of the food system, and spending the inheritance of future generations. Organic agriculture works to reverse the energy equation—reducing reliance on petroleum and focusing on the use of ambient renewable solar en- ergy. In contrast to systems that rely primarily on grain and mechanically harvested forages, pasture- based production is certainly much more solar-driven. Far less fuel is consumed by letting animals do their own harvesting and manure-spreading, and pasture-based production generally requires less imported fertilizer—much of which is energy intensive. The challenge for the grazier is to optimize the capture of solar energy. This is exemplified through management strategies that support densely growing forage that wastes little-to-no sunlight on bare ground. It involves selecting forage species that keep pastures green for as long as possible through- out the year. It also involves optimizing the use of legumes to fix nitrogen and deep-rooted broadleaves to extract subsoil minerals as a means of reducing outside fertilizer needs. Like all forms of organic farming, good organic grazing is very management intensive. In fact, what is popularly called management intensive grazing (MIG) or rotational grazing is well suited to organic systems. Fortunately, many good sources of information are available.48 7.11 Do you use allowed fertilizers and soil amendments (see Text Box 7C in this section) [§205.105 and §205.203]? Allowed fertilizers and amendments typically include but are not limited to the following:49 • rock dusts; includes most mined minerals, such as aglime50 • animal by-products • livestock manures • composts • plant materials and extracts • marine products and by-products • microbial inoculants and enzymes • natural soluble fertilizers with restrictions: υ potassium chloride (muriate of potash): allowed only if it is derived from a mined source and is applied in a manner that precludes buildup of chlorides in the soil [§205.602(g)]. Note that most commercial sources of potassium chloride are synthetic and NOT allowed in organic production. υ sodium nitrate (Chilean nitrate): allowed only if its use con- stitutes no more than 20% of the crop’s total nitrogen re- quirement [§205.602(h)]. n/a Yes No
- 23. Revised February 2004 Page 23 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Prohibited fertilizers and amendments include but are not limited to the following: x most synthetic or “artificial” commercial fertilizers, such as anhydrous ammonia, urea, ammonium nitrate, superphosphate, ammoniated phosphates, calcium nitrate, etc. [§205.105(a)] x biosolids; also known as municipal waste, sewage sludge [§205.105(g)] x most industrial by-products, especially if contaminated with heavy metals [§205.203(d)] x ash from manure burning [§205.602(a)] 7.12 Do you keep records of all fertilizer and amendment purchases, along with product labels? 7.13 If you are applying manure, compost, or another acceptable fertilizer or amendment, are you taking care to avoid contamination of surface and groundwater [§205.203(c)]?52 Text Box 7C What Inputs Can I Use On Organic Pastures and Range? One of the greater difficulties that organic producers face on a regular basis is determining whether or not a particular product or material may be used in organic production. Sad to say, the problems are real, but some basic clarifications will help. First of all, all natural or nonsynthetic materials can be assumed to be acceptable in organic production. There are a few exceptions, however, which will be explained shortly. Most organic producers and prospective producers have heard about the National List. The National List comprises §§205.600-205.619 of the National Standard; §205.601 and §205.602 are those sections directly pertinent to crop production, which includes forages. §205.601 includes synthetic materials allowed in organic crop production—for example, sulfur, insecticidal soap, etc.; §205.602 addresses natural, or nonsynthetic, materials that are prohibited, for example, ash from manure burning, nico- tine sulfate, etc. When considering commercial products, it is important that the grower be aware of all ingredients to determine that none are prohibited. If a full disclosure of ingredients is not found on the label, details should be obtained from the distributor or manufacturer and kept in the grower’s files. Note that such details should extend to inert ingredients. When in doubt about the acceptability of any material or product for certified organic production, contact your certifier. An important organization to know about is the Organic Materials Review Institute (OMRI).51 OMRI is a non-profit organization that evaluates products for suitability in organic production and process- ing. OMRI does not have status as a regulatory body. However, its decisions with regard to the acceptability of commercial products are highly respected and accepted by most certifiers. OMRI Listed products can be purchased and used with a high degree of confidence. Producers should be aware, however, that there are many acceptable products in the marketplace that have not been evalu- ated by OMRI and do not carry the OMRI Listed seal. Again, it is important to contact your certifier to verify whether a particular product or material can be used. n/a Yes No n/a Yes No
- 24. Revised February 2004 Page 24 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 7.14 If both organic and conventional pastures and crops are fertigated using the same equipment, are you taking steps to ensure that prohibited fertil- izer materials do not contaminate organic crops? It is a bad idea to irrigate organic crops with the same equipment used for conventional fertigation. However, any certifier that permits dual use will most likely insist on pro- tocols that include thorough cleaning and flushing, plus a date log for all cleanouts and irrigations. 7.15 Do you rotate feeding areas on your pastures? Using the same spot to feed hay or concentrated feeds results in manure accumulation in one place. This increases the hazard of nutrient pollution via run-off and leaching. It also leads to a fertility imbalance in the soil at the feeding site. Feeding hay on a permanent pad to collect manure is an alternative to site rotation. Notes on Organic Soil Management VIII. Weed Management in Pasture and Hay Crops Weeds are generally considered the greatest challenge to growing organic crops, whether they be veg- etables, grains, orchard trees, or pastures. The conventional farmer or rancher typically responds to weeds by spraying them with synthetic herbicides. Organic graziers do not have this option. If they are good managers, most will admit they really don’t need it, either. When good grazing practices are used, along with good soil fertility management, weeds become a minor issue. Forage species gradually crowd out most weeds, and any that remain are “grazed off” along with the more desirable plants. Beyond this, specific control measures are required only on an occasional basis. Most organic growers understand that many weeds occur simply because agricultural soil is left uncov- ered or unoccupied. 53 In pasture and range systems, bare soil commonly results from over-grazing. It can also result from undergrazing. Undergrazing encourages individual plants to become overly-ma- ture, dominating space and “shading out” emerging seedling grasses, legumes, and forbs. Mature plants n/a Yes No n/a Yes No
- 25. Revised February 2004 Page 25 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices are not stimulated to produce fresh growth, and nutritional quality plummets (see Text Box 15A of this workbook). When these overgrown plants are grazed or mechanically clipped, large areas of bare soil are exposed between plants—providing an excellent toehold for weeds. Grazing practices that maintain a dense stand of forage plants in their vegetative state (by not allowing them to go to seed) control many of the problem weeds that graziers are known to struggle with.54 One strategy that good graziers use to manage weeds that “escape” intensive grazing is multispecies graz- ing. For example, cattle typically do not eat woody plants; therefore goats—run alongside or in rotation with cattle—provide an excellent weed control complement. Sheep relish forbs that cattle may find unpalatable, and will clean up pastures that would otherwise require clipping.55 Organic producers also know that many weeds prosper under certain soil fertility conditions. Many weeds in the humid east are encouraged on low pH or low calcium soils.56 Liming to adjust pH and provide the correct balance of calcium and magnesium can often reduce pressure from certain weeds (for more details, see Section VII of this workbook). At the same time, fertilization can increase weed pressure. Applying large quantities of manure to the land frequently increases weeds, at least in the short term. In many such instances, the cause can be traced to weed seeds present in bedding materials. In others, however, raw manures have a stimulating effect on weed seeds already present in the soil. There are always fallback tools available when creative management either doesn’t succeed or is undone by weather or some other unexpected problem. Mowing, bushhogging, or selective hand-cutting are commonly relied upon; flame weeding or spraying with allowed herbicides may also be done. Even though a few “natural” herbicide products are now available, most are expensive, are restricted in their use, and seldom provide the same results as synthetic herbicides. Taking the big picture view of organic production, natural herbicides may be useful tools, but extensive reliance on them for weed management is inconsistent with traditional organic thinking and also contributes to producer reliance on off-farm inputs. The National Standard encourages reliance on whole system effects before employing specific practices or materials. See Text Box 8A for details on how weed control decisions must be made. A few words should also be said about weed management in mixed crop and livestock systems. A good humus-building rotation is one of the first steps to effective weed management in pastures and hay crops, as well as in row crops. A diverse rotation also reduces the number of niches that problem weeds can exploit from year to year.57 Sanitation is among the most under-recognized of good organic practices. Cleaning harvesting and mow- ing equipment between fields can prevent the distribution of weed seeds onto previously clean areas. Mowing or flaming ditchbanks and other areas adjacent to the field can work to prevent weed infesta- tion. However, because these areas can often serve as habitat for wildlife and beneficial insects, the timing of mowing and other operations should be carefully chosen.58 It is important that weeds not go to seed. Most weed species are capable of producing vast numbers of seeds that can create problems for years to come. There is growing evidence that biologically active soil—such as that encouraged under organic management—has an abundance of organisms that natu- rally reduce weed seed populations. However, this bonus of an organic system will not bail out bad management that allows annual reseeding of weeds.
- 26. Revised February 2004 Page 26 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Text Box 8A Weed and Pest Management Decisions §205.206—the Crop pest, weed, and disease management practice standard—requires that produc- ers use a three-level hierarchical approach in deciding how to deal with these problems. This can most easily be explained by designating these levels A, B, and C. Level A: The first line of defense in managing weed, insect, and disease pests generally comprises the most sustainable and systems-based practices. It emphasizes the fact that a well-designed and healthy organic system will naturally have fewer pest problems. Level A practices specifically include: • crop rotation and nutrient management [§205.206(a)(1)] • sanitation measures to remove disease vectors, weed seeds, etc. [§205.206(a)(2)] • cultural practices such as resistant or tolerant varieties, timing of planting, etc. [§205.206(a)(3)] Level B: Level B is the second line of defense, to be chosen if the basic systemic practices of level A are not sufficient to control the weed, insect, or disease problem. Level B practices generally include mechanical and physical practices that are traditional in organics, and the use of nonsynthetic or “natural” materials. Level B weed control options include: • mulching with fully biodegradable materials [§205.206(c)(1)] • mowing [§205.206(c)(2)] • grazing [§205.206(c)(3)] • cultivation and hand weeding [§205.206(c)(4)] • flame, heat, or electrical weeding [§205.206(c)(5)] • plastic mulches [§205.206(c)(6)] Level B insect/animal pest control options include: • introducing or augmenting predators and parasites [§205.206(b)(1)] • developing habitat for beneficial predators and parasites [§205.206(c)(2)] • nonsynthetic lures, traps, and repellents [§205.206(c)(3)] Level B crop disease control options include: • management practices (for example, fire, flooding) [§205.206(d)(1)] • application of nonsynthetic biological, botanical, or mineral inputs [§205.206(d)(2)] Level C: Level C is the third line of defense, to be chosen if the level of pest control required is not achieved after A and B control options are applied [§205.206(e)]. In such instances, you are allowed the wider use of biologicals and botanicals to control pests. You also have the option to use those materials included on the National List under §205.601—Synthetic substances allowed for use in organic crop production. If you anticipate the need for level C control measures, be sure that you indicate this in your OSP. Be specific about the control materials you might be using. Outline the indicators or thresholds you monitor that will trigger the use of those materials.
- 27. Revised February 2004 Page 27 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 8.1 Does your production system keep weeds at manageable levels? 8.2 Do you use approved practices or materials to control weeds [§205.206]? Allowed practices and materials typically include but are not limited to the following: • rotational grazing • grazing in a timely manner • multi-species grazing • competitive forage types and varieties • adjusting soil fertility, pH, etc. • interseeding/overseeding • higher seeding rates • mowing/bushhogging • allowed herbicides • flaming59 • hand weeding or chopping • machinery sanitation to prevent the spread of weed seed and rhizomes • release of biological control agents60 • use of crop rotation, nurse crops, smother crops, and cultivation in mixed forage and row-crop production systems • esoteric practices (See Text Box 7A) Prohibited materials typically include but are not limited to the following: x most synthetic herbicides [§205.105(a)] x heavy metal herbicides x soap-based herbicides—these may only be used in non-crop areas of an organic farm [§205.601(b)(1)] x micronutrient-based herbicides [§205.601(j)(6) Notes on Weed Management n/a Yes No n/a Yes No
- 28. Revised February 2004 Page 28 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices IX. Pest and Disease Management in Pasture and Hay Crops Pests and diseases play a vital role in natural selection by removing sick and unthrifty plants. Organic proponents argue that sickness in plants can be traced largely to poor nutrition and other stresses that result from poor crop and soil management.61 Organic producers maintain that organic soil-building practices will produce crops that are properly nourished and thereby less susceptible to attack by pests and diseases. Furthermore, organic producers and ecologists agree that natural biological pest control arises in a healthy organic system in the form of an active complex of natural predators and parasites that suppress pest populations. In actual practice, most managers of organic pasture and range rarely take additional action to control insect and disease pests. Where organic forages are concerned, maintaining a biodiverse ecosystem and using good fertility and cultural practices naturally keep pests and diseases from becoming a manage- ment problem. In such systems, pests are not eliminated but damage levels are low enough to be toler- ated. There are exceptions, of course—grasshopper plagues in the West and armyworm invasions in humid climes are good examples of circumstances where more pest control may be required.62 High-value organic hay crops can also have special pest problems. Alfalfa weevil is a good example of a pest that may well require additional attention.63 Insect and disease pest management is addressed in considerable detail in NCAT’s Organic Crops Workbook; it contains information that is not duplicated here.64 The National Organic Standard requires that pest management decisions be made in a hierarchical fash- ion. See Text Box 8A in Section 8 for details on how pest and disease control decisions must be made in organic systems. 9.1 Does your production system keep disease and insect pests at manageable levels? 9.2 Do you use approved practices to control plant disease and insect pests [§205.206]? Allowed practices typically include but are not limited to the following: • Integrated Pest Management (IPM) monitoring65 • animal predators (birds, bats, ducks, guinea fowl, etc.) • establishing and maintaining beneficial insect and wildlife habitats66 • resistant and tolerant crop varieties • sanitation • burning • crop rotation • flaming • mass trapping of insect pests • release of beneficial insects67 • application of allowed pesticides • esoteric practices (See Text Box 7A) n/a Yes No n/a Yes No
- 29. Revised February 2004 Page 29 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 9.3 Do you use allowed insect pest and disease control materials to manage forage pests [§205.206]? Allowed inputs typically include but are not limited to the following:68 • beneficial insects and other organisms69 • biological pesticides70 • botanical pesticides71 • insecticidal soaps72 • mineral-based pesticides • pheromones Prohibited pest and disease control materials include but are not limited to the following: x most synthetic insecticides, fungicides, miticides, etc. [§205.105(a)] x heavy metal-based pesticides x synthetic wetting agents [§205.105(a)] x nicotine sulfate and other tobacco products [§205.602(f)] x strychnine [§205.602(e)] 9.4 Do you keep records of all pest and disease control materials used, along with the product labels? 9.5 If you apply natural pesticides, do you do so in a manner that minimizes risk to non-target organisms and aquatic systems? Notes on Insect and Disease Pest Management X. Seeds and Planting Stock An entire section of the Federal Regulations—§205.204—addresses seeds and planting stock in organic production. This section is as applicable to hay and pasture crops as it is to vegetables and row crops. The first basic rule is this: organic seeds and planting stock MUST be used for organic production.73 When an equivalent organic crop variety is not commercially available, untreated conventionally grown seeds and planting stock may be used. See Text Box 10A for an explanation of planting stock; for clarifi- cation of equivalency and commercial availability, see Text Box 10B. n/a Yes No n/a Yes No n/a Yes No
- 30. Revised February 2004 Page 30 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices The second basic rule is one that has little relevance to forage systems, but needs to be mentioned any- way. It relates to annual transplants, which MUST be organically grown for organic production.74 The third basic rule is: seeds, annual seedlings, and planting stock used in organic production may NOT be treated with prohibited substances. There is one exception. Treatment with prohibited substances is allowed when the application of those substances is a requirement of Federal or State phytosanitary regulations [§205.204(a)(5)]. Conventional seed treatments are usually fungicidal; most fungicides used for this purpose are prohib- ited in organic production. Allowed treatments include natural materials—such as biological inocu- lants—and synthetic substances that are on the National List—such as seaweed extracts. The most com- mon example of allowed seed treatment is the inoculation of legume seeds with rhizobium bacteria. Since some rhizobium products can be genetically engineered or contain GE ingredients, it is important to make that determination in advance and obtain an allowed product. Organic growers must make certain that the seeds, transplants, and planting stock they use are not ge- netically engineered. Purchasing these items from a certified organic producer should guarantee that the propagation materials are not genetically modified and have a minimal degree of GMO pollen contami- nation. There is a particular provision in the Seeds and Planting Stock standard that may be relevant to you, especially if you establish or interplant any of your fields with perennial planting stock. Examples of perennial planting stock include grass sprigs, root pieces, and tree seedlings. §205.204(a)(4) reads “[n]onorganically produced planting stock to be used to produce a perennial crop may be sold, labeled, or rep- resented as organically produced only after the plant- ing stock has been maintained under a system of organic management for a period of no less than 1 year…” The popular interpretation of this section has been that pe- rennial planting stock may be obtained from nonorganic sources, but it must be under organic management for twelve months before the first harvest of an organic crop. This interpretation is consistent with many organic cer- tifier standards prior to federal regulation. If you read this provision carefully, however, it suggests an alter- nate interpretation. The alternative interpretation is that the twelve-month requirement applies to the sale of pe- rennial planting stock, not to its use once it has been placed in production. In other words, it is possible that this provision is pertinent to nursery production and not to the production of fruits, nuts, produce, or forage. The way your certifier chooses to interpret §205.204(a)(4) of the Standard can have implications if you are estab- lishing a Bermuda grass pasture, interplanting comfrey as a forage plant, or establishing an agroforestry sys- tem—especially one with forage trees such as locust. In many of these examples, there is a lag time of one year or more to allow for establishment, which removes much of the concern. However, the question of whether you Text 10A About Planting Stock The National Organic Standard lumps plant propagation materials into three ba- sic categories: seeds, annual seedlings, and planting stock. Seeds is self-explanatory. Annual transplants are seedlings of annual crops that have been removed from their original place of production and replanted elsewhere [§205.2]. Planting stock is defined as “[a]ny plant or plant tissue other than annual seedlings but including rhizomes, shoots, leaf or stem cuttings, roots, or tu- bers, used in plant production or propaga- tion [§205.2].” The most likely example of planting stock you might use in pasture or hay production is sprigs. Sprigs are clumps of stolons or rhizomes that are used to veg- etatively propagate certain grasses—espe- cially some warm-season species like Ber- muda grass.
- 31. Revised February 2004 Page 31 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices need to seek an organic source for perennial planting stock and document that search remains. Be certain to contact your certifier in advance of purchasing perennial planting stock to learn in full detail what your constraints might be. 10.1 Is all seed used either: • organically produced and/or • conventionally produced, non-GMO seeds that have NOT been treated with prohibited substances [§205.204(a)]? 10.2 Are only NON-genetically engineered seeds and planting stock used [§205.105(e)]? 10.3 If seeds and sprigs are produced on-farm, are they grown using organic methods and approved inputs [§205.204(a)]? 10.4 Where pasture is being established using perennial planting stock, such as sprigs, have you determined what your certifier requires with regard to sourcing [§205.204(a)(4)]? Text Box 10B Equivalency and Commercial Availability Equivalent variety is generally understood to mean a cultivar of the same type and similar plant characteristics when compared to the original preferred variety. For these purposes, type refers to the basic plant type (for example, there is a type of soybean called a haybean that is harvested as a forage. This is different from the standard food type and feed type of soybean that most farmers are familiar with); characteristics refers to factors such as color, pest resistance, and maturation. According to the National Organic Standard, an equivalent variety of seed or planting stock would be considered commercially unavailable if you could not locate an organic supplier. It might also be considered commercially unavailable if the organic supplier could not provide you with the quan- tity of seed you need, or if the available seed quality is substandard. Factors that might make seed quality substandard include the presence of seed-borne disease, very low germination percentages, high noxious weed seed content, and the like. The higher cost of organic seed and propagation materials is NOT considered an acceptable reason for using nonorganic seed or planting stock. Ultimately, the certifier must make the final decision on whether the use of nonorganic seed or planting stock is justified. You will need to present ample documentation to support any use of nonorganic seed, including a record of your attempts to locate organic seed sources. This usually entails making a record of phone calls, letters, or e-mails to and from seed suppliers documenting attempts to find an organic source. Most certifiers want clear indication that you have contacted at least three suitable suppliers.75 n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 32. Revised February 2004 Page 32 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 10.5 Do you retain documentation of all seeds, seed treatments (including rhizobial inoculants), and planting stock purchases? 10.6 Do you keep seed tags and empty packets on file? 10.7 If seed or plant treatments are used, have you determined that they are allowed and not genetically modified [§205.105(e)]? It is advisable to re- tain all documentation that proves a substance is allowable in organic pro- duction. Notes on Seed and Planting Stock XI. Field Equipment Equipment used for pasture management and for hay production and hauling must not be a source of contamination or a means by which organic and conventional products are commingled. 11.1 If harvesting, hauling, and crop handling equipment is also used for conventional crops, are cleanout protocols established and cleanout logs maintained? 11.2 If split or parallel production is done, is separate spraying equipment designated and clearly marked? n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 33. Revised February 2004 Page 33 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 11.3 If sprayers, planters, or dry material applicators are also used to apply prohibited materials for conventional production, are cleanout protocols clearly established and cleanout logs maintained? When seed planters are equipped with insecticide or fertilizer boxes and tanks that are NOT used for organic production, many certifiers prefer that these be removed or that the drive chains be disconnected when operating on organic acreage. 11.4 Are your sprayers, applicators, and spreaders properly calibrated to ensure precise application of materials? 11.5 Are your tractors, trucks, and other equipment free of fuel, coolant, and lubricant leaks? 11.6 Are all internal combustion engines properly tuned and maintained to ensure optimal fuel efficiency and reduce air pollution? 11.7 Is routine engine cleaning and maintenance of equipment done where it cannot contaminate production fields, harvested crops, or feeds? 11.8 Are fuels, lubricants, paints, coolants, and the empty containers that held these fluids stored where they cannot contaminate harvested crops? 11.9 Do you avoid field operations when soils are wet to prevent excess compaction and damage to soil structure? Notes on Field Equipment n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 34. Revised February 2004 Page 34 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices XII. Hay and Haylage Harvest Conventional hay harvesting sometimes involves the use of materials that might not be accepted in or- ganic production. Some preservatives and mold inhibitors, for example, may be prohibited in organic production. Individual products should be checked to determine whether they are natural (nonsynthetic) or are listed as an allowed synthetic input (See §205.601 of the National Standard for the list of allowed synthetics). Use of fungicide-treated twine might be prohibited; check with your certifier. 12.1 Are you harvesting your forages at an optimum stage to ensure high feed quality and continued viability of the stand? This question concerns good overall management and is not related to organic certification. Many pro- ducers sacrifice forage quality for quantity by harvesting when the crop is too mature. 12.2 If harvest-aid products are used, are they approved for organic production [§205.105]? Notes on Hay and Haylage XIII. Monitoring Your Pasture’s Performance The following questions highlight several indicators that can help you determine how well your organic management system is functioning; they can be reviewed annually and used to monitor your progress. Also included are additional questions that address special environmental concerns. 13.1 Does your pasture consist predominantly of desirable, well-adapted legumes, forbs, and grasses? n/a Yes No n/a Yes No n/a Yes No
- 35. Revised February 2004 Page 35 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 13.2 Are your forages usually at or near their optimum quality when you graze or harvest them? It is undesirable (and unprofitable) for pasture species to become rank and overly mature. Over-mature plants are not only low-quality livestock feed, they tend to shade out new seedlings, particularly clover, leading ultimately to bare ground between plants. (See Text Box 15A in Section XV of this workbook.) 13.3 Are your pastures generally free of subsurface compaction?76 Unless the pasture is located in a natural wetland, standing water is often an indicator of subsurface compaction. 13.4 Are your organic matter/humus levels stable or increasing [§205.203(c)]?77 13.5 If used, are tillage operations becoming easier under organic management from year to year? 13.6 Are earthworms and earthworm burrows evident in the soil?78 There are some circumstances where earthworms will not be found, even in well managed soils. Soils that routinely flood in spring, very arid soils, and some heavily glaciated soils in the northern tier of states may not have earthworms. 13.7 Does your soil emit a rich, earthy smell when tilled or dug? 13.8 Is dung beetle activity evident?79 Dung beetle activity should be vigorous on well-managed, organic permanent pastures and range. Less activity will be seen on pastures that are part of a mixed crop rotation, because tillage disrupts the life cycle of this insect. However, dung beetles are mobile and should still be active on rotation pasture. Note: the synthetic worming agent, ivermectin—allowed in organic production on a limited and emergency basis—is especially harmful to dung beetles [§205.603(a)(12)]. Where native dung beetle populations have been wiped out, they may be replenished with commercially available species. 13.9 Are your forages free of nutrient deficiencies under average conditions? Symptoms of nutrient deficiencies include chlorosis (yellowing), other discolorations of the leaves and stems, stunted growth, and consistently low yields. 13.10 Are your livestock free of disease conditions caused by excess soil nitrogen? Problems that may be caused or worsened by excessive nitrogen fertilization include grass tetany,80 prussic acid poisoning,81 nitrate toxicity,82 and fescue toxicity in high-endophyte fescue.83 n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 36. Revised February 2004 Page 36 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 13.11 Are your livestock free of disease conditions caused by deficiencies or im- balances of mineral nutrients? Some problems that may occur include grass tetany, which can be brought on by imbalances of magnesium and potas- sium as well as by excess nitrogen. 13.12 Is there an abundance of beneficial predatory and parasitic insects (lady bugs, lacewings, mantids, small wasps, etc.) under normal conditions? 13.13 Is erosion controlled on all your fields, paddocks, and access lanes [§205.203(a)]? 13.14 Are the riparian areas (stream banks) on your farm or ranch stabilized and protected?84 13.15 Are natural wetlands on your farm or ranch protected? 13.16 Are waterways on your farm or ranch protected from livestock and live- stock wastes [§205.239(c)]? It is a good idea to use fencing and water tanks to restrict stock from fouling natural streams. Notes on Pasture Performance XIV. The Organic Approach to Livestock Health The basic strategy to sustain livestock vitality in organic systems is the same as in crop production—that is, to identify and optimize those elements and conditions in nature that support health. Essentially, there are three elements that must be provided: optimum nutrition, low stress living conditions, and a reasonable level of biosecurity. There are a number of key ways in which these three elements are expressed in organic practice—especially in mixed production and pasture-based systems. These in- clude: n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 37. Revised February 2004 Page 37 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices • Providing balanced nutrition. This is reflected in the National Organic Program Regulations requiring organic feed [§205.237(a)]. Just as organic proponents argue that organic food is healthier for people, they likewise maintain that organic feed is healthier for animals. In mixed crop and livestock systems, the requirement for crop rotation results in a rich diversity of feeds. Similarly, in organic pasture-based systems, the absence of synthetic nitrogen fertil- izers encourages the growing of legumes alongside grasses, and the absence of synthetic her- bicides allows the growth of mineral-rich forbs; these contribute to the diversity of livestock diet. Note that artificial feedstuffs like synthetic urea are explicitly prohibited in organic pro- duction because they are found to be unhealthy for the animals. • Restricting exposure to toxins. Restricting toxin exposure is another reason for requiring organic feed. Residual pesticides and their breakdown products are additional sources of stress on livestock health—particularly to the liver, kidneys, and other systems responsible for eliminating poisons. • Excluding performance enhancers. Synthetic hormones and antibiotics are not allowed in organic production [§205.238(c)(3) and §205.238(c)(1)]. They are viewed as food contaminants by the organic community, and there are concerns over the development of antibiotic- resistant pathogens. These inputs push livestock to unnatural performance levels and mask the effects of unhealthy production systems. • Providing healthy and “natural” living conditions. [§205.239(a)] Living conditions are espe- cially important to livestock health. Buildings and facilities that are overcrowded, unsani- tary, lacking in fresh air movement, or are otherwise stressful to animals invite disease and injury. Living conditions for livestock must: ! permit livestock to exercise and to exhibit natural behaviors ! allow access to the outdoors ! provide access to pasture for ruminants ! offer animals protection from severe weather ! be safe and sufficiently sanitary ! not cause pollution • Avoiding excessively stressful management practices. All forms of stress increase suscepti- bility to injury and disease. Good organic managers strive to limit stressful handling of ani- mals as much as possible. This also applies to physical alterations—castration, ear notching, beak trimming, branding, etc. See Section XVIII of this workbook for more information on physical alterations. • Preventive practices. Good organic livestock management also involves the use of standard preventive practices, including sanitation, vaccinations, feeding of probiotics, quarantine of sick and newly purchased animals, and other biosecurity precautions to prevent difficult pest and disease problems from infecting organic stock. Your OSP should reflect a holistic health management plan that uses these principles and measures as a foundation. You must also indicate what practices, procedures, and materials will be used to deal with those animals that do become ill. These options are discussed in Section XIX of this workbook, “Treat- ment of Sick or Injured Livestock.” Finally, one aspect of organic animal health seldom discussed is the relationship between type and breed of livestock and its suitability for organic production in given climates and circumstances. The National Organic Standard addresses this concern in §205.238(a)(1). This section requires that producers choose livestock species and types suited to the site-specific conditions of the farm and those with natural resis- tance to prevalent diseases and parasites.
- 38. Revised February 2004 Page 38 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Notes on Organic Livestock Health XV. Organic Feed All certified organic livestock must be fed 100% organically grown feeds. Under ideal conditions most feed will be produced on-farm, which argues again for mixed (that is, integrated crop and livestock) production and pasture-based systems. Pasture-based systems have particular advantages in that ani- mals are allowed to harvest their feed themselves under circumstances that are a close approximation of natural conditions. Pasture-based production also reduces the fossil fuel energy used and the pollution generated by harvesting, feeding, and manure spreading operations. Text Box 15A Quality Feed from Pasture and Hay As good graziers know, the feed value of pasturage changes with the stage of plant growth. Grasses and forbs are most nutritious and digestible prior to flowering. Once these plants flower and begin to set seed, they become fibrous and their feed value declines precipitously. Novice graziers are too often deceived by the volume of forage that can be obtained by letting the pasture mature—the quantity may be great, but the quality is poor. Good grazing practice focuses on “harvesting” when pasture plants are young and lush. Skill, however, is required to ensure that overgrazing and/or selective grazing of the pasture does not result. Good grazing management is as much an art as it is a science. 85 Grazing management is such an important component of an organic livestock system that additional instruction through a grazing school is recommended. The same quality vs. quantity principle should be applied to the mechanical harvesting of hay or haylage. More feed value will be obtained by cutting a lush non-matured crop.
- 39. Revised February 2004 Page 39 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices The National Organic Program Regulations allow one exemption to the 100% feed requirement—if an entire, distinct dairy herd is under conversion to organic management, producers are permitted to feed up to 20% conventional feedstuffs for the first nine months of the transition, followed by 100% organic feed thereafter. See Section XXIII of this workbook for more details. The National Standard does not address the quality of water provided to livestock. However, it goes without saying that adequate quantities of clean water are essential to livestock health and to good pro- duction. One particular concern is excessively high nitrates—a growing problem in groundwater sources— that can cause reproductive problems.86 15.1 Do your livestock graze only certified organic pastures or rangelands [§205.237(a)]? 15.2 Are all farm-produced feeds and forages certified organically grown [§205.237(a)]? 15.3 Are all purchased feeds and forages certified organic [§205.237(a)]? 15.4 Are all your feed supplements and additives allowed in organic production? The following are specifically prohibited as livestock feed or feed supplements: x animal drugs and synthetic hormones [§205.237(b)(1)] x plastic pellets [§205.237(b)(3)] x urea [§205.237(b)(4)] x manure (including poultry litter) [§205.237(b)(4)] x slaughter by-products (including bone meal, blood meal, feather meal) [§205.237(b)(5)] x excessive amounts of feed supplements or additives [§205.237(b)(2)]87 x synthetic amino acids n/a Yes No n/a Yes No n/a Yes No n/a Yes No Text Box 15 B What Inputs Can I Use in Organic Livestock Production? The constraints on inputs for organic livestock production are similar to those for pastures and crops (see Text Box 7C). Natural (or nonsynthetic) materials can be assumed to be allowed. Exceptions will be discussed shortly. §205.603 of the National Standard is that portion of the National List that deals with synthetic sub- stances allowed for use in organic livestock production. §205.604 deals with natural (or nonsynthetic) substances prohibited for use in organic livestock production. §205.603 is a fairly lengthy and de- tailed list, which has a large number of individual entries; at the time of this writing, §205.604 only lists strychnine—a botanical—as prohibited. A few terms in the National List should be clarified. Feed supplements—one sub-category of allowed synthetics—refers to “[a] combination of feed nutrients added to livestock feed to improve the nutri- ent balance or performance of the total ration and intended to be: (1) Diluted with other feeds when fed to livestock; (2) Offered free choice with other parts of the ration if separately available; or (3) Further diluted and mixed to produce a complete feed” [§205.2]. Feed supplements are considered different from feed additives, which are defined as “…substance[s] added to feed in micro quantities to fulfill a specific nutritional need; i.e., essential nutrients in the form of amino acids, vitamins, and Continued on page 40
- 40. Revised February 2004 Page 40 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 15.5 Do you retain all feed tags and feed purchase records? 15.6 Do you retain all purchase records and labels from feed supplements and additives? 15.7 Do you have a backup plan in case of an on-farm feed shortage emergency, and is it outlined in your Organic System Plan? It is a good idea to include the names of feed brokers you would contact should the need arise. 15.8 Do your livestock have free access to fresh, clean water? n/a Yes No n/a Yes No n/a Yes No n/a Yes No Text Box 15B continued and minerals” [§205.2]. At the time of this writing, the only feed supplement listed is conventional milk replacer. The accompanying annotation indicates that replacers are for emergency use only and must not contain antibiotics, non-milk products, and may not come from livestock treated with bovine somatotrophin (BST), a.k.a. bovine growth hormone (BGH) [§205.603(c)]. To our knowledge, no organic milk replacers are currently on the market and the restrictions in the annotation eliminate most conventional products. Therefore, it is obvious that the intent of this provision is to discourage use of milk replacers and to encourage the feeding of whole organic milk from the herd or flock. Allowed feed additives, at this time, include several trace minerals and vitamins; no synthetic amino acids have yet been listed. An issue of special interest to the organic poultry community is the status of one particular feed additive, the synthetic amino acid methionine. Synthetic methionine has his- torical use in non-pasture based organic poultry production prior to the implementation of federal regulation. Supplemental methionine is not generally needed for the production of range- or pas- tured poultry in which the birds can balance their nutritional needs with insects, worms, and other wild foods that are naturally rich in this amino acid. In October 2003, the National Organic Program amended the National List, ruling that synthetic methionine may be used in organic poultry only until October 21, 2005 [§205.603(d)(1)]. This sunset provision was recommended by the National Organic Standards Board to allow producers time to find alternative natural sources before the com- plete ban on synthetic methionine goes into effect. Organic livestock producers can expect a considerable degree of confusion with regard to allowed synthetics—much more, in fact, than they will see with organic crop production. It is critical that you work closely and establish good lines of communication with your certifier. This begins with the development of a clear and detailed OSP, in which you outline all of the inputs you might use in all anticipated circumstances. It is also helpful for you to know about the Organic Materials Review Institute (OMRI).88 See Text Box 7C for a description of OMRI.
- 41. Revised February 2004 Page 41 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices XVI. Livestock Living Conditions, Facilities, and Handling According to the Regulations, organic livestock producers must establish and maintain living conditions that accommodate the health and natural behavior of their animals. The requirements reflect concerns for animal welfare and sustainability of production as well as for environmental quality. The means used to meet these requirements appear to be flexible at this time and accommodate a wide range of production philosophies. While adjustments may be made to accommodate stage of production, climatic conditions, and the envi- ronment, the Regulations [§205.239(a)(1)] require that all livestock have access to: • outdoor areas • shade • shelter • space for exercise • fresh air • direct sunlight Shelter must be designed to allow animals • opportunity to exercise [§205.239(a)(4)(i)] • protection from temperature extremes [§205.239(a)(4)(ii)] • adequate ventilation [§205.239(a)(4)(ii)] • comfort behaviors [§205.239(a)(4)(i)] • natural grooming and maintenance [§205.239(a)(4)(i)] • a low-hazard environment to prevent injury [§205.239(a)(4)(iii)] • bedding as appropriate to the species; must be organic if typically consumed [§205.239(a)(3)] Full confinement of livestock is permitted on a tempo- rary basis only. The circumstances that permit tempo- rary confinement of organic livestock are: • inclement weather [§205.239(b)(1)] • specific health and safety needs of the animal [§205.239(b)(3)] • risk to soil or water quality [§205.239(b)(4)] • the animal’s stage of production [§205.239(b)(2)] (see Text Box 16A) NOP requirements for living conditions highlight a number of conflicts with practices in use before federal organic standards were in place. A good example is the use of hoop houses for swine production. This al- ternative production system, which originated in Swe- den, is noted for being exceptionally humane. It does an exceptional job of allowing natural behavior while providing good sanitation and protection from severe weather. The drawback of this system—from an or- ganic perspective—is that current designs do not al- low for outdoor access.89 There is also a clash with some conventional biosecurity concerns. The most notable conflict involves outdoor Text Box 16A Temporary Confinement for Stage of Production An example of stage of production con- finement would be the final finishing of beef cattle. The National Organic Stan- dards Board recommends a finish stage of no more than 120 days of confinement. It is interesting to note, however, that re- search has shown that beef cattle can be fattened in a confinement-free pasture en- vironment if high-energy grain is provided to them—cattle typically prefer grain to forages. Producers might also consider that there is a growing market for grass- finished beef, which uses no supplemen- tal grains. Producing high-quality grass- finished beef requires excellent grazing management, however. Be sure to do your homework in advance.
- 42. Revised February 2004 Page 42 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices access for poultry. Conventional wisdom argues that outdoor access can increase the vulnerability of poultry flocks to disease. Avian influenza (AI)—for example—is considered one of the more serious threats to poultry production. AI is spread by wild fowl; however, outbreaks to date have been largely limited to confinement operations. This suggests that some factor in outdoor production—sunlight, perhaps—may act as a biocontrol. Still, arguments are made for confined production based on the threat posed by AI. Talk to your certifier about any plans you have to restrict outdoor access of your livestock. Be certain to outline your rationale in detail in your OSP. Ruminant livestock must have access to pasture or range. Organic pasture should be managed to pro- duce the quantity and quality of forage and browse suitable to the grazing species, stage of production, and stocking rate. See Text Boxes 3A and 15A for more information on pasture. Poor quality livestock housing and living conditions can become a health hazard for the animals, the farmer, and the farm help. These concerns are most common in conventional confinement production systems and should be less of a hazard in organic production. However, hazards can still occur. Specific things to watch out for include: • ammonia accumulation in temporary confinement buildings • dust and other airborne particulates • histoplasmosis and other avian-associated respiratory diseases • hantavirus and other diseases spread by rodents • safety of facilities and equipment to prevent accidents While the Regulations do not provide guidelines for artificial lighting, access to natural light and dark cycles can reasonably be interpreted as essential to the welfare of livestock. This may have particular relevance to the practice of forced molting. In conventional operations egg producers often attempt to synchronize and increase production by limiting laying hen access to food, water, and natural periods of darkness. Technically, forced molting can be seen as a violation of §205.238(a)(4), which requires the reduction of stress; §205.238(a)(2), which requires the provision of adequate feed; and §205.239(a), which requires living conditions that accommodate natural behavior. Therefore, it is not likely that many certifiers will allow the practice of forced molting. Another possible issue for organic egg producers is the fate of “spent hens”—layers that have ceased to be productive. If the birds are slaughtered for organic food, they should be treated in the same manner as broilers or other slaughter stock. However, if the birds are destroyed to create fertilizer, conventional feed, or simply for disposal, questions of humane handling and of site contamination may be raised by the certifier. Such practices should be discussed with the certifier in advance and outlined clearly in the OSP. In instances where conventional operations are being converted to organic production, treated wood may be permitted if it does not present a significant contamination hazard to animals or feed. However, new or replacement construction may not contain any prohibited materials, such as arsenate-treated wood, lead-based paints, creosote, etc., where they can contact organic crops or animals.90 Unnecessary stress reduces productivity, increases susceptibility to disease, reduces meat quality, in- creases the likelihood of injury to both animals and humans, and, therefore, should be minimized. The National Organic Standard is not prescriptive as regards livestock handling practices, and there is little guidance provided in the traditional organic literature. Fortunately, increased interest in humane and low-stress handling procedures ensures that such information is becoming more readily available. 91
- 43. Revised February 2004 Page 43 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 16.1 Are all your livestock given access to the out-of-doors, fresh air, sunlight, space to exercise, and shelter from inclement weather [§205.239(a)(1)]? 16.2 Are all your livestock provided with sufficient quantity and quality of feed and water to meet their health and welfare needs [§205.238(a)(2)]? 16.3 Are all your ruminant stock provided with pasture [§205.239(a)(2)]? 16.4 Do you feed hay or other feeds to ruminants when pasture or range forage is not available [§205.238(a)(2)]? Allowing animals to starve in order to save on costs or to preserve organic status is not allowed. 16.5 Do your animals on pasture or range have access to some form of protection from severe weather [§205.239(a)(1)]? 16.6 Are all wooden livestock buildings, corrals, handling facilities, fence posts, gateposts, board fencing, etc., constructed either with untreated wood or with other allowed materials [§205.206(f)]? If prohibited materials are present in older buildings, they must not present a contamination hazard. Prohibited materials may be used in circumstances where they cannot contaminate organic agricultural soil or livestock. 16.7 Do you use allowed materials and processes92 to control structural pests in livestock production buildings [§205.271(c) and §205.271(d)]? See Text Box 16B. n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No Continued on page 44 Text Box 16B Structural Pest Management Decisions Structural pests include a wide range of organisms that can damage structures, such as termites; use structures as habitat and a food source, like mice and grain weevils; or exploit the structural environ- ment to infect or infest another host animal, as mites and lice do. Like pasture weed, pest, and disease management, you are required to use a multi-level hierarchical approach in deciding how to deal with structural pests. In this case, there are four levels, which will be referred to as A, B, C, and D. Level A: The first line of defense generally comprises preventive measures. These Level A practices specifically include: • removal of pest habitat, food sources, and breeding areas [§205.271(a)(1)] • prevention of pest access [§205.271(a)(2)] • management of environmental factors [§205.271(a)(3)]
- 44. Revised February 2004 Page 44 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 16.8 Do you provide adequate bedding for temporary- and semi-confined live- stock when and where needed [§205.239(a)(3)]? Note: in circumstances where livestock typically consume a portion of the bedding, the bedding materials must be certified organic. 16.9 Do you store prohibited materials where they pose no danger of contami- nation to livestock? 16.10 Is housing cleaned and manure removed often enough to protect livestock health [§205.238(a)(3)]? 16.11 Do you use allowed materials to clean and sanitize housing units [§205.271(c) and §205.271(d)]? 16.12 Is your feeding equipment adequately maintained and cleaned to prevent injury to livestock and to prevent the spread of disease? 16.13 Are your watering systems adequately maintained and sanitized for the purpose of preventing disease or the spread of disease? Text Box 16B continued Level B: Level B is the second line of defense, to be chosen if the preventive practices of Level A are not sufficient to control pests. Level B practices generally include mechanical and physical practices. Level B practices include: • traps, light, sound, and similar physical controls [§205.271(b)(1)] • natural and allowed synthetic lures and repellents [§205.271(b)(2)] Level C: Level C is the third line of defense, to be chosen if the level of pest control required is not achieved after A and B control options are applied [§205.271(c)]. In such instances, you are allowed the wider use of nonsynthetic and allowed synthetics provided for on the National List. Level D: In the event that pest control actions A, B, and C do not adequately prevent or control facility pests, a synthetic substance not on the National List may be applied PROVIDED THAT the producer and the certifier agree on the substance, method of application, and measures to be taken to prevent contact with organic livestock, feed, or other organic products [§205.271(d)]. If Level D action is taken, you must update your OSP to reflect the application, how it was made, and the contamination control measures used [§205.271(e)]. If use of a prohibited pesticide is required by federal, state, or local laws or regulations, this does not compromise your organic status as long as measures are taken to prevent contamination of the live- stock, livestock feed, and other organic products [§205.271(f)]. n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 45. Revised February 2004 Page 45 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 16.14 Do you use allowed materials and processes to clean watering and feeding systems [§205.271(c) and §205.271(d)]? 16.15 If livestock must be transported long distances, are they provided with feed and water en route? 16.16 When moving, working, or otherwise handling your livestock, do you use methods that minimize stress to the animals? 16.17 Do you have a strategy for disposal of dead livestock that does not pose a health risk to other livestock, contaminate organic products, or pollute the environment [§205.238(a)(3)]? 93 Organic producers need to understand and follow state regulations regarding dead animal disposal. Composting is a desirable option in areas where it is permitted. 16.18 Are your production buildings and areas adequately protected from pesticide drift and/or infiltration by contaminated runoff water? 16.19 Are plastics and other wastes from the operation properly disposed of to prevent contamination or livestock health problems? See Text Box 16C. 16.20 Is all water runoff from production areas controlled or contained so that it does not contaminate surface waters or cause soil erosion [§205.239(c)]? 16.21 If you produce organic and conventional animals, do you segregate the animals or use some form of identification to ensure that commingling does not occur? n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No Text Box 16C Recycling and Waste Management Though it strives to be more environmentally friendly, organic farming, like conventional farming, will still generate waste materials that cannot be recycled on-farm. Common examples include plastic bale wrappers and natural pesticide containers. Recycling is the preferred option for plastic, aluminum, and glass wastes; landfilling should be used if recycling is not an option. Burning of plastics is strongly discouraged. If you must burn plastics, be certain that you do not burn them with wood or other materials that you plan to return to the field. Ash that has been contaminated with plastics is prohibited in organic crop production [§205.203(d)(4)]. n/a Yes No n/a Yes No
- 46. Revised February 2004 Page 46 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 16.22 Do you use organically approved methods and materials to manage weeds around facilities and buildings? Allowed practices and materials typically include but are not limited to the following: • thermal weeding (for example, flaming) • hoeing or hand-pulling • mowing/string trimming • herbicidal soaps [§205.601(b)(1)] 16.23 Are your buildings and production lots numbered and records maintained that document management history? Notes on Livestock Facilities XVII. Manure Management Manure is one of the most valued fertilizers on an organic operation. Capturing the full value of manure requires attention to how it is collected, stored, and spread on the field. This workbook section will focus on matters that relate to collection and storage. NCAT’s Organic Crops Workbook and other ATTRA pub- lications address its use as a fertilizer and soil amendment.94 National Organic Program Regulations state that organic producers “must manage manure in a manner that does not contribute to the contamination of crops, soil, or water by plant nutrients, heavy metals, or pathogenic organisms and optimizes recycling of nutrients” [§205.239(c)]. This has implications not only for how manure is applied to the field, but also for how it is handled and stored prior to spreading. Contamination is not the only issue. Unless properly handled, manure can also be a health issue for livestock and humans. Accumulating manure can breed flies, generate high levels of ammonia gas, and spread disease. The Regulations do not specify handling procedures, only that the system used not compromise organic integrity. Therefore, in theory and in fact, you have a number of alternatives for how you may manage manure. n/a Yes No n/a Yes No
- 47. Revised February 2004 Page 47 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Composting is one of the most reliable and time-honored means of conserving and recycling manure nutrients and is highly recommended for organic farming. It stabilizes the nutrients in manure, protect- ing them against volatilization and leaching. At the same time, it aids in the control of plant and animal diseases, flies, and weeds.95 Should you choose to compost your manure, there are a few constraints you should know about if you intend to sell compost to other organic producers or plan to use it yourself in the production of food crops. §205.203(c)(1) of the Regulations places strict limitations on how and when raw uncomposted manure can be applied. Uncomposted manure may not be used on food crops less than 120 days prior to harvest if the edible portion has contact with the soil; it may not be used less than 90 days before harvest on food crops where the edible portion does not have soil contact. Composted manure does not have these restrictions; however, the National Standard is very specific in its definition of compost. For compost to meet National Organic Program specifications, the initial carbon:nitrogen ratio of the beginning compost feedstocks must be between 25:1 and 40:1. A temperature between 131º F and 170º F must be maintained for 3 days when using an in-vessel or static aerated pile system. The temperature must be maintained between 131º F and 170º F for 15 days when using a windrow composting system; during that 15 days, the materials must be turned a minimum of five times [§205.203(c)(2)]. Further restrictions on compost-making also apply. These relate to the addition of other feedstock mate- rials. Allowed materials include bedding, food wastes, ground rock powders, Biodynamic™ prepara- tions, and those materials otherwise allowed as organic fertilizers or soil amendments. Materials that may NOT be added to the compost pile if it is to be used in organic production include most synthetic fertilizers [§205.105(a)], biosolids (sewage sludge) [§205.105(g)], pesticide-contaminated materials [§205.203(c)], materials contaminated with heavy metals [§205.203(c)], and plastics [§205.203(e)(1)]. No matter what system of manure management you elect to use, be certain that you do not use any prohibited materials in the process. Two specific examples can be cited. If you are using a barn lime or other rock powder to absorb and deodorize animal wastes, be aware that hydrated lime is specifically prohibited in §205.603(b)(3); superphosphate is also prohibited [§205.105(a)]. In conventional lagoon systems, stabilizing chemicals are frequently added. Be certain you are using an allowed stabilizer for organic management. Consult your certifier when in doubt. Controlling manure flies is another issue. The great majority of synthetic insecticides and synthetic in- secticidal baits are prohibited in organic production. Good sanitation procedures, composting, and some common sense management can go a long way in reducing the manure fly problem. These fundamental steps can be backed up with biological and allowed insecticidal controls. Refer to Text Box 16B for guid- ance in how to make decisions for controlling these pests. 17.1 If manure is stockpiled or lagoon-stored, do you take measures to avoid leaching and contamination of surface waters[§205.239(c)]? 17.2 If a lagoon system is used to store manure, is the capacity of your system sufficient to eliminate the hazards of dike failure or overflow during heavy rains[§205.239(c)]? 17.3 Is your production facility, including all lots and pens, managed to prevent contamination of ground and surface waters by manure leaching and runoff [§205.239(c)]? n/a Yes No n/a Yes No n/a Yes No
- 48. Revised February 2004 Page 48 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 17.4 Do you use organically acceptable means to control manure-breeding flies [§205.105(a)]? Allowed options include but are not limited to: • sanitation • manure composting • odor management • parasitic wasps, hister beetles, beneficial nematodes, or other introduced biological controls96 • flying insect traps97 • diatomaceous earth • botanical pesticides 17.5 Do you use organically acceptable means for odor management [§205.105(a)]? Allowed options include but are not limited to: • manure composting • microbial inoculants (source must be GMO-free) • botanical extracts • manure drying • rock powders 17.6 If you produce and stockpile compost, do you take precautions to ensure that surface and groundwater contamination does not occur[§205.239(c)]? 17.7 Do you keep your compost free from contamination by prohibited substances? 17.8 If you use your compost for food crop production or sell it to other organic producers, do you keep compost production records that include daily tem- perature readings and frequency of windrow turnings?98 Notes on Manure Management n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 49. Revised February 2004 Page 49 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices XVIII. Physical Alterations Physical alterations refer to irreversible procedures that alter the natural appearance or function of ani- mals. They are typically used for five reasons in livestock management: 1) for purposes of identification, for example branding, tattooing, ear tags, ear notching 2) to prevent injury from fighting or cannibalism among animals, for example debeaking, dehorning, tail clipping, castration 3) to prevent damage to pastures, for example nose rings in hogs 4) to improve product quality and marketability, for example castration, caponization; and 5) for livestock health, for example tail docking in sheep. According to the National Organic Standard, physical alterations are permitted “as needed to promote the animal’s welfare.” Convenience for the producer should not be construed as “animal welfare.” For example, the docking of tails on dairy cattle may serve the convenience of the dairyman by removing the irritation occasioned by being slapped in the face by a wet tail. However, a cow’s tail has definite pur- pose in fighting off flies and its removal is not likely to be in the animal’s best interests. A further requirement of the Organic Standard is that physical alterations be done “in a manner that minimizes pain and stress” [§205.238(a)(5)]. For example, it is desirable to castrate male calves at a very young age, as opposed to later in life when the pain and stress is much greater. Another example is the use of freeze branding using dry ice, which is considered more humane than fire branding using electri- cally- or fire-heated metal. 99 Since the Regulations are not specific about which practices are and are not acceptable, there is no consis- tent agreement among certifying bodies (or even among animal welfare advocates) as to what alterations should be allowed. If you are planning to use any physical alterations on your livestock, clearly outline in your OSP WHAT you plan to do, HOW you plan to do it, and WHEN it will be done. Be especially clear in explaining WHY you plan to do the alteration. These alterations should be justified in the plan with regard to their necessity for livestock welfare, product quality, and audit control. It is also wise to indicate whether the planned alterations will be a routine practice or a contingency in the event of ex- treme animal behavior. You are strongly advised to confer closely with your certifier to determine what is and is not an acceptable practice for your operation. 18.1 Have you discussed all planned and contingency physical alterations with your certifier and outlined them in your OSP? 18.2 Are you selecting physical alteration methods and performing them in a manner that causes the least amount of pain and stress to your animals [§205.238(a)(5)]? Notes on Physical Alterations n/a Yes No n/a Yes No
- 50. Revised February 2004 Page 50 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices XIX. Treatment of Sick or Injured Livestock Despite the best efforts of organic management, some livestock will inevitably get sick or injured and require treatment. At the time of this writing, many routine veterinary medicines—most notably antibi- otics—are prohibited. Animals treated with prohibited medications cannot be sold as organic. This sometimes leaves the producer in a quandary—should an animal be treated at the cost of its organic status, or should one gamble on hopes of recovery without treatment, even if the animal suffers? In fact, the National Organic Regulation does not allow you that choice—§205.238(c)(7) states that the producer of organic livestock must not “[w]ithhold medical treatment from a sick animal in an effort to preserve its organic status. All appropriate medications must be used to restore an animal to health when methods acceptable to organic production fail…” Because few conventional medications are allowed, organic producers have been encouraged to explore complementary and alternative veterinary medicine (CAVM)100 treatment options, such as herbalism, homeopathy, radionics, acupuncture, chiropractic, and other non-traditional modalities. CAVM treat- ments can certainly be viewed as “appropriate medications” as long as they provide needed relief and care for the animal. Keep in mind that no treatment, conventional or alternative, will always be success- ful. On a practical level, one of the wisest things you can do is to find a veterinarian who understands and supports your choice to be organic. With such a vet as your “herd health partner,” it is much easier to develop treatment strategies that are holistic and NOP compliant, and that avoid the accidental use of prohibited medicines when suitable alternatives are available.101 Of course, this is easier said than done. Currently, the number of practicing veterinarians that both understand the NOP Regulations and are trained in alternative modalities are still few and far between. When working with conventionally minded veterinarians, you must take extra precautions. Many vets will give antibiotic injections without asking or even explaining what they are doing. You will need to clarify your situation at the outset. You may need to provide the alternative medication and even administer it yourself. Keep in mind that many alternative therapies work slowly and are more effective with chronic conditions than acute ones. Fi- nally, if the alternative treatments you try should fail, you will need to resort to conventional treatments and accept the loss of organic status for that animal. It is expected that many new-to-organic producers will attempt to adapt conventional confinement pro- duction systems to organic. This raises a specific concern: that some producers might design production systems to “sacrifice” a high percentage of livestock to disease, thus circumventing the intent of the Regulations, which is that the production system itself be healthy. For example, a producer might plan on raising too many animals in semi-confinement with the idea that he or she will treat any visibly sick animals with antibiotics, and sell the untreated “survivors” as organic. Such Plans are not considered acceptable. Producers are warned against developing OSPs that anticipate high culling percentages and subsequent conventional sales as a health management strategy. 19.1 Are you using organically acceptable strategies and techniques to treat, control, and/or prevent diseases and injuries in livestock [§205.105]? Allowed options include but are not limited to: • selective breeding • quarantine of newly purchased, injured, or diseased animals • nutritional therapy • aseptic protocols during vaccinations, physical alterations, and surgical procedures n/a Yes No
- 51. Revised February 2004 Page 51 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices • use of electrolytes, glucose, dextrose • vitamin therapy • probiotics (includes colostrum—must not be from a genetically engineered source) • iodine • hydrogen peroxide • vaccination102 • herbal remedies103 • homeopathy104 • flower essences, and related therapies • acupuncture105 • chiropractic • aromatherapy • radionics106 • reiki107 Prohibited materials and techniques include but are not limited to: x antibiotics [§205.238(c)(1)] x genetically modified probiotics [§205.105(e)] x most conventional veterinary medications 19.2 Do you keep records of all animal health products used, along with their purchase receipts and labels?108 19.3 Do your herd/flock health records accurately document all health treatments given and/or procedures performed?109 19.4 Are your herd/flock health records adequate to track animals treated with prohibited materials to ensure that they are NOT sold as organic [§205.236(c)]? 19.5 If livestock become sick or injured, do you take action and apply the necessary medications to restore health regardless of the consequences to the animal’s organic status [§205.238(c)(7)]? 19.6 Are you using allowed medications solely for the purposes of restoring animal health [§205.238(c)(2)]? This is not a trick question—you may not administer any animal drug to enhance growth or performance. Medications are allowed only for the treatment of injury or disease. 19.7 Do you have a working relationship with a veterinarian? n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 52. Revised February 2004 Page 52 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Notes on Sick or Injured Livestock XX. Internal and External Parasite Management The first line of defense in parasite management—especially of internal parasites—is optimal nutrition. Livestock provided with ample quantities of good quality organic feed for their stage of growth have an excellent chance of staying a step ahead of parasites. The second line of defense is biodiversity. The diversity of a well-managed organic farm or ranch goes a long way towards reducing pressure from internal and external parasites. Biodiverse landscapes sup- port biological control. Furthermore, the variation in cultural practices, controlled grazing, and the like reduce the niches these pest organisms require to thrive. Still, many organic producers consider para- sites one of their greatest challenges, and additional management and inputs are often required to keep these pests under control. Producers are encouraged to investigate cultural practices before purchasing costly off-farm inputs. This is especially true of alternative pesticides, which can be quite expensive. There is also the matter of safety. Simply because a pesticide is natural does not mean it is safe. Botanicals, in particular, can be toxic to humans, livestock, and a wide range of non-target organisms. Be certain to follow label instruc- tions should you need to use them. Text Box 20A Grazing and Parasite Management There are a number of strategies and techniques that graziers can use to reduce problems with internal and external parasites. Most of them require a good degree of management skill and a controlled grazing environment. For example: • by controlling how low pasture forages are grazed, one can reduce the intake of internal parasites, since they tend to reside on the lower portions of plant stems and leaves Continued on page 53
- 53. Revised February 2004 Page 53 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 20.1 Are you using organically acceptable strategies and techniques for preventing and controlling internal parasites in livestock [§205.105]? 110 Among the preventatives and treatments for internal parasites are a number of modalities that might be considered unconventional and experimental. They are, however, allowed for use in organic production systems. Options include but are not limited to: • pasture rotation (see Text Box 20A in this section of the workbook) • controlled grazing (see Text Box 20A in this section of the workbook) • multi-species grazing (see Text Box 20A in this section of the workbook) • dragging or clipping pasture to disperse manure piles • fecal sampling as a monitoring tool • selective breeding for resistant stock • sanitation • herbal treatments (see Text Box 20B in this section of the workbook) • diatomaceous earth (see Text Box 20B in this section of the workbook) • ivermectin (see Text Box 20B in this section of the workbook) • electrotherapies111 • radionics112 Prohibited materials and techniques include but are not limited to: x most synthetic worming agents [§205.105(a)] x ionophores—antibiotics that control protozoan parasites [§205.238(c)(1)] Text Box 20A continued • by rotating pastures on a timely basis, internal parasites are allowed to hatch and die before the host livestock return to the field—a self-cleaning process • since most internal parasites are not shared across species, both multi-species grazing or rotational grazing with different species are viable strategies for reducing parasite loads • allowing younger, more parasite-susceptible stock to graze first on fresh pasture; older, less susceptible stock can follow when forage is shorter and the parasite hazard increases • following cattle with pastured or ranged chickens is a strategy for reducing both inter- nal and external parasites—particularly flies. Poultry “disassemble” manure pats, destroying eggs and feeding on larvae. Continued on page 54 Text Box 20B About Organically Acceptable Dewormers If you farm or ranch in a region with high internal parasite pressure, then you have a particularly difficult challenge. As you will see, there are very few organically acceptable products available to assist you. Diatomaceous earth (or DE) is often touted as a parasiticide and is commonly used by organic producers. DE is manufactured from the fossilized remains of tiny sea organisms called diatoms, n/a Yes No
- 54. Revised February 2004 Page 54 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Text Box 20B continued which are mined and ground to make a fine “shell flour.” The particles of the flour have sharp edges that pierce the exoskeleton of parasites and insect pests, causing damage that leads to their deaths. The sharp edges are apparently small enough that they cause no damage to the intestinal tracts of livestock. When used, DE is often mixed with feeds, with free-choice supplements, or is provided as free choice on its own. The only direct physical hazard comes from breathing too much DE; silicosis and related lung conditions can result. An indirect—and possibly more serious hazard—may result from failure to control a significant parasite problem. While heavily promoted as a dewormer, the efficacy of DE is open to question. Some veterinarians believe that the positive effects attributed to DE actually arise from other aspects of good organic management and diatomaceous earth is accorded more credit than it deserves. However, the jury is still out on this matter and DE should not be entirely discounted as a deworming agent. If you choose to use DE, make certain that it is part of a more comprehensive parasite management plan. Also, be certain that you are using an organically acceptable form of diatomaceous earth. There are formulations of diatomaceous earth intended for use in swimming pool filters and similar applica- tions. These forms are not allowed. Several herbal agents113 are also reputed to be useful for deworming livestock. Garlic is most often mentioned, though other plants and plant extracts have also been used. It has even been suggested that raw garlic be added to the feed. If you choose such a strategy, be certain to consult with your certifier. The garlic or other plants used in this manner may need to be organically grown. Unless “home-grown,” herbal dewormers are likely to be expensive and their efficacy is not well docu- mented as yet. At the time of this writing, one synthetic parasiticide—ivermectin—is allowed for limited use in organic production. Ivermectin is prohibited in slaughter stock, but is allowed for emergency treat- ment of dairy and breeder stock when management strategies do not prevent infestation. Milk or milk products from a treated animal cannot be marketed as organic for 90 days following treatment. In breeder stock, treatment cannot occur during the last third of gestation if the progeny will be sold as organic and must not be used during the lactation period of breeding stock [§205.603(a)(12)]. One of the principal concerns surrounding the use of synthetic dewormers is their effect on the ecology of soil life—especially those organisms involved in the breakdown and incorporation of manure. Ivermectin is known to decimate dung beetles, one of the main organisms involved in manure recycling. It is wise, therefore, to make limited use of this material. 114 The National Organic Standards Board has brought up the possibility of removing ivermectin from the National List at some time in the near future. It may or may not be replaced with another syn- thetic option.
- 55. Revised February 2004 Page 55 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 20.2 Are you using organically acceptable strategies and techniques to control or prevent flies, mosquitoes, and external parasites [§205.105]? Options include but are not limited to: • pasture rotation • multi-species grazing (see Text Box 20A in this section of the workbook) • dragging or clipping pasture to disperse manure piles • manure management (see Section XVII of this workbook) • sanitation115 • ventilation and moisture control • screening • fly parasites and other beneficials116 • bat conservation117 • purple martins118 • walk-through fly traps119 • sticky traps • flying insect traps120 • electric bug zappers • biological pesticides • diatomaceous earth • botanical pesticides and preparations Prohibited materials and techniques include but are not limited to: x most synthetic insecticides and acaricides121 [§205.105(a)] x synthetic insecticidal ear tags [§205.105(a)] Notes on Parasites XXI. Assessing the Vitality and Health of Your Organic Livestock The following questions can assist you in assessing the effectiveness of your organic production system with regard to livestock health.122 It is highly advisable to also utilize the services of your veterinarian. Arrange for routine herd health checks to be done and give serious consideration to your veterinarian’s advice and observations. See Section XIX of this workbook for more background. n/a Yes No
- 56. Revised February 2004 Page 56 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 21.1 Do your livestock appear well fed (that is, in good body condition for age of animal, no ribs showing, etc.)? 21.2 Is there a low incidence of ascites and other metabolic diseases123 in your poultry flock? 21.3 Do your animals have healthy coats? 21.4 Are your animals’ eyes bright and clear? 21.5 Are your animals active and responsive? 21.6 Are the teats and udders of lactating animals in good condition? 21.7 Are your animals’ feet/hooves in good condition? 21.8 Is there little evidence of sores, swelling, or inflamed tissues on your live- stock? 21.9 Are there few incidents of injury and illness? 21.10 Is there little evidence of fighting and aggression? 21.11 Are your animals typically calm and content? 21.12 Are veterinary visits primarily for preventive care? n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 57. Revised February 2004 Page 57 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Assessment Notes XXII. Predator Management Wild and domestic predators can be a problem in almost any livestock system, causing costly injuries and death losses. However, looks can sometimes be deceiving. Producers should first determine whether the animal carcass being devoured was actually killed by the suspected predator or whether it died from another cause, making the “suspect” nothing worse than a scavenger. Such assessment can prevent unnecessary expense and reduce negative impacts on wildlife diversity and neighbor relations. 22.1 Are you using organically acceptable strategies and techniques to control predation of your livestock124 [§205.105]? Options include but are not limited to: • night confinement of stock • lambing in secure sheds and lots • guard animals125 • noise, light, and visual devices • fencing • live trapping and relocation • proper disposal of dead animals (see Text Box 22A in this section of the workbook) Prohibited materials and techniques include but are not limited to: x poison baits—§205.604(a) specifically prohibits strychnine n/a Yes No Text Box 22A Disposing of Dead Livestock Dead livestock and unmanaged livestock processing wastes can be a source of disease and can at- tract scavengers and predators that can become a danger to live animals. Furthermore, the potential exists for highly valued scavengers, such as bald eagles, to become infected with the diseases of domestic stock; it may also disrupt their natural feeding behaviors. Composting is a desirable means of disposal. Most Cooperative Extension offices have information on composting dead livestock.126
- 58. Revised February 2004 Page 58 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Notes on Predator Control XXIII. Source of Animals Compared with most organic standards across the globe, the USDA’s National Organic Standard is more strict with regard to the source of livestock. The history of each animal is a major determining factor in whether it can eventually be sold or represented as organic. Some animals obtained from nonorganic sources can be transitioned into organic production under certain conditions and if specific criteria are met [§205.236]. Please refer to Figure 2 “Origin of Livestock.” It is a flowchart published by the National Organic Pro- gram on April 11, 2003 to help producers understand the requirements of the Regulation. Further detail and elaboration follow: • Mammalian livestock (cattle, sheep, hogs, goats, rabbits, etc.) raised for meat production must be under full organic management beginning no later than the third trimester of gestation. For example, bred cows from conventional sources must be under full organic management at least three months prior to calving for the offspring to be considered organic. • Livestock used as breeder stock may be obtained from a nonorganic operation. However, while they may be used to produce organic offspring, the breeder animals themselves may not be sold as organic slaughter stock. • Poultry chicks from conventional sources are allowed for the production of organic meat and eggs only if raised organically beginning the second day of life, that is, as “day-old chicks.” Older birds grown under conventional management are only allowed as breeder stock for production of hatching eggs. • Dairy animals from conventional sources must be maintained under organic management for a minimum of one year prior to selling, representing, or using their milk or milk products as organic. • If an entire, distinct dairy herd is under conversion to organic management, you are allowed to feed up to 20% conventional feedstuffs for the first nine months of the transition, followed by 100% organic feed thereafter. Dairy offspring whose dams receive less than 100% organic feedstuffs during the final trimester of pregnancy may not be marketed as organic meat ani- mals. Note that there are several ways to interpret the 80/20 Rule. Contact your certifier! • Once a dairy herd has been fully transitioned into organic status under the 80/20 Rule, all of the herd’s milk-producing animals must be under organic management from the third trimes- ter of gestation.
- 59. Revised February 2004 Page 59 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices FIGURE 2 Section 205.236 of the National Organic Program requires that livestock products that are to be sold, labeled, or represented as organic must be from livestock under continuous organic management as represented below. Are you raising POULTRY? Are you raising DAIRY ANIMALS? Did you convert an ENTIRE DAIRY HERD after October 21, 2002, and use the feed exemption? YES YES NO NO YES The POULTRY must be under continuous organic management no later than the second day after hatching. All future DAIRY ANIMALS must be under continuous organic management from the last third of gestation. The DAIRY ANIMALS must be under continuous organic management beginning no later than 1 year prior to production. ORIGIN OF LIVESTOCK April 11, 2003 The ANIMALS must be under continuous organic management from the last third of gestation. NO
- 60. Revised February 2004 Page 60 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices There is considerable confusion on how to interpret the National Standard regarding replacement dairy animals. As stated in §205.236(2), one year of organic management is all that is required for dairy animals before their milk may be marketed as organic. This suggests that conventional heifers may be acquired and “transitioned” as needed for replacement or herd expansion. However, §205.236(2)(iii) states that once an entire herd has been converted, all dairy animals must be organic from the last third of gesta- tion—the same as the requirement for slaughter stock—implying that you cannot acquire further con- ventional heifers and convert them to organic production. The two sections are clearly contradictory. A resolution for the “replacement heifer” conundrum will likely require a change in the regulations, though this could take considerable time to come about. The NOSB is currently recommending a conser- vative interpretation. The language they recommend as a change in the Regulation states: “On existing organic dairy farms all replacement or expansion dairy animals shall be under continuous organic man- agement from the last third of gestation.” If the conservative interpretation is enforced, it has significant implications for the raising of dairy replacements. No matter what interpretation is chosen, the National Standard varies considerably from what some producers were accustomed to prior to Federal Regulation. To retain organic status, dairy calves may not receive antibiotics or any other prohibited medicines at any time. They may not be fed conventional milk replacers, except in emergencies (see Text Box 15B for details). Organic producers also may not sell or “farm out” their organic heifer calves, ewe lambs, or doe kids to a conventional operation with the intent of re-acquiring and re-integrating those animals into the organic dairy herd at a future date. In light of all the uncertainties surrounding replacement dairy animals, it is most important that you clarify your strategy in your OSP and consult with your certifier in advance. Finally, it should be mentioned that artificial insemination (a.i.) is permitted in organic production. An- tibiotics used to preserve a.i. semen are allowed at the recommendation of the NOSB. However, the use of hormones to synchronize estrous cycles for breeding is not allowed. 23.1 If livestock have been acquired from an organic source, do you have verifi- cation of their organic status [§205.236(c)]? 23.2 Do you retain purchase records for all acquired livestock? 23.3 Do you keep adequate feed and management records to document the tran- sition of conventional dairy animals to organic status [§205.236(c)]? 23.4 Do you keep adequate records to document the organic management of breeder stock to ensure the organic status of their offspring [§205.236(c)]? 23.5 If you are raising organic livestock (other than poultry) for slaughter or for production of other non-dairy livestock products, have the animals been under continuous organic management from the last third of gestation [§205.236(a)]? n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 61. Revised February 2004 Page 61 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 23.6 If you are raising organic poultry, have the birds been under continuous organic management beginning no later than the second day of life [§205.236(a)(1)]? 23.7 If you are producing organic milk or milk products, is the milk coming from animals that have been under continuous organic management for no less than 12 months [§205.236(a)(2)]? 23.8 If you chose to convert your entire dairy herd to organic production at one time, have you provided a minimum of 80% organic feed for the first 9 months of the 12-month conversion period [§205.236(a)(2)(i)]? 23.9 If you chose to convert your entire dairy herd to organic production at one time, have you provided a minimum 100% organic feed for the last 3 months of the 12-month conversion period and continued to provide 100% organic feed thereafter [§205.236(a)(2)(ii)]? Notes on Source of Animals XXIV. Feed Storage There are several areas of concern regarding feed storage. The first involves preserving feed quality. In large part this necessitates sound design and construction of bins, cribs, barns, and other storage struc- tures, followed by good maintenance. Feed quality also involves controlling pests. All pest control must be done using organically acceptable methods and materials. See Text Box 16B for more information on facility pest management. A second concern of feed storage is contamination. Care must be taken that feed not become contami- nated by prohibited materials like fuels, lubricants, and cleaning agents. Wood treated with prohibited chemicals must not be used where it can contact stored feeds. A contamination hazard can also be pre- sented by baling twine that has been treated with a fungicide to prevent rotting. Be certain to check with your certifier—they may not even allow you to use treated twine. Treated twine—and plastic twine for that matter—must be properly disposed of. Used twine should not be left where animals can chew it or n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 62. Revised February 2004 Page 62 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices get tangled in it; it should not find its way onto manure or compost piles, and it definitely should not be left or spread in the field. Dumping in a proper landfill appears to be the soundest means of disposal. For more information, see Text Box 16C. The third area of concern is the hazard of commingling organic with conventional feeds. This is prima- rily an issue for split operations. 24.1 Are the floors, ceilings, and walls of your feed storage bins in good condition? 24.2 Are the floors, ceilings, and walls of your feed storage bins constructed of non-treated lumber or other materials that will not contaminate organic crops? 24.3 Are your feed storage bins sealed to prevent access by rodents, birds, and other pest animals? 24.4 Where both conventional and organic feeds are handled and stored, are organic and conventional storage bins segregated and clearly marked? 24.5 Where feed bins and storage areas have mixed use (both conventional and organic storage), are there clean-out protocols, clean-out logs, storage records, and visible labeling that clearly establish whether the contents are organic or conventional? 24.6 Are prohibited materials stored away from organic storage units? 24.7 Are appropriate sanitation procedures used? 24.8 Are you using organically acceptable pest control products and practices?127 See Text Box 16B for information on how pest control decisions should be made. Approved pest control techniques and materials include but are not limited to: • fencing/screening/netting • good sanitation • noisemakers • trapping • release of beneficial predators/parasites • barn cats • diatomaceous earth • approved biological pesticides • approved botanical pesticides • vitamin D3 (for rodents) n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 63. Revised February 2004 Page 63 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 24.9 Are stored feeds reasonably free of pest problems? 24.10 Do storage facilities meet farm/ranch needs for capacity and the ability to segregate feeds as needed? 24.11 If some feeds are stored off-farm, are these storage units either certified organic or included in your farm’s inspection and certification? 24.12 If you are using plastic bale wrappers, plastic silage bags, plastic baling twine, or are allowed to use treated baling twine, are the wastes properly disposed of to ensure organic integrity and to protect the environment? See Text Box 16C for additional information. Notes on Feed Storage XXV. On-Farm and Custom Feed Processing or Handling The National Organic Program Regulations make use of the term handling to denote processing and related activities. §205.2 specifically defines a handler as “[a]ny person engaged in the business of han- dling agricultural products, including producers who handle crops or livestock of their own produc- tion…” It defines a handling operation as “[a]ny operation or portion of an operation…that receives or otherwise acquires agricultural products and processes, packages, or stores such products.” Therefore, when the Regulations refer to handlers, they are referring to a varied group of individuals and businesses that include both specialized organic food processors and farmers who do value-added processing. It should be noted that retailers (such as grocers) that do not process or re-package the organic goods they sell need not be certified. Feed processing/handling scenarios can range from very simple to very complex, depending on the nature of the operation. In the simplest of cases, producers purchase commercial organic feeds from certified suppliers. In such instances there are very few concerns about contamination or commingling. n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 64. Revised February 2004 Page 64 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices In more complex circumstances, farmers may have their feeds processed by custom processors who, likely as not, also process conventional feeds. This greatly increases the dangers of contamination and commingling. Having your own processing equipment reduces the hazard enormously, but not neces- sarily if you run a split operation. There is less hazard of commingling when custom milling is done on your farm than when feedstuffs are hauled to a mill. On-farm custom processing typically involves only one or two units of processing machinery, and it is easy to ensure proper clean-out before an organic batch is run. In contrast, stationary commercial feed mills typically have a large number of bins, augers, transfer legs, and other equipment; only a certified organic mill would be certain to employ all the protocols necessary to ensure organic integrity. There are several ways to ensure organic integrity in feed handling. Many of these are covered in the workbook questions provided in this section. Commingling and contamination issues aside, a word should be said about ration formulation. Ration formulations for conventional livestock production will, in most instances, also be suitable for organic production—as long as only 100% organic feeds and allowed ingredients are used, of course. Contact Cooperative Extension for guidance in developing healthy stock rations128 . While conventional ration formulas are generally suitable, organic management and crop rotation de- sign may dictate some adjustments. Hybrid corn grown under organic management may have a some- what lower protein content than the same varieties produced with conventional fertilization; the amino acid balance, however, is often more favorable. Conversely, organic producers sometimes choose to grow open-pollinated corn varieties, some of which have significantly higher protein and mineral con- tents. Diverse crop rotations also result in a greater variety of unconventional feedstuffs that can be challenging to incorporate into rations. 25.1 Is your on-farm milling, mixing, and/or chopping equipment properly maintained to prevent contamination of organic feeds with prohibited materials? 25.2 If conventional feeds are also processed on your farm, are equipment clean- out protocols clearly established and logs maintained? 25.3 When custom processing is done on your farm using portable equipment provided by a service or neighboring farmer, is that processing service or farmer certified organic? 25.4 If you are using a noncertified portable custom processing unit, are thor- ough clean-out protocols established and a clean-out log maintained? Be certain the name and address of the custom service is recorded and avail- able to the inspector/certifier and that arrangements can be made for in- spection of the equipment and processing records. 25.5 When processing equipment is purged (sacrificing the first batch of or- ganic feed following conventional processing), do you keep adequate records on the quantity of feed used in purging and how it was subsequently used? The first batch of feed used to purge processing equipment may be dis- n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 65. Revised February 2004 Page 65 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices posed of in a number of ways. It may be sold on the conventional market, fed to conventional livestock in split or parallel production, fed to draft animals, or used as a soil amendment, etc. 25.6 If you use an off-farm custom feed handler, is he or she certified organic? The National Organic Program Regulations prohibit handling of organic feed at mill sites that have not been certified [§205.237(a)]. Notes on Feed Processing XXVI. On-Farm and Custom Livestock Processing or Handling It is not enough merely to raise animals organically. In order for livestock products to bear the organic label, all processing and handling of the products must be done by certified operators. This includes (but is not limited to) all slaughtering, packing, and milk processing. The typical handling operations this section is concerned with are butchering, cheese making, the clean- ing and packaging of eggs, etc. Because of their innate complexity, most of these handling/processing components will likely require the submission of an organic handling system plan129 in addition to the OSP that you prepare as a production plan. Be prepared to pay additional inspection and certification fees in this instance. One of the major concerns in organic processing, regardless of scale, is identifying and sourcing ap- proved ingredients. All allowed nonorganic ingredients (with the exception of water and salt, which are considered natural and allowed) are addressed in the National List. §205.605 of the National List deals with non-agricultural substances that are allowed in organic processing, both natural (nonsynthetics) and synthetics. §205.606 deals with nonorganically produced agricultural products that are allowed. As with organic production, OMRI has an valuable role to play in the evaluation of products for organic processing. OMRI Listed products can be purchased and used with a high degree of confidence. As a reminder, however, there are many acceptable products in the marketplace that have not been evaluated by OMRI and do not carry the OMRI Listed seal. When in doubt, contact your certifier to verify whether a particular product or material can be used. Another question surrounds processing technologies. At present, only ionizing radiation and genetic engineering are specifically prohibited [§205.105(e) and §205.105(f)]. n/a Yes No
- 66. Revised February 2004 Page 66 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Water quality is a particular concern in organic processing. Microbial contamination is the primary issue. Hydrogen peroxide, ozone, and chlorine are among the synthetic materials allowed in organic processing that are effective in controlling microbial contamination. The use of chlorine requires addi- tional clarification. §205.605(b)(9)—the portion of the National List that outlines non-agricultural synthetics allowed in or- ganic processing—says that chlorine materials are allowed for “disinfecting and sanitizing food contact surfaces,” and that “residual chlorine levels in the water shall not exceed the maximum residual disinfec- tant limit under the Safe Drinking Water Act.” (Currently the residual chlorine limit under the Safe Drinking Water Act is 4 parts per million, or ppm.) The language of this section has caused a great deal of misunderstanding and has led to a wide disparity of interpretation among certifiers. Some have as- sumed that this language means that chlorinated water greater than 4 ppm chlorine may not come in contact with organic food products and may be used only for sanitizing food preparation surfaces. Oth- ers have assumed that the language requires that food products be washed only with water that contains no more than 4 ppm chlorine—a level that is virtually ineffectual for sanitizing. Still other certifiers have believed that the Safe Drinking Water Act criterion allows highly chlorinated water to be used, but that the wastewater leaving the organic facility be less than 4 ppm chlorine. The most rational interpretation (that we have heard, at least) is that the notation in the regulation was improperly written; that the intent of the provision was that the rinse water that makes final contact with the organic product contain less than 4 ppm chlorine. In other words, a food product such as whole chickens may be bathed in water containing a high concentration of chlorine for sanitation purposes. However, that product must receive a thorough final rinse of water that contains less than 4 ppm chlo- rine. The producer should be aware that full clarification of the regulation regarding chlorine has not been made at the time of this writing. Therefore, be certain to consult with your certifier if you are using chlorine products for organic processing. Further issues in on-farm processing include avoiding contamination and commingling and the manage- ment of waste products, among others. Unfortunately, the scope of this workbook is limited with regard to processing and we are not covering those details in any depth. If you are planning a complex process- ing operation, you are encouraged to consult someone in the industry with first-hand experience as well as your certifier. 26.1 Are all the technologies you use for on-farm processing or in custom processing allowed in organic production [§205.270(a)]? Allowed technologies include but are not limited to: n/a Yes No • baking • boiling • canning • chilling • churning • cooking • curing • cutting • dehydrating • distilling • drying • eviscerating • extracting • fermenting • freezing • grinding • heating • jarring • mixing • packaging • preserving • separating • slaughtering • smoking • washing
- 67. Revised February 2004 Page 67 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 26.2 Are you avoiding the use of ionizing radiation or ingredients that have been treated with ionizing radiation [§205.105(f)]? 26.3 Has a flow chart of all on-farm processing steps and procedures been developed and is it available for review by the certifying body and its inspectors? 26.4 Are all purchased raw commodities and ingredients used in on-farm processing or in hired custom processing certified organic or otherwise allowed for use in organic processing [§205.105 and §205.270]? 26.5 Do you take care to determine that all ingredients are NOT genetically engineered and do not result from a process that uses genetically modified organisms [§205.105(e)]? 26.6 Do you keep labels, invoices, and descriptions of all ingredients, processing aids, and cleaning agents on file? 26.7 Do you use proper sanitation protocols in on-farm processing? 26.8 Do you use food-grade equipment and inputs in processing? 26.9 Where both organic and conventional products are handled and processed, do you have protocols for segregation of product and clean-up clearly established and are they adequate to prevent contamination and commingling [§205.272(a)]? 26.10 Where both organic and conventional products are handled and processed, are your logs of processing runs and clean-outs up-to-date? 26.11 Do you store prohibited substances away from processing equipment, processing inputs, raw products, and finished products? 26.12 Do you maintain processing equipment to prevent contamination of organic products with lubricants or other contaminants? 26.13 If you do on-farm meat processing, do you have a strategy for disposal of offal and other waste products that does not pose a health risk to livestock, contaminate organic products, or pollute the environment? n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 68. Revised February 2004 Page 68 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 26.14 Is wastewater from processing managed in a way that does not cause pol- lution or a health hazard? 26.15 Are packaging wastes managed so they do not contaminate organic prod- ucts and do not create a pollution problem? See Text Box 16C for more information on waste management. 26.16 Are coliform tests completed for all water used in food processing and wash- ing? Annual testing is advisable and may be required by the certifier. 26.17 If you are using chlorine for sanitation purposes in on-farm processing, do you have a clear understanding of your certifier’s expectations with regard to meeting the National Standard for residual chlorine levels [§205.605(b)(9)]? See the text in this section for clarification. 26.18 Have you performed any and all additional water analyses as requested by your certifier? 26.19 If water treatment technologies are needed or required, have they been in- stalled and are they fully functional? 26.20 Are you satisfied that your water sources are free of contamination by pro- hibited substances? 26.21 If you are producing both organic and nonorganic eggs, are protocols in place to prevent the commingling of products [§205.272(a)]? 26.22 If you are producing both organic and conventional meats, are protocols in place to ensure that commingling of meat products does not occur [§205.272(a)]? 26.23 If you are producing both organic and nonorganic milk and/or milk prod- ucts, are protocols in place to prevent commingling [§205.272(a)]? 26.24 If you are producing both organic and conventional animal fiber and/or fiber products, are protocols in place to prevent commingling [§205.272(a)]? 26.25 If commercial trucking is used to haul animal products from your opera- tion, is care taken to ensure that organic products are not contaminated or commingled with conventional products [§205.272(a)]? n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 69. Revised February 2004 Page 69 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 26.26 If you process meat and meat products on your farm, has your processing facility also been inspected and has it met organic requirements? 26.27 If you have livestock processed elsewhere for sale under your own label, is your meat processor certified organic or has the facility been covered under your organic inspection and certification? 26.28 If you process and package milk and milk products, has your processing facility also been inspected and has it met organic requirements? 26.29 If you have milk and/or milk products processed elsewhere for sale under your own label, is your processor certified organic or has the facility been covered under your organic inspection and certification? 26.30 If you package eggs, has your packaging facility also been inspected and has it met organic requirements? 26.31 If you have eggs packaged elsewhere for sale under your own label, is your packager certified organic or has the facility been covered under your organic inspection and certification? 26.32 If you process fiber, has your facility also been inspected and has it met organic requirements? 26.33 If you have fiber processed elsewhere for sale under your own label, is your processor certified organic or has the facility been covered under your organic inspection and certification? Notes on Processing / Handling n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 70. Revised February 2004 Page 70 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices XXVII. Packaging and Labeling Producers that package and label their products have several things to consider besides the challenge of designing eye-catching, customer-friendly logos. The packaging used for organic products must not contaminate the contents or otherwise compromise organic integrity. Packaging materials must not be impregnated with prohibited pesticides and should not be stored in a manner that invites pest infesta- tion. The Regulations have very strict requirements for labeling. There are four categories of labeling based on product composition: • “100% Organic” is any product that contains 100% organic ingredients (excluding salt and water, which are considered natural). Most raw, unprocessed products off-the-farm can be designated “100% Organic”. Likewise, many value-added farm products that have no added ingredients—such as frozen whole chickens, fresh ground beef, and packaged eggs—can also be labeled “100% Organic.” • “Organic” can be used to label any product that contains a minimum of 95% organic ingredi- ents (excluding salt and water). Up to 5% of the ingredients may be nonorganic agricultural products that are not commercially available as organic and/or non-agricultural products that are in §205.605 of the National List. • “Made With Organic ___________” can be used on the label of a product that contains at least 70% organically produced ingredients (excluding salt and water). There are a number of detailed constraints regarding the ingredients that comprise the nonorganic portion. Produc- ers should consult §205.304 of the Regulations for details. • The specific organic ingredients may be listed in the ingredient statement of products con- taining less than 70% organic contents—for example, “Ingredients: water, barley, beans, or- ganic tomatoes, salt.” See §205.305 of the Regulations for more details. The USDA’s official organic seal may only be used on products that can be labeled “100% Organic” or “Organic.” Products labeled “100% Organic” or “Organic” may also feature the logo of the certifying agent on the label. Small producers exempted from certification (that is, marketing less than $5000 of organic product) may not use the USDA seal, may not sell their products for use in certified products, and may not state in any manner that their product is certified. The labeling of organic products is rather detailed where processed prod- ucts are involved. This is especially true when a number of different ingredients—some of them nonorganic—are used. This workbook will not venture further into these complexities. For guidance on labeling, refer to Subpart D of the National Standard: §205.301 for labeling based on percent organic product composition; §205.302 regarding calculations for percentage of ingredients; §205.303-§205.305 for additional details on package labeling. §205.306 addresses the labeling of livestock feeds; §205.307 addresses the labeling of non-retail containers; §205.308-§205.309 deals with point of retail labeling; §205.311 addresses the specifics on use of the USDA seal. For most organic farmers who market raw and unprocessed products, labeling issues are not complex. In most instances where these producers are required to supply a label, the words “100% Organic” or “Or- ganic” will be appropriate. Even in such circumstances, it is important to read and understand the spe- cifics of labeling in the Organic Regulations and to confer with your certifier. Be certain, too, to describe in full detail and include a copy of your label in your OSP. USDA Organic Seal
- 71. Revised February 2004 Page 71 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 27.1 Are all packaging materials free of impregnated pesticides or other prohibited substances [§205.272(b)(1)]? 27.2 Are all packaging materials stored where they will remain free from contamination or infestation by pests? 27.3 If you are re-using any bags or containers, are you taking measures to ensure that there is no risk of commingling with nonorganic products or of contamination with prohibited substances [§205.272(b)(2)]? 27.4 Is all labeling in compliance with the National Organic Program Regulations [§205.300, §205.301, §205.302, §205.303, §205.304, §205.305, and §205.306]? Be sure to read the appropriate sections of the Regulations and confer with your certifier. 27.5 Where sales of both organic and conventional products occur, do adequate labeling and protocols exist to ensure segregation? 27.6 Are all product lots sold from your farm assigned lot numbers that permit traceability through your record keeping system [§205.236(c)]? Generally this would not be considered necessary for products such as freezer beef that are marketed directly to the end consumer. Further information on lot numbers is provided in Section XXIX. Notes on Packaging and Labeling XXVIII. Marketing Organic certification and regulation have arisen largely in response to a growing organic marketplace130 in which the producer and the end consumer never meet face-to-face. This marketplace is similar in many ways to the conventional marketplace, though the players are different and the infrastructure is not as well developed (as a rule). n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 72. Revised February 2004 Page 72 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Traditionally, organic agriculture has been associated with relationship-based direct marketing and lo- cal/regional food systems. Relationship-based marketing covers those strategies in which customers and farmers actually do meet and may even get to know each other. Direct marketing strategies are NOT required in the National Standard. However, there is good reason to consider direct marketing if you grow fresh vegetables and flowers, produce range eggs or freezer beef, 131 and are located near a city or other market opportunity. Local and regional marketing shortens the distance food products travel, improves quality for the consumer, and typically leaves more of the food dollar in the producer’s pocket. The following are several local and regional marketing options: • Community Supported Agriculture132 • direct sales to local stores, processors, and restaurants133 • farmers’ markets134 • roadside sales135 • agri-entertainment136 Notes on Marketing XXIX. Documentation, Record Keeping, and Audit Trail Whether you are an organic or a conventional farmer, the amount of recordkeeping required is increas- ing. In the conventional realm, much of the increase relates to regulation of fertilizer nutrients and pes- ticides. In organic systems, the recordkeeping is necessary to ensure organic integrity. §205.103 of the National Standard is specific with regard to requirements for record keeping on an or- ganic operation. The records must: 1) be well-adapted to the business being conducted, 2) disclose all activities and transactions in adequate detail, 3) be maintained for not less than five years beyond their creation, 4) be sufficient to demonstrate compliance with federal regulations, and 5) be available for inspection by the certifier and by authorized representatives of the State organic program and the Secretary of Agriculture.
- 73. Revised February 2004 Page 73 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices The actual amount of documentation the individual producer will need to generate and file to meet these requirements is not exact and depends on the complexity of the operation. The audit trail refers to the documentation necessary to determine the source, movement, and transfer of ownership of any organic product. A complete and thorough audit trail allows a processed product—a carton of yogurt, for example—to be traced back to the farm the milk originally came from. Sometimes the concept of audit trail is also extended to include production records and inputs, which also serve to demonstrate that the producer is farming organically. Lot numbers are an important aspect of a good audit trail. Lot numbers are codes assigned by producers to link products to their origin and the year or date on which they were produced. Lot numbers may not be necessary if you direct market, but are essential if you sell into wholesale markets or to processors. A good lot numbering system is logical and can readily be decoded. For example, Lot No. OE061434 might code for Organic Eggs, from production building #06, which was collected on the Julian Calendar date 143 (May 23), in the year 2004. Lot No. OC0604 might code for Organic Corn, from bin #06, which was harvested in 2004.137 Identification of individual animals or groups of animals is important in organic management and is often linked to or incorporated into the lot number system. Livestock identification becomes especially important in split operations and in circumstances where select animals within the herd are nonorganic either because they are breeding stock or because of treatment with prohibited medications. The following are among the common forms of documentation that organic livestock producers must keep to ensure a complete audit trail and record system138 : • accurate maps with fields, paddocks, pen numbers, feed storage areas, and/or production units clearly marked with a consistent numbering or lettering system • accurate history sheets for fields, paddocks, pen numbers, and/or production units. History includes record of production practices, materials applied, dates of field operations, etc. • copies of correspondence and notices to neighbors, county road maintenance authorities, utili- ties, and others that demonstrate efforts to ensure the protection of organic fields from spray- ing and other forms of contamination • soil and water test reports • verification of the organic status of seeds, sprigs, and other purchases that require such docu- mentation • seed tags and/or seed packaging • documentation of efforts to procure organic inputs where needed • forage crop pest and disease monitoring reports • labels from purchased fertilizers, pest control products, and other inputs • production logs and activity records • crop harvest records • verification of organic status for purchased animals • herd/flock health records • labels from vaccines and any other medications • labels from cleansers and sanitizers • breeding records • labels from purchased feeds, supplements, and additives • receipts from purchased feeds • receipts for purchased inputs and/or services • clean truck affidavits
- 74. Revised February 2004 Page 74 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices • outgoing bills of lading • weight records • storage records • equipment and storage unit cleanout logs • slaughter and processing records • sales receipts and/or invoices • sales records • complaint log139 29.1 Is there an adequate animal identification system in place [§205.236(c)]? 29.2 Does your lot numbering and audit control system permit accurate track- ing of animals and animal products through processing and marketing [§205.236(c)]? 29.3 Are records of sales maintained to ensure a complete audit trail? 29.4 Are you maintaining a complete set of operation records covering the pro- duction and handling of all agricultural products that you intend to be sold, labeled, or represented as organic [§205.103(a)]? 29.5 Is your record keeping system appropriate and well adapted to the needs of your organic operation [§205.103(b)(1)]? 29.6 Does your record keeping system fully disclose all activities and transac- tions in sufficient detail so as to be readily understood and audited [§205.103(b)(2)]? 29.7 Have you retained or are you preparing to retain all records applicable to your organic operation for at least 5 years [§205.400(d) and §205.103(b)(3)]? 29.8 Is the record keeping system sufficient to demonstrate compliance with organic regulations and the Organic Foods Production Act [§205.103(b)(4)]? 29.9 Are your records available for inspection and copying during normal busi- ness hours by authorized representatives of the Secretary of Agriculture, the State organic program, and/or the certifying agent [§205.103(c)]? 29.10 If you have a split operation, are there adequate records to demonstrate that no commingling occurs? n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No n/a Yes No
- 75. Revised February 2004 Page 75 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Notes on Recordkeeping Finding Referenced Information Sources A number of resources are mentioned in the footnote text of this document. Contact information to obtain these materials is provided below. Acres U.S.A.: Acres U.S.A. is a private business that publishes a monthly sustainable farming magazine under the same name. Acres U.S.A. also publishes and distributes a wide number of books on alternative agriculture and related subjects. To obtain a free book catalog and other information contact: Acres U.S.A. P.O. Box 91299 Austin, TX 78709-1299 Tel: 512-892-4400 Fax: 512-892-4448 E-mail: [email protected] Website: http://www.acresusa.com/magazines/magazine.htm Alternative Farming Systems Information Center: AFSIC is one of several information centers at the National Agricultural Library (NAL) that provide in-depth coverage of specific subject areas relating to the food and agricultural sciences. AFSIC focuses on alternative farming systems that aim at maintaining agricultural productivity and profitability, while protecting natural resources. Such systems include sustainable, low-input, regenerative, Biodynamic, or organic farming and gardening. Alternative Farming Systems Information Center National Agricultural Library, Room 304 10301 Baltimore Avenue Beltsville, MD 20705-2351 Tel: 301-504-6559 Fax: 301-504-6409 E-mail: [email protected] Website: http://www.nal.usda.gov/afsic/
- 76. Revised February 2004 Page 76 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices ATTRA: ATTRA (Appropriate Technology Transfer for Rural Areas) is a USDA-funded project that is managed by the National Center for Appropriate Technology—a non-profit organization. ATTRA pub- lishes and distributes information on organic and sustainable agriculture. Many of its publications can be directly downloaded from its website. Hard copies and other information and services can be ob- tained by calling the 800-line phone service. ATTRA P.O. Box 3657 Fayetteville, AR 72702-3657 Tel: 800-346-9140 Tel: 479-442-9824 Fax: 479-442-9842 Website: http://www.attra.ncat.org/ Cooperative Extension Service: Every state has one or more land grant universities that provide exten- sion outreach for farmers. Local access to each state’s services is usually available at the county level in the person of the “County Agent.” Cooperative Extension typically has good information on basic pas- ture and livestock production practices. While resources pertinent to organic production have been lim- ited, the situation in most states is improving. A listing of addresses for state cooperative extension publications offices is appended to this workbook. Countryside & Small Stock Journal: The Countryside & Small Stock Journal was established in 1917 and targets homesteaders and others in the Voluntary Simplicity movement that seek greater self-reliance. The Journal is of particular value for its frequent articles on small livestock care and production. Organic methods are emphasized. Countryside & Small Stock Journal W11564 Hwy 64 Withee, WI 54498 Tel: 715-785-7979 Fax: 715-785-7414 E-mail: [email protected] Website: http://www.countrysidemag.com/ The Kerr Center for Sustainable Agriculture: The Kerr Center for Sustainable Agriculture is a non-profit foundation in southeastern Oklahoma that focuses on sustainable farming and ranching. It is very active on public policy issues, but also publishes a fair bit of nuts-and-bolts information. The Kerr Center for Sustainable Agriculture PO Box 588 Poteau, OK 74953 Tel: 918-647-9123 Fax: 918-647-8712 E-mail: [email protected] Website: http://www.kerrcenter.com
- 77. Revised February 2004 Page 77 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices National Organic Program: The National Organic Program (NOP) was created to implement the Or- ganic Foods Production Act of 1990, which is the over-arching legislation behind the federal standards. The NOP’s website is the place to go for viewing the Regulations, and to monitor the progress and recom- mendations of the National Organic Standards Board. Richard Matthews, Program Manager National Organic Program USDA-AMS-TM-NOP Room 4008—South Building 1400 and Independence Avenue, SW Washington, DC 20250-0020 Tel: 202-720-3252 Fax: 202-205-7808 E-mail: [email protected] Website: http://www.ams.usda.gov/nop/indexIE.htm Organic Materials Review Institute: The Organic Materials Review Institute (OMRI) is a nonprofit organization whose primary mission is to publish and disseminate generic and specific (brand name) lists of materials allowed and prohibited for use in the production, processing, and handling of organic food and fiber. OMRI also conducts scientific research and education on the use of materials by the organic industry. Subscriptions to OMRI include the current generic and brand name supplier lists, with periodic updates and a quarterly newsletter. OMRI Box 11558 Eugene, OR 97440 Tel: 541-343-7600 Fax: 541-343-8971 E-mail: [email protected] Website: http://www.omri.org/ SAN: SAN (Sustainable Agriculture Network) is the outreach arm of the SARE (Sustainable Agriculture Research and Education) program, which has been the USDA’s primary means of studying and spread- ing the word about sustainable farming systems. SAN publishes and distributes a number of for-sale books and free publications. Sustainable Agriculture Publications 210 Hills Building University of Vermont Burlington, VT 05405-0082 Tel: 802-656-0484 E-mail: [email protected] Website: http://www.sare.org/ Small Farm Today: Small Farm Today magazine is published bi-monthly and is dedicated to the preserva- tion and promotion of small farming, rural living, community, sustainability, and agripreneurship. It has many features on livestock production, with particular attention to rare breeds and alternative stock. Health care and management techniques discussed are typically organic in nature. Small Farm Today 3903 W Ridge Trail Rd Clark MO 65243-9525 Tel: 573-687-3525 Fax: 573-687-3148 E-mail: [email protected] Website: http://www.smallfarmtoday.com/
- 78. Revised February 2004 Page 78 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Soil Foodweb, Inc.: Soil Foodweb, Inc. publishes books and articles, gives lectures, and does laboratory testing of soils and composts. Publication topics include soil microbiology, soil ecology, farming, or- chards, golf/turf, nursery/landscape, forestry, and lawn and garden. Soil Foodweb, Inc. 1128 NE 2nd St., Suite 120 Corvallis, OR 97330 Tel: 541-752-5066 Fax: 541-752-5142 E-mail: [email protected]> Website: http://www.soilfoodweb.com/sfi_html/index.html The Soil and Health Library: This is an electronically accessible free public library offering a tightly focused collection of books on holistic agriculture, holistic health, self-sufficient living, and personal development. Most of the titles in this library are out of print. Some can be quite hard to find; many of these books are old enough to be public domain materials. It is an excellent place to find classic organic farming texts by pioneers such as Albert Howard, Eve Balfour, F.H. King, J.I. Rodale, and Newman Turner. Website: http://www.soilandhealth.org/ The Stockman Grass Farmer is a publication devoted entirely to the art and science of turning grass into cash flow. The Stockman Grass Farmer serves as an information network for grassland farmers sharing the latest in intensive grazing technology and pasture management. The Stockman Grass Farmer 282 Commerce Park Drive Ridgeland, MS 39157 Tel: 601-853-1861 Fax: 601-853-8087 E-mail: [email protected] Website: http://www.stockmangrassfarmer.com Photo by USDA NRCS
- 79. Revised February 2004 Page 79 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Cooperative Extension Publications Offices and Websites: Alabama Cooperative Extension Publications Auburn University 122 Duncan Hall Annex Auburn University, AL 36849 Tel: 334-844-5690 http://www.aces.edu/dept/extcomm/ publications/ University of Alaska Cooperative Extension Service Attn: Distribution University of Alaska Fairbanks PO Box 756180 Fairbanks, AK 99775-6180 Tel: 907-474-7268 Fax: 907-474-2631 E-mail: [email protected] http://www.uaf.edu/coop-ext/publications/ University of Arizona CALSmart 4042 N. Campbell Avenue Tucson, AZ 85719-1111 Tel: 520-318-7275 Fax: 520-795-8508 E-mail: [email protected] http://ag.arizona.edu/pubs/ Arkansas Cooperative Extension Publications University of Arkansas Division of Agriculture Cooperative Extension Service 2301 South University Avenue Little Rock, Arkansas 72204 Tel: 501-671-2000 Fax : 501-671-2209 http://www.aragriculture.org/publications/ default.asp University of Arkansas Agricultural Engineering Publications http://www.aragriculture.org/ agengineering/default.asp (Same address as above.) University of California, Agriculture and Natural Resources ANR Communication Services 6701 San Pablo Avenue Oakland, CA 94608-1239 Tel: 510-642-2431 or 800-994-8849 E-mail: [email protected] http://anrcatalog.ucdavis.edu or 1441 Research Park Drive Davis, CA 95616 Tel: 530-757-8930 Colorado State University Cooperative Extension 1 Administration Building Colorado State University Fort Collins, CO 80523-4040 Tel: 970-491-6281 Fax: 970-491-6208 http://www.cerc.colostate.edu/ University of Connecticut Cooperative Extension Communications and Information Technology 1376 Storr Road, Unit 435 University of Connecticut Storrs, CT 06269-4035 Tel: 860-486-3336 Fax: 860-486-0100 or 860-486-3334 E-mail: [email protected] http://www.canr.uconn.edu/ces/ (CES homepage) or http://137.99.85.230/FMPro?- db=products.fp3&-token=63&- format=browse.htm&-lay=cgi&- sortfield=Category&category=New%20Publications&- find#
- 80. Revised February 2004 Page 80 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices University of Florida Extension Institute of Food and Agricultural Sciences Gainesville, FL 32611 E-mail: [email protected] http://edis.ifas.ufl.edu/ University of Georgia College of Agricultural and Environmental Sciences Cooperative Extension Service Athens, GA 30602 http://www.ces.uga.edu/ces/pubs.html Publications and Information Office College of Tropical Agriculture and Human Resources 3050 Maile Way, Gilmore Hall 119 University of Hawaii at Manoa Honolulu, HI 96822 Tel: 808-956-7046 E-mail: [email protected] http://www2.ctahr.hawaii.edu/oc/ University of Idaho Extension Agricultural Publications University of Idaho Moscow, ID 83844-2240 Tel: 208-885-7982 Fax: 208-885-4648 E-mail: [email protected] http://info.ag.uidaho.edu/Catalog/ catalog.htm University of Illinois Office of Extension and Outreach 214 Mumford Hall (MC-710) 1301 W. Gregory Dr. Urbana, IL 61801 Tel: 217-333-5900 E-mail: [email protected] http://www.extension.uiuc.edu/pubs.html University of Delaware College of Agriculture and Natural Resources Cooperative Extension Newark, DE 19716 Tel: 302-831-2791 http://ag.udel.edu/extension/ Information/ publications_from_the_university.htm Purdue Cooperative Extension (Indiana) Tel: 888-398-4636) E-mail: [email protected] http://www.agcom.purdue.edu/AgCom/Pubs/ menu.htm Iowa State University Extension Extension Distribution Center 119 Printing and Publications Building Iowa State University Ames, Iowa 50011-3171 Tel: 515-294-5247 Fax: 515-294-2945 E-mail: [email protected] http://www.exnet.iastate.edu/pubs/ Kansas State University Extension Production Services Kansas State University 24 Umberger Hall Manhattan, KS 66506-3402 Tel: 785-532-5830 Fax: 785-532-7938 E-mail: [email protected] http://www.oznet.ksu.edu/library/ University of Kentucky College of Agriculture Cooperative Extension Service Ag Communications Services 131 Scovell Hall Lexington, KY 40546-0064 Tel: 859-257-4736 Fax: 859-323-1051 http://www.ca.uky.edu/coahome/pubs.htm Louisiana State University Cooperative Extension Service LSU Agricultural Center P.O. Box 25203 101 Efferson Hall Baton Rouge, LA 70894-5203 Tel: 225-578-2263 E-mail: [email protected] http://www.agctr.lsu.edu/nav/pubcatalog.htm
- 81. Revised February 2004 Page 81 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices University of Maine Cooperative Extension UMCE Communications Office 5741 Libby Hall, Room 110 Orono, ME 04469-5741 Tel: 207-581-3269 Fax: 207-581-1387 E-mail: [email protected] http://www.umext.maine.edu/publications/ catalog.htm University of Maryland Cooperative Extension College of Agriculture and Natural Resources http://www.agnr.umd.edu/MCE/Publica- tions/index.cfm University of Massachusetts Extension UMass Extension Bookstore Draper Hall 40 Campus Center Way Amherst, MA 01003-9244 Fax: 413-545-5174 E-mail: [email protected] http://www.umass.edu/umext/bookstore/ Michigan State University Extension 108 Agriculture Hall East Lansing, MI 48824-1039 Tel: 517-355-2308 Fax: 517-355-6473 E-mail: [email protected] http://ceenet.msue.msu.edu/bulletin/ ctlgmast.html University of Minnesota Extension Service Extension Distribution Center 405 Coffey Hall 420 Eckles Avenue University of Minnesota St. Paul, MN 55108-6068 Tel: 612-624-4900 or 800-876-8636 Fax: 612-625-6281 E-mail: [email protected] http://www.extension.umn.edu/units/dc/ Mississippi State University Extension Service http://msucares.com/pubs/index.html University of Missouri Outreach and Extension E-mail: [email protected] http://extension.missouri.edu/main/ publications.shtml Montana State University Extension Service Extension Publications P.O. Box 172040 Montana State University Bozeman, MT 59717-2040 Tel: 406-994-3273 E-mail: [email protected] http://www.montana.edu/wwwpb/pubs/ University of Nebraska Cooperative Extension Extension Publications IANR Communications & Information Technology Box 830918 Lincoln, NE 68583-0918 Fax: 402-472-0542 E-mail: [email protected] http://www.ianr.unl.edu/pubs/browse.htm University of Nevada Cooperative Extension Tel: 775-784-7070 E-mail: [email protected] http://www.unce.unr.edu/pubs.html University of New Hampshire Cooperative Extension UNH Cooperative Extension Publication Center Nesmith Hall, 131 Main Street Durham, NH 03824-3597 Tel: 603-862-2346 Fax: 603-862-2441 E-Mail: [email protected] http://ceinfo.unh.edu/pubs.htm Rutgers Cooperative Extension—New Jersey Administrative office: Rutgers Cooperative Extension Cook College Rutgers 88 Lipman Dr. New Brunswick, NJ 08901-8525 Tel: 732-932-9306 http://www.rce.rutgers.edu/pubs/index.html
- 82. Revised February 2004 Page 82 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices New Mexico State University Cooperative Extension Agricultural Communications—Bulletin Office Box 30003, MSC 3AI New Mexico State University Las Cruces, NM 88003-8003 Tel: 505-646-2701 E-mail: [email protected] http://www.cahe.nmsu.edu/pubs/ Cornell Cooperative Extension—New York Cornell University Resource Center 7 Business & Technology Park Ithaca, NY 14850 Tel: 607-255-2080 Fax: 607-255-9946 E-mail: [email protected] http://www.cce.cornell.edu/publications/ catalog.html North Carolina State University Cooperative Extension http://www.ces.ncsu.edu/resources/ North Dakota State University Extension Service Distribution Center, NDSU Extension Service Morrill Hall, P.O. Box 5655 North Dakota State University Fargo, ND 58105-5655 Tel: 701-231-7882 Fax: 701-231-7044 E-mail: [email protected] http://www.ext.nodak.edu/extpubs/ Ohio State University Extension Media Distribution 385 Kottman Hall 2021 Coffey Rd. Columbus, Ohio 43210-1044 Tel: 614-292-1607 Fax: 614-292-1248 E-mail: [email protected] http://ohioline.osu.edu/lines/farm.html Oklahoma State University Cooperative Extension Service University Mailing Services Oklahoma State University Stillwater, OK 74078 Tel: 405-744-5385 http://agweb.okstate.edu/pearl/ Oregon State University Extension Publication Orders Extension & Station Communications Oregon State University 422 Kerr Administration Corvallis, OR 97331-2119 Fax: 541-737-0817) E-mail: [email protected] http://wwwagcomm.ads.orst.edu/ agcomwebfile/EdMat/default.html Penn State Cooperative Extension Publications Distribution Center The Pennsylvania State University 112 Agricultural Administration Building University Park, PA 16802-2602 Tel: 814-865-6713 Fax: 814-863-5560 E-mail: [email protected] http://pubs.cas.psu.edu/Subject.html University of Rhode Island Cooperative Extension Cooperative Extension Education Center College of the Environment and Life Sciences 3 East Alumni Avenue University of Rhode Island, Kingston, RI 02881 Tel: 401-874-2900 Fax: 401-874-2259 http://www.uri.edu/ce/factsheets/
- 83. Revised February 2004 Page 83 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices Clemson University Cooperative Extension Service—South Carolina Public Information Specialist A-101 Poole Ag. Center Clemson University Clemson, S.C. 29634 Tel: 864-656-3876 Fax: 864-656-0742 E-Mail: [email protected] http://www.clemson.edu/ psapublishing/DIGITAL.HTM South Dakota State University Cooperative Extension Service http://sdces.sdstate.edu/ Tennessee State University Cooperative Extension http://www.tnstate.edu/cep/ University of Tennessee Agriculture Extension Service Marketing & Communications Services Institute of Agriculture University of Tennessee 104 Morgan Hall Knoxville, TN 37901-1071 Tel: 865-974-7141 Fax: 865-974-9433 http://www.utextension.utk.edu/ publications/default.asp Texas A&M University Cooperative Extension Distribution and Supply P.O. Box 1209 Bryan, Texas 77806 Tel: 888-900-2577 Fax: 979-862-1566 E-mail: [email protected] http://texaserc.tamu.edu/catalog/ index.html Utah State University Cooperative Extension Utah State University Extension Bulletin Room #202 8960 Old Main Hill Logan, UT 84322-8960 Tel: 435-797-2251 http://extension.usu.edu/publica/ index.htm University of Vermont Extension CTR: Publications Agricultural Engineering Building University of Vermont Burlington, VT 05405-0004 http://ctr.uvm.edu/ctr/elecpubs.htm Virginia Cooperative Extension http://www.ext.vt.edu/resources/ Washington State University Cooperative Extension Bulletin Office Washington State University Box 645912 Pullman, WA 99164-5912 Tel: 509-335-2857 http://pubs.wsu.edu/ West Virginia University Extension Service Offices of Communications and Technology. West Virginia University Extension Service 507 Knapp Hall Morgantown, WV 26506-6031 Tel: 304-293-4221 Fax: 304-293-6611 http://www.wvu.edu/~exten/infores/ pubs.htm University of Wisconsin Extension Cooperative Extension Publications 45 North Charter Street Madison, WI 53715 Tel: 608-262-3346 Fax: 608-265-8052 E-mail: [email protected] http://www1.uwex.edu/ces/pubs/ University of Wyoming Cooperative Extension Service University of Wyoming Cooperative Extension Service P.O. Box 3354 Laramie, WY 82071-3354 http://www.uwyo.edu/ces/pubs3.htm
- 84. Revised February 2004 Page 84 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices University of the Virgin Islands Cooperative Extension Clarice Clarke, St. Croix Extension Specialist, Communications Tel: 340-692-4060 E-mail: [email protected] http://rps.uvi.edu/CES/ comhome.htm Endnotes 1 NCAT’s Organic Crops Workbook is available in PDF format at <http://attra.ncat.org/attra-pub/PDF/ cropsworkbook.pdf>. 2 For information on the Independent Organic Inspectors Association, contact IOIA, P.O. Box 6, Broadus, MT 59317, Tel: 406-436-2031, Website: <http://www.ioia.net/>. 3 This workbook can be downloaded in PDF format at <http://attra.ncat.org/attra-pub/PDF/ livestockworkbook.pdf>. 4 “A sustainable agriculture provides nourishing food, protects those who work the land, helps stabilize the earth’s climate, and safeguards soil and water.” Asilomar Declaration, California, 1990. “A sustainable agriculture is one that, over the long term, enhances the environmental quality and the resource base on which agriculture depends; provides for basic human food and fiber needs; is economically viable; and enhances the quality of life for farmers and society as a whole.” American Society of Agronomy 5 You may also wish to use the National Organic Program Compliance Checklist for Producers, available from ATTRA at <http://attra.ncat.org/attra-pub/PDF/compliance.pdf>. 6 Humus refers to the relatively stable state that organic plant and animal materials achieve following decomposition in the soil or compost pile. 7 For more information on the history of organic farming, see ATTRA’s Overview of Organic Crop Produc- tion at <http://attra.ncat.org/attra-pub/organiccrop.html>. To access some of the classic texts on hu- mus farming visit the Soil and Health Library website at <http://www.soilandhealth.org/>. 8 OFPA text can be found on the National Organic Program website at <http://www.ams.usda.gov/ nop/archive/OFPA.html>. 9 For more information on federal regulation of organic farming, visit the website of the National Organic Program at <http://www.ams.usda.gov/nop/>. Additional useful information can be accessed on the Organic Trade Association website specifically at <http://www.ota.com/organic/us_standards.html>. Also see ATTRA’s Organic Farm Certification & The National Organic Program at <http://attra.ncat.org/ attra-pub/PDF/organcert.pdf>. 10 A list of accredited certifiers can be found on the National Organic Program website at <http:// www.ams.usda.gov/nop/CertifyingAgents/CertAgenthome.html>. 11 A sample of a Purchased or Rented Land Verification Form is provided as a template on the Minnesota Department of Agriculture website at <http://www.mda.state.mn.us/esap/organic/sampleforms.pdf>. 12 A discussion of this subject can be found on the OTA website at <http://www.ota.com/ NewYorkTimesJuly16.html>. 13 The easiest way to access the National Organic Standard is to visit the NOP’s website at <http:// www.ams.usda.gov/nop>. 14 For more information, see ATTRA’s Overview of Organic Crop Production at <http://attra.ncat.org/ attra-pub/organiccrop.html>. University of Guam Cooperative Extension Victor T. Artero, Associate Dean/Director CES CALS Building, Room 206 UOG Station, Mangilao GU 96923 E-mail: [email protected] http://www.uog.edu/cals/site/publications.html
- 85. Revised February 2004 Page 85 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 15 For more information, see ATTRA’s Sustainable Pasture Management at <http://attra.ncat.org/attra- pub/PDF/sustpast.pdf>, Rotational Grazing at <http://attra.ncat.org/attra-pub/PDF/rotgraze.pdf>, Matching Livestock and Forage Resources in Controlled Grazing at <http://attra.ncat.org/attra-pub/PDF/ matchl&f.pdf>, and Introduction to Paddock Design and Fencing—Water Systems for Controlled Grazing at <http://attra.ncat.org/attra-pub/paddock.html>. Also see the Kerr Center for Sustainable Agriculture’s Management Intensive Grazing at <http://www.kerrcenter.com/kerrweb/publications/MIG/ mangmnt_intense_graze.htm>, and Cell Grazing: Getting Started on Your Place at <http:// www.kerrcenter.com/kerrweb/publications/2002_proceedings/cell_grazing.pdf>. 16 See ATTRA’s Sustainable Poultry: Production Overview at <http://attra.ncat.org/attra-pub/PDF/ poultryoverview.pdf>, Sustainable Chicken Production at <http://attra.ncat.org/attra-pub/PDF/ chicken.pdf>, Pastured Poultry at <http://attra.ncat.org/attra-pub/pasturedpoultry.html>, Feeding Chick- ens at <http://attra.ncat.org/attra-pub/feeding.html>, and Range Poultry Housing at <http:// attra.ncat.org/attra-pub/PDF/poulthous.pdf>. 17 ATTRA’s publication Organic Livestock Feed Suppliers at <http://attra.ncat.org/attra-pub/ livestockfeed.html> may prove useful in finding feed sources. ATTRA’s Sources for Organic Fertilizers & Amendments at <http://attra.ncat.org/attra-pub/orgfert.html> also provides the names of many suppli- ers of kelp and mineral products that are often available in feed-grade formulations. 18 ATTRA has generic OSP forms available in the publication Creating an Organic Production and Handling System Plan: A Guide to Organic Plan Templates at <http://attra.ncat.org/attra-pub/handlingsys.html>. Unfortunately, at the time of this writing, these templates have not been designed to accommodate all the needs of livestock operations. 19 A sample map is provided on the Minnesota Department of Agriculture website at <http:// www.mda.state.mn.us/esap/organic/sampleforms.pdf>. 20 See ATTRA’s Sources of “Spraying Prohibited” Signs for Organic Farms at <http://attra.ncat.org/attra- pub/sprayingpro.html>. 21 A sample of a neighbor notification letter is provided in template form on the Minnesota Department of Agriculture website at: <http://www.mda.state.mn.us/esap/organic/sampleforms.pdf>. 22 A sample of an adjoining land use verification form is provided as a template on the Minnesota Depart- ment of Agriculture website at: <http://www.mda.state.mn.us/esap/organic/sampleforms.pdf>. 23 Guidelines are provided in the Minnesota Department of Agriculture Factsheet Pesticide Drift and Mis- use at <http://www.mda.state.mn.us/appd/pesticides/drift.pdf>. 24 For an interesting article on farm biodiversity, see “Farming with the Wild: Agriculture and the Biodiversity Crisis” in Biodiversity, Vol. 11, No. 1. (Winter 2001) at <http://www.cgbd.org/visitor/pub- lications/biodiversity_winter01.pdf>. 25 ATTRA has information on herbal pastures and non-traditional forages available on request; it also has a publication titled Intercropping Principles and Production Practices at <http://www.attra.ncat.org/attra- pub/PDF/intercrop.pdf>. Planting and maintaining diverse forage species in a single field is an ex- ample of intercropping. A somewhat dated but recommended classic book on the subject, Fertility Pas- tures and Cover Crops by Newman Turner, is still available. For information on ordering, contact the Soil and Health Library website, provided in the resource section. 26 There is additional information on crop rotation in NCAT’s Organic Crops Workbook at <http:// attra.ncat.org/attra-pub/PDF/cropsworkbook.pdf>. Also recommended is SAN’s Managing Cover Crops Profitably, 2nd edition at <http://www.sare.org/handbook/mccp2/index.htm>, and Saskatchewan’s Prin- ciples and Practices of Crop Rotation, at <http://www.agr.gov.sk.ca/docs/crops/ integrated_pest_management/soil_fertility_fertilizers/cpc0397.asp>. 27 See ATTRA’s Overview of Cover Crops and Green Manures at <http://attra.ncat.org/attra-pub/PDF/ covercrop.pdf>, SAN’s Managing Cover Crops Profitably, 2nd edition at <http://www.sare.org/handbook/ mccp2/index.htm>, and Ohio State’s Cover Crop Fundamentals at <http://ohioline.osu.edu/agf-fact/ 0142.html>.
- 86. Revised February 2004 Page 86 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 28 See ATTRA’s Pursuing Conservation Tillage Systems for Organic Crop Production at <http://attra.ncat.org/ attra-pub/PDF/omconservtill.pdf>. 29 See ATTRA’s Agroforestry Overview at <http://attra.ncat.org/attra-pub/PDF/agrofor.pdf>, The Kerr Center for Sustainable Agriculture’s Agroforestry Practices at <http://www.kerrcenter.com/kerrweb/ publications/Agroforestry.htm>, and the NRCS publications Agroforestry for Farms and Ranches at <http:/ /www.unl.edu/nac/farms-ranches.pdf> and Working Trees for Livestock at <http://www.unl.edu/nac/ brochures/wtl/wtl.pdf>. 30 See ATTRA’s Multi-Species Grazing at <http://attra.ncat.org/attra-pub/PDF/multispecies.pdf>. 31 See ATTRA’s Farmscaping to Enhance Biological Control at <http://attra.ncat.org/attra-pub/PDF/ farmscaping.pdf>. 32 For a description of cation balancing and a discussion of the issues as they relate primarily to soils and crop production see the Virginia Association for Biological Farming’s Soil Cation Nutrient Balancing in Sustainable Agriculture at <http://www.vabf.org/soilre1.php> and Does My Soil Need Cation Nutrient Balancing? at <http://www.vabf.org/soilre2.php>. Perhaps the two best books relating cation balanc- ing to animal health are The Albrecht Papers Vol. II: Soil Fertility and Animal Health, available from Acres USA, and The Dairy Nutrition Manual, available from Midwestern Bio-Ag, Hwy ID, Box 126, Blue Mounds, WI 53517, 608-437-4994. For good information on implementing soil cation balancing that is sensitive to organic management, try Gary Zimmer’s The Biological Farmer—available from Acres USA. Also see ATTRA’s Sustainable Soil Management at <http://www.attra.org/attra-pub/PDF/soilmgmt.pdf>. See ATTRA’s Alternative Soil Testing Laboratories at <http://attra.ncat.org/attra-pub/soil-lab.html> for labo- ratories that provide tests and recommendations that include base saturation. 33 A number of commercial soil testing laboratories provide organic fertilizer recommendations. See ATTRA’s Alternative Soil Testing Laboratories at <http://attra.ncat.org/attra-pub/soil-lab.html>. The University of Georgia’s publication How to Convert an Inorganic Fertilizer Recommendation to an Organic One at <http://www.ces.uga.edu/pubs/PDF/C853.pdf> may also be helpful. 34 See ATTRA’s Manures for Organic Crop Production at <http://attra.ncat.org/attra-pub/PDF/ manures.pdf>. 35 See ATTRA’s Alternative Soil Amendments at <http://attra.ncat.org/attra-pub/PDF/altsoil.pdf>. 36 For more details see NCAT’s Organic Crops Workbook at <http://attra.ncat.org/attra-pub/PDF/ cropsworkbook.pdf>. 37 See ATTRA’s Overview of Cover Crops and Green Manures at <http://attra.ncat.org/attra-pub/PDF/ covercrop.pdf> and NCAT’s Organic Crops Workbook at <http://attra.ncat.org/attra-pub/PDF/ cropsworkbook.pdf>. 38 ATTRA is developing further information on a number of esoteric practices. Currently available is ATTRA’s Biodynamic Farming & Compost Preparation at <http://attra.ncat.org/attra-pub/PDF/ biodynam.pdf>. For information on radionics see Radionics in Agriculture at <http://home.earthlink.net/ ~gkuepper/index/Radionics.htm>. For in-depth reading on a wide range of esoteric agricultural prac- tices, see the books Secrets of the Soil and Stone Age Farming, available from Acres, USA. 39 See NCAT’s Organic Crops Workbook at <http://attra.ncat.org/attra-pub/PDF/cropsworkbook.pdf>. Also see ATTRA’s Overview of Cover Crops and Green Manures at <http://attra.ncat.org/attra-pub/PDF/ covercrop.pdf>, SAN’s Managing Cover Crops Profitably, 2nd edition at <http://www.sare.org/handbook/ mccp2/index.htm> and Ohio State’s Cover Crop Fundamentals at <http://ohioline.osu.edu/agf-fact/ 0142.html>. 40 See ATTRA’s Alternative Soil Amendments at <http://attra.ncat.org/attra-pub/PDF/altsoil.pdf> and Sources for Organic Fertilizers & Amendments at <http://attra.ncat.org/attra-pub/orgfert.html>. 41 See ATTRA’s Alternative Soil Amendments at <http://attra.ncat.org/attra-pub/PDF/altsoil.pdf> and Sources for Organic Fertilizers & Amendments at <http://attra.ncat.org/attra-pub/orgfert.html>. 42 See ATTRA’s Foliar Fertilization at <http://attra.ncat.org/attra-pub/PDF/foliar.pdf>. 43 See The Kerr Center for Sustainable Agriculture’s Pasture Legumes: Establishment and Management at <http://www.kerrcenter.com/kerrweb/publications/legumes.html>.
- 87. Revised February 2004 Page 87 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 44 See NCAT’s Organic Crops Workbook at <http://attra.ncat.org/attra-pub/PDF/cropsworkbook.pdf>. 45 See ATTRA’s Manures for Organic Crop Production at <http://attra.ncat.org/attra-pub/PDF/ manures.pdf>. 46 See ATTRA’s Alternative Soil Amendments at <http://attra.ncat.org/attra-pub/PDF/altsoil.pdf> and Sources for Organic Fertilizers & Amendments at <http://attra.ncat.org/attra-pub/orgfert.html>. 47 For guidance on determining optimum forage residual heights, see ATTRA’s Sustainable Pasture Man- agement at <http://attra.ncat.org/attra-pub/PDF/sustpast.pdf>, Assessing the Pasture Soil Resource at <http://attra.ncat.org/attra-pub/pastsoil.html>, and Rotational Grazing at <http://attra.ncat.org/attra- pub/PDF/rotgraze.pdf>. 48 A widely read and respected periodical is the Stockman-Grass Farmer (see the Resources Section). Also see ATTRA’s Sustainable Pasture Management at <http://attra.ncat.org/attra-pub/PDF/sustpast.pdf>, Rotational Grazing at <http://attra.ncat.org/attra-pub/PDF/rotgraze.pdf>, Matching Livestock and Forage Resources in Controlled Grazing at <http://attra.ncat.org/attra-pub/PDF/matchl&f.pdf>, and Introduc- tion to Paddock Design and Fencing—Water Systems for Controlled Grazing at <http://attra.ncat.org/attra- pub/PDF/paddock.pdf>, along with the Kerr Center for Sustainable Agriculture’s Cell Grazing: Getting Started on Your Place at <http://www.kerrcenter.com/kerrweb/publications/2002_proceedings/ cell_grazing.pdf> and Management Intensive Grazing at <http://www.kerrcenter.com/kerrweb/publica- tions/MIG/mangmnt_intense_graze.htm>. 49 Many state extension offices have lists of organic fertilizers and amendments featuring their N-P-K values and other information. Two good on-line sources are North Carolina’s Nutrient Content of Fertil- izer and Organic Materials at <http://www.soil.ncsu.edu/publications/Soilfacts/AG-439-18/> and Cornell University’s A Guide to the Nutrient Value of Organic Materials at <http://www.cce.cornell.edu/counties/ Suffolk/grownet/organic/nutrient.html>. A publication that might also be useful is the University of Georgia’s How to Convert an Inorganic Fertilizer Recommendation to an Organic One at <http:// www.ces.uga.edu/pubcd/C853.htm>. 50 See Rutgers University’s Agricultural Liming Materials at <http://www.rce.rutgers.edu/pubs/pdfs/ fs905.pdf>. 51 Contact information for OMRI can be found in the Resources Section of this workbook. 52 See ATTRA’s Protecting Water Quality on Organic Farms at <http://attra.ncat.org/attra-pub/PDF/om- waterquality.pdf>. 53 For more information see Charles Walter’s Weeds, Control Without Poisons (Acres USA), ATTRA’s Prin- ciples of Sustainable Weed Management for Croplands at <http://attra.ncat.org/attra-pub/PDF/weed.pdf>, and SAN’s A Whole-Farm Approach to Managing Pests at <http://www.sare.org/bulletin/farmpest/>. 54 See ATTRA’s Sustainable Pasture Management at <http://attra.ncat.org/attra-pub/PDF/sustpast.pdf>, Rotational Grazing at <http://attra.ncat.org/attra-pub/PDF/rotgraze.pdf>, and Matching Livestock and Forage Resources in Controlled Grazing at <http://attra.ncat.org/attra-pub/PDF/matchl&f.pdf>. 55 See ATTRA’s Benefits of Multispecies Grazing <http://attra.ncat.org/attra-pub/PDF/multispecies.pdf>. 56 See Ehrenfried Pfeiffer’s Weeds and What They Tell and Jay McCaman’s Weeds and Why They Grow, both available from Acres USA. 57 See NCAT’s Organic Crops Workbook at <http://attra.ncat.org/attra-pub/PDF/cropsworkbook.pdf> for more information on weed management in rotation crops. 58 See ATTRA’s Farmscaping to Enhance Biological Control at <http://attra.ncat.org/attra-pub/PDF/ farmscaping.pdf>. 59 See ATTRA’s Flame Weeding for Agronomic Crops at <http://attra.ncat.org/attra-pub/PDF/ flameweed.pdf>. Note that most of the information in this publication is primarily intended for row crop production. 60 For a brief description of weed biocontrol, see the Organic Agriculture Centre of Canada’s Research Report 2002—Biological Weed Control at <http://www.organicagcentre.ca/docs/9-4.pdf>. 61 See NCAT’s Organic Crops Workbook section V., “Supporting Biodiversity and the Rotation Practice Standard”, for information on crop diversity and crop rotation.
- 88. Revised February 2004 Page 88 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 62 ATTRA has information on managing these pests. For example, see ATTRA’s Grasshopper Management at <http://attra.ncat.org/attra-pub/PDF/grasshopper.pdf>. 63 See ATTRA’s Organic Alfalfa Production at <http://attra.ncat.org/attra-pub/PDF/alfalfa.pdf>. 64 NCAT’s Organic Crops Workbook can be found at <http://attra.ncat.org/attra-pub/PDF/ cropsworkbook.pdf>. 65 See ATTRA’s Biointensive Integrated Pest Management at <http://attra.ncat.org/attra-pub/PDF/ipm.pdf>, SAN’s A Whole-Farm Approach to Managing Pests at <http://www.sare.org/bulletin/farmpest/>, and Ohio State’s Sticky Traps: A Useful Tool for Pest-Scouting Programs at <http://ohioline.osu.edu/hyg-fact/ 1000/1033.html>. Most Cooperative Extension offices have further information on IPM. 66 See ATTRA’s Farmscaping to Enhance Biological Control at <http://attra.ncat.org/attra-pub/PDF/ farmscaping.pdf>. 67 To locate sources of beneficial insects, see Ohio State’s Commercial Suppliers of Beneficial Organisms at <http://ohioline.osu.edu/hyg-fact/2000/2122.html>. 68 Several good general resources on organic pest control agents are available. Among them are Univer- sity of Connecticut’s Pesticides for Organic Growers and Ignoring Labels on Organic Products Can Cause Prob- lems. Use the search feature at <http://www.hort.uconn.edu/ipm/> to locate both of these publica- tions. Also note that more detail on alternative pesticides is provided in NCAT’s Organic Crops Workbook at <http://attra.ncat.org/attra-pub/PDF/cropsworkbook.pdf>. 69 For more information on beneficial insects, see Oklahoma State’s Beneficial Insects at <http:// pearl.agcomm.okstate.edu/insects/home/f-7307.pdf> (you may need to locate the publication using the search feature at <http://pearl.agcomm.okstate.edu/>) and Purdue University’s Common Natural En- emies at <http://www.entm.purdue.edu/Entomology/ext/targets/e-series/EseriesPDF/E-92.pdf>. 70 Appendix B of ATTRA’s Biointensive Integrated Pest Management at <http://www.attra.org/attra-pub/ PDF/ipm.pdf> features a list of microbial pesticides, trade names, and suppliers. Most of these are permitted in certified organic production. 71 For more information on botanical pesticides, see Cornell University’s Nature’s Botanical Insecticide Arsenal at <http://www.cce.cornell.edu/counties/Suffolk/grownet/organic/botinsct.htm>. Also see Oklahoma State’s Botanical Pest Controls at <http://pearl.agcomm.okstate.edu/hort/ornamental/ f6433.htm>. (You can also locate the publication using the search feature at <http:// pearl.agcomm.okstate.edu/>.) 72 For more information on insecticidal soaps, see the University of Connecticut’s Insecticidal Soaps. To locate this publication, use the search feature at the University of Connecticut IPM website at <http:// www.hort.uconn.edu/ipm/>. 73 For assistance in locating sources of organic seeds and planting stock, see ATTRA’s Suppliers of Seed for Certified Organic Production (Including Untreated and Non-GMO Seed) at <http://attra.ncat.org/attra-pub/ altseed.html>. OMRI is developing a listing of certified organic seed and planting stock producers. See the OMRI Seed and Planting Stock List at <http://www.omri.org/OMRI_SEED_list.html>. 74 Details are provided in NCAT’s Organic Crops Workbook at <http://attra.ncat.org/attra-pub/PDF/ cropsworkbook.pdf>. 75 ATTRA has forms for recording your search for organic seeds and planting stock in Organic Livestock Documentation Forms at <http://www.attra.ncat.org/attra-pub/PDF/livestockforms.pdf>. 76 The presence of subsurface compaction can be found by using a penetrometer. Instructions for making and using a simple homemade penetrometer can be found in ATTRA’s Assessing the Pasture Soil Resource at <http://attra.ncat.org/attra-pub/pastsoil.html>. 77 A “Fertility / Soil Monitoring Log” is included in ATTRA’s Organic Livestock Documentation Forms at <http://attra.ncat.org/attra-pub/PDF/livestockforms.pdf>. 78 See ATTRA’s Sustainable Soil Management at <http://attra.ncat.org/attra-pub/PDF/soilmgmt.pdf> for more information on earthworms. 79 See ATTRA’s Dung Beetle Benefits in the Pasture Ecosystem, at <http://attra.ncat.org/attra-pub/PDF/ dungbeetle.pdf>.
- 89. Revised February 2004 Page 89 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 80 For more information on grass tetany, see the University of Nevada’s Grass Tetany in Beef Cattle at <http://www.forages.css.orst.edu/Topics/Pastures/Species/Grasses/Animal_issues/Tetany.html>. 81 For more information on prussic acid poisoning, see Purdue University’s Minimizing the Prussic Acid Poisoning Hazard in Forages at <http://www.forages.css.orst.edu/Topics/Pastures/Species/Grasses/ Animal_issues/Prussic_Minimizing.html>. 82 For more information on nitrate poisoning see the University of Nevada’s Nitrate Poisoning at <http://www.forages.css.orst.edu/Topics/Pastures/Species/Grasses/Animal_issues/Nitrate.html>. 83 For a discussion of endophyte toxicity in fescue, see The Tall Fescue Endophyte Story at <http:// www.caf.wvu.edu/~forage/fescue_endophtye/story.htm>. 84 See the Kerr Center for Sustainable Agriculture’s Riparian Area Management Techniques at <http:// www.kerrcenter.com/kerrweb/publications/riparian.pdf>. 85 For more information, see ATTRA’s Sustainable Pasture Management at <http://attra.ncat.org/attra- pub/PDF/sustpast.pdf>, Rotational Grazing at <http://attra.ncat.org/attra-pub/PDF/rotgraze.pdf>, Matching Livestock and Forage Resources in Controlled Grazing at <http://attra.ncat.org/attra-pub/ matchlandf.html>, and Introduction to Paddock Design and Fencing-Water Systems for Controlled Grazing at <http://attra.ncat.org/attra-pub/PDF/paddock.pdf>. Also see the Kerr Center for Sustainable Agriculture’s Management Intensive Grazing at <http://www.kerrcenter.com/kerrweb/publications/ MIG/mangmnt_intense_graze.htm> and Cell Grazing: Getting Started on Your Place at <http:// www.kerrcenter.com/kerrweb/publications/2002_proceedings/cell_grazing.pdf>. 86 For additional information on water quality for livestock, see Colorado State’s Livestock Drinking Water Quality at <http://www.ext.colostate.edu/pubs/livestk/04908.html>. 87 To be more precise, §205.237(b)(2) reads: “The producer of an organic operation must not…[p]rovide feed supplements or additives in amounts above those needed for adequate nutrition and health mainte- nance for the species at its specific stage of life.” 88 Contact information for OMRI can be found in the Resources Section of this workbook. 89 See ATTRA’s Hooped Shelters for Hogs at <http://attra.ncat.org/attra-pub/PDF/hooped.pdf>. 90 See ATTRA’s Organic Alternatives to Treated Lumber at <http://attra.ncat.org/attra-pub/PDF/ lumber.pdf>. 91 Moving ‘Em by Burt Smith and Stockmanship by Bud Williams are both considered leading works on the subject. Both books are available through The Stockman Grass Farmer (see Resources Section). Also rec- ommended is Dr. Temple Grandin’s webpage <http://www.grandin.com/> and Colorado State’s Live- stock Handler’s Safety at <http://www.ext.colostate.edu/pubs/livestk/01813.html>. 92 An excellent reference book for structural and household pest management is Common-Sense Pest Con- trol by Olkowski, Daar, and Olkowski. This book is available from Acres, USA. 93 See Ohio State’s “Composting Livestock Mortalities” at <http://www.oardc.ohio-state.edu/fabe/ composting.htm>, the University of Minnesota’s “Composting Is The Natural Way To Dispose Of Dead Animals” at <http://www.extension.umn.edu/extensionnews/1997/JN1329.html>, and Penn State’s “Dead Pig Composting” at <http://www.penpages.psu.edu/penpages_reference/28901/ 28901209.HTML>. In addition, the Water Quality Program of the University of Missouri Outreach and Extension has guide sheets on dead animal regulation and composting. Request guide sheets WQ 205- WQ 211, WQ 216 and WQ 225 at <http://www.fse.missouri.edu/waterquality/wqprograms/ composting.htm>. 94 NCAT’s Organic Crops Workbook can be found at <http://attra.ncat.org/attra-pub/PDF/ cropsworkbook.pdf>. Also see ATTRA’s Manures for Organic Crop Production at <http://attra.ncat.org/ attra-pub/PDF/manures.pdf>. Also helpful is North Carolina State’s Components of a Complete Manure Management Plan at <http://www.bae.ncsu.edu/bae/programs/extension/publicat/wqwm/ ebae185_93.html>.
- 90. Revised February 2004 Page 90 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 95 See ATTRA’s Farm-Scale Composting Resource List at <http://attra.ncat.org/attra-pub/PDF/ farmcompost.pdf>, the University of Missouri’s Making and Using Compost at <http:// muextension.missouri.edu/xplor/agguides/hort/g06956.htm>, the University of Maine’s How Compost Happens at <http://www.umext.maine.edu/onlinepubs/htmpubs/1159.htm>, and Louisiana State’s Basic Principles of Composting at <http://www.lsuagcenter.com/Communications/pdfs_bak/compost.PDF>. 96 Sources of biological control agents and information include Peaceful Valley Farm Supply at <http:// www.groworganic.com/>, 530-272-4769; and The Source at <http://www.sourcebiofly.com/>. 97 See the University of Florida’s Insect Attractants and Traps at <http://edis.ifas.ufl.edu/BODY_IN080>. 98 See ATTRA’s Organic Livestock Documentation Forms at <http://attra.ncat.org/attra-pub/PDF/ livestockforms.pdf> for an example of a compost production record. 99 See Oklahoma State University’s Freeze Branding Cattle at <http://www.ansi.okstate.edu/exten/beef/ FS3250.PDF>. 100 To learn more about CAVM, the Complementary and Alternative Veterinary Medicine website at <http://www.altvetmed.com/> is recommended. 101 To find a list of practicing holistic veterinarians, state-by-state, visit the American Holistic Veterinary Medical Association website at <http://www.ahvma.org/> or contact them at 2218 Old Emmorton Road, Bel Air, MD 21015, Tel: 410-569-0795 Fax: 410-569-2346. Other useful resources include the Academy of Veterinary Homeopathy at <http://www.theavh.org/>, or contact them at P.O. Box 9280, Wilmington, DE 19809, Tel: 866-652-1590; the International Association of Veterinary Homeopathy, 2707 76th Av- enue, SE, Mercer Island, WA 98040, Tel: 206-232-7667, website <http://www.iavh.at/>; and the Veteri- nary Botanical Medicine Association, 334 Knollwood Lane, Woodstock, GA 30188, website <http:// www.vbma.org/>. 102 Vaccines are the only inputs that might derive from genetic engineering and still be allowed in organic production [§205.105(e)]. 103 Several books on treatment of livestock using herbs can be found at the 7mFarm & Herbals website at <http://www.7mfarm.com/books.html>. Another excellent source is Acres, USA. One classic book on herbal treatments is Juliette de Bairacli Levy’s The Complete Herbal Handbook for Farm and Stable, available from both Acres U.S.A. and 7mFarm. 104 Several books on treatment of livestock using homeopathy can be found at the 7mFarm & Herbals website at <http://www.7mfarm.com/books.html> and at the Homeopathic Educational Services website at <http://www.homeopathic.com/>. Another excellent source for books on homeopathy for livestock is Acres, USA. 105 A brief description of acupuncture as used by a veterinarian can be found at <http:// www.risingsunvet.com/acupun.htm>. Several books on treatment of livestock using acupuncture can be found at the 7mFarm & Herbals website at <http://www.7mfarm.com/books.html>. 106 Radionics is one of many esoteric practices permitted in organic production. For information on radi- onics see Radionics in Agriculture at <http://home.earthlink.net/~gkuepper/index/Radionics.htm>. 107 Some brief descriptive information can be found at Reiki for Animals at <http://www.adoredbeast.com/ july00_2.shtml>. 108 See ATTRA’s Organic Livestock Documentation Forms at <http://attra.ncat.org/attra-pub/PDF/ livestockforms.pdf> for a Health Care Products: Product Inventory form. 109 See ATTRA’s Organic Livestock Documentation Forms at <http://attra.ncat.org/attra-pub/PDF/ livestockforms.pdf> for examples of an Individual Organic Animal Health Record and an Organic Poul- try Flock Health Record. 110 See ATTRA’s Integrated Parasite Management for Livestock at <http://attra.ncat.org/attra-pub/PDF/ livestock-ipm.pdf>. Also see Iowa State’s Gastrointestinal Parasites: Natural and/or Old-time Treatments at <http://www.pfi.iastate.edu/OFR/Anthelmintics.htm>. 111 Electrotherapies include controversial modalities and tools like the Hulda Clark zapper. For informa- tion pro and con see Zapper: General Information at <http://www.lifedevice.com/Zapper.htm> and Fasci- olopsis buski at <http://www.biosci.ohio-state.edu/~parasite/fasciolopsis.html>.
- 91. Revised February 2004 Page 91 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 112 Radionics is one of many esoteric practices allowed in organic production. For information on radion- ics see Radionics in Agriculture at <http://home.earthlink.net/~gkuepper/index/Radionics.htm>. 113 Several books on treatment of livestock using herbs can be found at the 7mFarm & Herbals website at <http://www.7mfarm.com/books.html>. Another excellent source is Acres, USA. One classic book on herbal treatments is Juliette de Bairacli Levy’s The Complete Herbal Handbook for Farm and Stable, available from both Acres U.S.A. and 7mFarm. 114 See ATTRA’s Dung Beetle Benefits in the Pasture Ecosystem, at <http://attra.ncat.org/attra-pub/PDF/ dungbeetle.pdf>. 115 See the University of Nebraska’s Sanitation for Fly and Disease Management at Confined Livestock Facilities at <http://ianrpubs.unl.edu/insects/g1175.htm>. 116 Sources of biological control agents and information include: Peaceful Valley Farm Supply at <http:/ /www.groworganic.com>, 530-272-4769; and The Source at <http://www.sourcebiofly.com/>. 117 For more information on bats and bat conservation, see Bat Conservation International at <http:// www.batcon.org/> and the Organization for Bat Conservation at <http://www.batconservation.org/>. 118 For information on purple martins, see The Purple Martin Conservation Association at <http://www.purplemartin.org/>. 119 The University of Kentucky has a discussion on the efficacy and function of the walk-through fly trap, which is most effective for horn flies, at <http://www.uky.edu/Agriculture/Entomology/entfacts/ livestc/ef508.htm>. Highly descriptive information on walk-through flytraps can be found in the Uni- versity of Missouri’s Walk-Through Trap to Control Horn Flies on Cattle at <http:// muextension.missouri.edu/xplor/agguides/agengin/g01195.htm>. 120 Information on traps for deer and horse flies can be found in the University of Florida’s The Trolling Deer Fly Trap at <http://extlab1.entnem.ufl.edu/PestAlert/deerfly.htm>. General information on insect traps and their design can be found in the University of Florida’s Insect Attractants and Traps at <http:// edis.ifas.ufl.edu/BODY_IN080>. 121 Acaricides are pesticides that kill mites and/or ticks. 122 ATTRA’s Beef Farm Sustainability Checksheet at <http://attra.ncat.org/attra-pub/PDF/beefchec.pdf> and Dairy Farm Sustainability Checksheet at <http://attra.ncat.org/attra-pub/PDF/dairychecksheet.pdf> are also strongly recommended. 123 For basic information on poultry diseases, see Agriculture Canada’s Poultry Fact Sheet #3 at <http:// eru.usask.ca/saf_corp/livestok/poultry/diseases.htm>. Also, there is a list of poultry disease links at <http://www.poultryconnection.com/links/Diseases_and_Disorders/>. 124 See ATTRA’s Predator Control for Sustainable & Organic Livestock Production at <http://attra.ncat.org/ attra-pub/predator.html>. 125 See the Colorado State’s Livestock Guard Dogs, Llamas and Donkeys at <http://www.ext.colostate.edu/ pubs/livestk/01218.html>. 126 See Ohio State’s “Composting Livestock Mortalities” at <http://www.oardc.ohio-state.edu/fabe/ composting.htm>, the University of Minnesota’s “Composting Is The Natural Way To Dispose Of Dead Animals” at <http://www.extension.umn.edu/extensionnews/1997/JN1329.html>, and Penn State’s “Dead Pig Composting” at <http://www.penpages.psu.edu/penpages_reference/28901/ 28901209.HTML>. In addition, the Water Quality Program of the University of Missouri Outreach and Extension has guide sheets on dead animal regulation and composting. Request guide sheets WQ 205- WQ 211, WQ 216 and WQ 225 at <http://www.fse.missouri.edu/waterquality/wqprograms/ composting.htm>. 127 ATTRA has information prepared on natural pest control alternatives for grain storage. See Stored Grain Pest Management at < http://attra.ncat.org/attra-pub/PDF/storedgrain.pdf>. 128 See Colorado State’s Formulating Rations With the Pearson Square at <http://www.ext.colostate.edu/ pubs/livestk/01618.html>. 129 ATTRA has generic Organic System Plan forms available in the publication Creating an Organic Produc- tion and Handling System Plan: A Guide to Organic Plan Templates at <http://attra.ncat.org/attra-pub/ PDF/handlingsys.pdf>. A portion of the publication includes templates for organic handling systems.
- 92. Revised February 2004 Page 92 NCAT’s Organic Livestock Workbook: A Guide to Sustainable and Allowed Practices 130 ATTRA’s Organic Marketing Resources at < http://attra.ncat.org/attra-pub/PDF/markres.pdf> is ad- vised reading for those exploring organic marketing options. Also recommended is SAN’s Reap New Profits: Marketing Strategies for Farmers and Ranchers at < http://www.sare.org/market99/index.htm>. ATTRA also has several publications that specifically address the marketing of livestock products, these include: Alternative Meat Marketing at <http://attra.ncat.org/attra-pub/PDF/Altmeat.pdf>, Alternative Beef Marketing at < http://attra.ncat.org/attra-pub/PDF/altbeef.pdf>, and Alternative Marketing of Pork at < http://attra.ncat.org/attra-pub/PDF/altpork.pdf>. 131 For an overview of grass-fed beef and chicken production and marketing from a holistic management perspective, see Richard and Peggy Sechrist’s article Organic, Grass-Fed Beef and Chicken: Management and Markets at <http://www.kerrcenter.com/kerrweb/publications/2002_proceedings/grass-fed_beef.pdf>. 132 See ATTRA’s Community Supported Agriculture at <http://attra.ncat.org/attra-pub/PDF/csa.pdf>. 133 See ATTRA’s Direct Marketing at <http://attra.ncat.org/attra-pub/PDF/directmkt.pdf>. 134 See ATTRA’s Farmers’ Markets at < http://attra.ncat.org/attra-pub/PDF/farmmarket.pdf>. 135 The ATTRA publications Direct Marketing at <http://attra.ncat.org/attra-pub/PDF/directmkt.pdf> and Entertainment Farming & Agri-Tourism at <http://attra.ncat.org/attra-pub/PDF/entertn.pdf> have information on roadside sales. In addition, Cornell University has building plans and other information available in their Extension publication entitled Facilities for Roadside Markets at <http:// www.cce.cornell.edu/publications/agriculture.cfm>. 136 See ATTRA’s Entertainment Farming & Agri-Tourism at <http://attra.ncat.org/attra-pub/PDF/ entertn.pdf>. 137 In the Julian Date Calendar, each day is assigned a number in sequence from 001 through 365 (366 in leap years). The Julian system is commonly used for product coding. An example of the Julian calendar is featured at <http://www.dscr.dla.mil/sbo1/julian_date_calendar.htm> . 138 See ATTRA’s Organic Livestock Documentation Forms at <http://attra.ncat.org/attra-pub/PDF/ livestockforms.pdf>. 139 A sample of a complaint log is provided as a template on the Minnesota Department of Agriculture website at: <http://www.mda.state.mn.us/esap/organic/sampleforms.pdf>. IP228 Slot 228