January 12, 2004:
In light of recent developments we are dedicating the first
round of the new year to resolving issues and quelling fears
surrounding mad cow disease.
I am very concerned about the case of mad cow disease (BSE)
recently found in the United States. I’m thinking of
feeding organic beef to my family. Are there any differences
between organic and non-organic beef production?
There are significant differences between organic and non-organic
meat production. To begin with, there is an absolute ban on
the feeding of mammalian and poultry slaughter by-products
to organic mammals and poultry. This contrasts with non-organic
regulations, which still allow the feeding of cattle and other
slaughter by-products to cattle and other livestock.
The FDA banned the feeding of cattle brain and spinal tissue
to cattle in 1997, but they still allow the following materials
to be fed to non-organic cattle:
- Blood and blood products (from cattle and other species);
- Gelatin (rendered from the hooves of cattle and other
- Fats, oils, grease, and tallow (from cattle and other
- Poultry and poultry by-products;
- Rendered pork protein;
- Rendered horse protein;
- Poultry manure (which may include spilled feed containing
rendered animal products); and
- Human food wastes* (which may contain beef scraps).
None of the items listed above may be fed to organic cattle
or other organic livestock.
What about milk replacer? I’ve heard that non-organic
milk replacer often contains cattle and hog blood. Is this
allowed in organic production?
It’s true that non-organic milk replacer commonly
contains spray dried blood plasma and blood serum from cattle
and hogs. Research in Europe has shown that BSE can be transmitted
by blood, which is why any U.S. citizen who has traveled to
a country with BSE is prohibited from donating blood.
Most organic calves are fed organic whole milk. Milk replacer
may only be used as an emergency supplement. If milk replacer
is used, the NOP regulation requires that the milk replacer
contain no non-milk products, no antibiotics, and no products
from rBST treated animals.
I’ve heard that the USDA is planning to implement a
nationwide livestock tracking system. What kind of records
must be maintained for organic cattle?
Traceability is a fundamental requirement for organic certification.
The National Organic Program regulation, in section 205.236.c,
requires that all organic livestock operations must maintain
records “sufficient to preserve the identity of all
organically managed animals and edible and non-edible animal
products produced on the operation.” Section 205.103
further requires that all organic operations, including those
with livestock, maintain records which “fully disclose
all activities and transactions” and “demonstrate
compliance with the Act and regulations.”
This means that records kept by organic livestock producers
must track all animals, including the source(s) of the animals;
the sources and quantities of feed; all medications; and all
products produced and sold. These records are reviewed at
least annually by an inspector representing a USDA-accredited
What about feed mills? Are there any requirements that prevent
feed mills from mixing organic feed with feed which may contain
rendered animal by-products?
Yes. In order to produce organic livestock feed, feed mills
must be inspected and certified. If they produce both organic
and non-organic feed, they must implement procedures, documented
with written records, to prevent the commingling of organic
and non-organic feed. This includes steps to clean storage
bins and mixing and bagging equipment prior to producing batches
of organic feed. Organic feed mills also must prevent the
contamination of organic feed with antibiotics, hormones,
slaughter by-products, and insecticides which may be added
to non-organic rations. They must also ensure that rodenticides
and insecticides used in the facility do not contaminate organic
Are organic animals slaughtered in special slaughterhouses?
Organic beef must be slaughtered in slaughterhouses which
are certified organic. As such, slaughterhouses must slaughter
organic animals when all equipment is clean and empty. There
must be no chance of commingling organic with non-organic
meat, or contaminating organic meat with prohibited materials.
Records must be maintained of all organic slaughter activities
and steps taken to protect organic integrity. If a plant can
prove that it can segregate organic animals and meat products
and take all steps necessary to protect organic integrity,
then it can be certified. It does not have to be dedicated
to slaughtering only organic animals, however.
Have there ever been any cases of organic cattle diagnosed
with mad cow disease?
There were several cases in Europe where cattle on organic
farms were diagnosed with the disease. Upon further investigation,
it was established that the cattle had not been born on the
organic farms. They had been purchased from non-organic farms,
and converted to organic production.
In the United States, organic cattle must be fed and managed
organically their entire lives in order to be slaughtered
for organic beef. In fact, a calf’s mother must be fed
and managed organically during the last third of the calf’s
gestation in order for the calf to be sold as organic slaughter
stock. In the U.S., the only animals which can be converted
from non-organic to organic production are dairy cattle, breeding
stock, and animals which produce non-edible products, such
as wool. If such animals are converted from non-organic to
organic production, those animals can never be slaughtered
for organic meat.
* All items from the American Association of Feed Control
Officials’ brochure “Reduce the threat of BSE”
available at www.aafco.org
For a full list of your questions and our
answers as well as some highlighted articles, visit our certification
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