Answers to Your Questions: JANUARY

Developed by The New Farm® Answer Team

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.

1. 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 species;
  • Fats, oils, grease, and tallow (from cattle and other species);
  • 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.

2. 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.

3. 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 certification agency.

4. 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 feed.

5. 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.

6. 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


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