Organics in the News

Organic livestock rules reduce risky feeding,
but tighter restrictions would improve safety.


By James A. Riddle

Organics in the News

Editor’s NOTE: Certified organic farming enjoys success – and challenges – like never before thanks to surging consumer demand, USDA-regulated standards, and increasing attention to how farming impacts our land, water, communities and human health.

We’ve asked Jim Riddle to bring his perspective to our e-pages as a voice from the progressive center of this dynamic food and farming sector. “Organics in the News” is an occasional series where Riddle shares his insights in the context of current events.

James A. (Jim) Riddle has been an organic farmer, gardener, inspector, educator, policy analyst, author, and consumer. He was founding chair of the Independent Organic Inspectors Association, (IOIA), and co-author of the IFOAM/IOIA International Organic Inspection Manual.

Riddle has helped train hundreds of organic inspectors throughout the world. Riddle serves as vice-chair of the National Organic Standards Board, which advises the USDA on organic agriculture policies and regulations. In 2003, Jim was appointed Endowed Chair of Agricultural Systems at the University of Minnesota.

He serves as an organic policy specialist for NewFarm.org.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

April 5, 2004:

Introduction The National Organic Program Final Rule requires organic livestock producers to implement numerous proactive management practices, including a prohibition on the feeding of mammalian or poultry slaughter by-products to mammals or poultry. In order to minimize the risk of organic livestock being fed slaughter by-products, some changes should be made to the NOP regulation and how it is implemented.

Background A review of the NOP regulation reveals that numerous requirements effectively minimize the risk that organic livestock, and livestock producing organic products, are not fed slaughter by-products. These regulatory requirements include:

a) Under the NOP, organic livestock must be fed and managed organically their entire lives in order to be slaughtered for organic meat. In fact, an animal’s mother must be fed and managed organically during the last third of the animal’s gestation in order for the animal to be sold as organic slaughter stock.

b) There is an absolute ban on the feeding of mammalian and poultry slaughter by-products to organic mammals and poultry.

c) 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 (such as blood), no antibiotics, and no products from rBST treated animals.

d) Traceability is a fundamental requirement for organic certification. The NOP 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.

e) 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.

f) Organic livestock 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.

A closer analysis of the regulation reveals the following pathways whereby slaughter by-products, or animals fed slaughter by-products, could enter organic livestock production systems:

1) 205.236(a)(2) allows conventional dairy cows to be converted to organic production, either using the "one year" or "80/20" method of conversion. This allowance means that animals that previously consumed slaughter by-products could be found on organic dairy farms. Such animals could never be slaughtered for organic meat, but they could produce organic milk and organic calves.

2) The current interpretation of CFR205.236 (a)(2)(iii) provides for two paths in which non-organic livestock may enter certified organic dairy operations. One method allows organic dairy operations to employ a one-year conversion. This method of conversion has been interpreted to allow dairy operations to continually introduce non-organic replacement animals, provided that the animals are fed and managed organically for one year prior to producing organic milk. The second method, known as “80/20”, requires an operation to use replacement animals which have been fed and managed organically from the last third of gestation.

Organic dairy operations that continually introduce non-organic animals into a herd may pose a risk of having animals in an organic herd that were previously fed slaughter by-products. In contrast, farms that manage all animals organically from the last third of gestation may reduce this risk.

3) 205.236(a)(3) allows breeder stock from nonorganic operations to be used to produce organic offspring, provided that the breeder stock are "brought onto the [organic] facility no later than the last third of gestation." Breeder stock, sourced from nonorganic farms, could have been previously fed slaughter by-products. While it may not be practical to prohibit nonorganic breeder stock from producing organic offspring, the NOP should clarify that, once breeder stock have been converted to organic production, they cannot be managed non-organically and continue to produce organic offspring.

4) While 205.237(b)(4) prohibits the feeding of manure (e.g. poultry litter which may contain spilled feed with slaughter by-products) and 205.237(b)(5) prohibits feeding "mammalian or poultry by-products to mammals or poultry", there is no linkage to 205.604, which is the list of non-synthetic substances prohibited in organic livestock production. The only item listed in 205.604 is strychnine. To clarify the prohibition of feeding manure and slaughter by-products, the NOSB and NOP should amend 205.604 to show specific "non-synthetic" feed ingredients and additives items which are prohibited. Such action would be similar to the prohibition of arsenic in both the crops section at 205.206(f) and on the National List at 205.602(b).

5) There is confusion if the prohibition in 205.237(b)(5) is limited to "slaughter by-products." Taken literally, someone could feed slaughter products to organic animals. There is no definition of "slaughter by-products". The NOP should issue clarification stating that the prohibition of slaughter by-products includes all slaughter products, not just waste materials.

6) The NOSB has recommended that ingredients and processing aids allowed by 205.605 and 205.606 for human consumption also be allowed in livestock feeds. If enacted, this could allow gelatin and anima- derived enzymes (and possibly other animal products) to be used in livestock feed. If this recommendation of the NOSB is enacted, the NOP should specifically exclude animal derivatives for use in livestock feed by placing them on 205.604 as prohibited for use in organic livestock production.

7) Likewise, the NOSB has recommended that feed additives allowed by the Association of American Feed Control Officials (AAFCO) be allowed under 205.603(d). AAFCO allows numerous animal slaughter by-products to be used as feed additives. If the prior recommendation of the NOSB is enacted, the NOP should specifically prohibit AAFCO-allowed feed additives which contain animal derivatives by placing them on 205.604 as prohibited for use in organic livestock production.

Recommendation In order to further minimize the risk of slaughter by-products and animals which have consumed slaughter by-products from being used on organic livestock operations, the following actions should be implemented:

1) The NOP should change the regulation or reverse its "two track" interpretation and require all dairies, once they have converted to organic production, to use replacement animals which have been fed and managed organically from the last third of gestation.

2) The NOP should clarify that, once breeder stock have been converted to organic production, they cannot be managed non-organically and continue to produce organic offspring.

3) The NOSB and NOP should amend 205.604 to indicate exactly which "non-synthetic" feed ingredients and additives are prohibited.

4) The NOP should issue clarification stating that the prohibition of slaughter by-products include all slaughter products, not just waste materials.

5) If items on 205.605 and 205.606 are allowed for use in organic livestock production, the NOP should specifically prohibit animal derivatives by placing them on 205.604 as prohibited for use in organic livestock production.

6) The NOP should specifically prohibit AAFCO-allowed feed additives which contain animal derivatives by placing them on 205.604 as prohibited for use in organic livestock production.

Jim Riddle serves as vice-chair of the National Organic Standards Board, which advises the USDA on organic agriculture policies and regulations.