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. |
