Where does it state in the NOP section that pasture land must be provided for all species of livestock? Must animals be individually ear tagged with accompanying records in order to qualify for organic production?

Joanne Berger


We put your question to our organic policy specialist, Jim Riddle. He now holds the endowed chair in agricultural systems at the University of Minnesota and is a longtime advocate of sustainable agriculture. Here’s what Jim had to say:

“The NOP does not state that pasture must be provided to all species of livestock. Section 205.239(a)(1) states that every operation must provide ‘access to the outdoors, shade, shelter, exercise areas, fresh air, and direct sunlight suitable to the species, its stage of production, the climate, and the environment.’ 205.239(a)(2) requires access to pasture for ruminants.

“Section 205.236(c) requires that, ‘the producer of an organic livestock operation must maintain records sufficient to preserve the identity of all organically managed animals and edible and nonedible animal products produced on the operation.’ Section 205.103 contains further record keeping requirements which must be met by all organic operations. Under that section, records must: be adapted to the operation; fully disclose all activities and transactions in sufficient detail as to be readily understood and audited; be maintained for at least 5 years; demonstrate compliance with the NOP; and be available for inspection and copying.

“The NOP does not mandate the use of individual ear tags, but, for large animals, ear tags, neck chains, tattoos, and brands are commonly used to satisfy the animal identification requirement. Individual animal records are generally maintained for large animals. Group or flock records are generally used for smaller species such as poultry.”




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