Getting Organic Certification
James A. Riddle
Endowed Chair in Agricultural Systems
University of Minnesota
Proceedings of the Midwest Poultry Federation Convention
March 16-18, 2004, St. Paul, MN
In the United States, it has only been legal to label meat as "organic" since February, 1999. Because of this, the organic livestock industry is still very much in its infancy, but production is growing rapidly. Certified organic pasture and rangeland more the doubled between 1997 and 2001, and was up 28 percent from 2000 to 2001, mirroring the rapid expansion in organic livestock and poultry. The number of certified organic beef cattle, milk cows, hogs, pigs, sheep, and lambs was up nearly four-fold since 1997, and up 27 percent from 2000 to 2001. Poultry animals raised under certified organic management - including laying hens, broilers, and turkeys - showed even higher rates of growth during this period.
With the Organic Foods Production Act now in force, and with consumer demand for organic products growing at over 20 percent per year, more and more operators are interested in getting certified to enter this growing sector.
In order to get certified, an operator first must contact a USDA-accredited certifying agent (ACA). A complete list of ACAs, along with contact information for each, can be found at www.ams.usda.gov/nop/CertifyingAgents/Accredited.html
Organic System Plan
Every certification applicant and certified organic operator must develop an organic system plan that is agreed to by the producer and an accredited certifying agent. An organic system plan must meet the requirements of the Organic Foods Production Act and the National Organic Program Final Rule.
An organic system plan must include:
(1) A description of practices and procedures to be performed and maintained, including the frequency with which they will be performed;
(2) A list of each substance to be used as a production or handling input, indicating its composition, source, location(s) where it will be used, and documentation of commercial availability, as applicable;
(3) A description of the monitoring practices and procedures to be performed and maintained, including the frequency with which they will be performed, to verify that the plan is effectively implemented;
(4) A description of the recordkeeping system implemented to comply with the requirements established in § 205.103;
(5) A description of the management practices and physical barriers established to prevent commingling of organic and nonorganic products on a split operation and to prevent contact of organic production and handling operations and products with prohibited substances; and
(6) Additional information deemed necessary by the certifying agent to evaluate compliance with the regulations.
Every certified operation must maintain records concerning the production, harvesting, and handling of organic products. Such records must:
(1) Be adapted to the particular business that the certified operation is conducting;
(2) Fully disclose all activities and transactions of the certified operation in sufficient detail as to be readily understood and audited;
(3) Be maintained for not less than 5 years beyond their creation; and
(4) Be sufficient to demonstrate compliance with the Act and the regulations in this part.
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.
The operator must make the records available for inspection and copying during normal business hours by authorized representatives of the USDA, the applicable State program's governing State official, and the certifying agent.
Origin of livestock
Organic livestock must be under continuous organic management from the last third of gestation or hatching, except that poultry or edible poultry products must be from poultry that has been under continuous organic management beginning no later than the second day of life.
Livestock or edible livestock products that are removed from an organic operation and subsequently managed on a nonorganic operation may be not sold, labeled, or represented as organically produced.
Breeder or dairy stock that has not been under continuous organic management since the last third of gestation may not be sold, labeled, or represented as organic slaughter stock.
The producer of an organic livestock operation must provide livestock with a total feed ration composed of agricultural products, including pasture and forage, that are organically produced and, if applicable, organically handled, except that nonsynthetic substances and synthetic substances allowed under § 205.603 may be used as feed additives and supplements.
The producer of an organic livestock operation must not:
(1) Use animal drugs, including hormones, to promote growth;
(2) Provide feed supplements or additives in amounts above those needed for adequate nutrition and health maintenance for the species at its specific stage of life;
(3) Feed plastic pellets for roughage;
(4) Feed formulas containing urea or manure;
(5) Feed mammalian or poultry slaughter by-products to mammals or poultry; or
(6) Use feed, feed additives, and feed supplements in violation of the Federal Food, Drug, and Cosmetic Act.
Livestock health care
The producer must establish and maintain preventive livestock health care practices, including:
(1) Selection of species and types of livestock with regard to suitability for site-specific conditions and resistance to prevalent diseases and parasites;
(2) Provision of a feed ration sufficient to meet nutritional requirements, including vitamins, minerals, protein and/or amino acids, fatty acids, energy sources, and fiber (ruminants);
(3) Establishment of appropriate housing, pasture conditions, and sanitation practices to minimize the occurrence and spread of diseases and parasites;
(4) Provision of conditions which allow for exercise, freedom of movement, and reduction of stress appropriate to the species;
(5) Performance of physical alterations as needed to promote the animal's welfare and in a manner that minimizes pain and stress; and
(6) Administration of vaccines and other veterinary biologics.
When preventive practices and veterinary biologics are inadequate to prevent sickness, a producer may administer synthetic medications, provided that such medications are allowed under § 205.603.
Parasiticides allowed under § 205.603 may be used on:
(1) Breeder stock, when used prior to the last third of gestation but not during lactation for progeny that are to be sold, labeled, or represented as organically produced; and
(2) Dairy stock, when used a minimum of 90 days prior to the production of milk or milk products that are to be sold, labeled, or represented as organic.
Prohibited health care practices and inputs
The producer of an organic livestock operation must not:
(1) Sell, label, or represent as organic any animal or edible product derived from any animal treated with antibiotics, any substance that contains a synthetic substance not allowed under § 205.603, or any substance that contains a nonsynthetic substance prohibited in § 205.604.
(2) Administer any animal drug, other than vaccinations, in the absence of illness;
(3) Administer hormones for growth promotion;
(4) Administer synthetic parasiticides on a routine basis;
(5) Administer synthetic parasiticides to slaughter stock;
(6) Administer animal drugs in violation of the Federal Food, Drug, and Cosmetic Act; or
(7) Withhold medical treatment from a sick animal in an effort to preserve its organic status. All appropriate medications must be used to restore an animal to health when methods acceptable to organic production fail. Livestock treated with a prohibited substance must be clearly identified and shall not be sold, labeled, or represented as organically produced.
Livestock living conditions
The producer of an organic livestock operation must establish and maintain livestock living conditions which accommodate the health and natural behavior of animals, including:
(1) 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;
(2) Access to pasture for ruminants;
(3) Appropriate clean, dry bedding. If the bedding is typically consumed by the animal species, it must comply with the feed requirements of § 205.237;
(4) Shelter designed to allow for:
(i) Natural maintenance, comfort behaviors, and opportunity to exercise;
The producer of an organic livestock operation may provide temporary confinement for an animal because of:
(ii) Temperature level, ventilation, and air circulation suitable to the species; and
(iii) Reduction of potential for livestock injury.
(1) Inclement weather;
(2) The animal's stage of production;
(3) Conditions under which the health, safety, or well being of the animal could be jeopardized; or
(4) Risk to soil or water quality.
The producer of an organic livestock operation must manage manure in a manner that does not contribute to contamination of crops, soil, or water by plant nutrients, heavy metals, or pathogenic organisms and optimizes recycling of nutrients.
Labeling of livestock feed
Organic livestock feed products may display on any package panel the following terms:
(1) The statement, "100 percent organic" or "organic," as applicable, to modify the name of the feed product;
(2) The USDA seal;
(3) The seal, logo, or other identifying mark of the certifying agent which certified the production or handling operation producing the raw or processed organic ingredients used in the finished product, Provided, That, such seals or marks are not displayed more prominently than the USDA seal;
(4) The word, "organic," or an asterisk or other reference mark which is defined on the package to identify ingredients that are organically produced. Water or salt included as ingredients cannot be identified as organic.
Organic livestock feed products must:
(i) On the information panel, below the information identifying the handler or distributor of the product and preceded by the statement, "Certified organic by...," or similar phrase, display the name of the certifying agent that certified the handler of the finished product. The business address, Internet address, or telephone number of the certifying agent may be included in such label.
(ii) Comply with other Federal agency or State feed labeling requirements as applicable.
205.603 Synthetic substances allowed for use in organic livestock production
In accordance with restrictions specified in this section, the following synthetic substances may be used in organic livestock production:
(a) As disinfectants, sanitizer, and medical treatments as applicable.
(b) As topical treatment, external parasiticide or local anesthetic as applicable.
(2) Aspirin-approved for health care use to reduce inflammation.
(i) Ethanol-disinfectant and sanitizer only, prohibited as a feed additive.
(ii) Isopropanol-disinfectant only.
(4) Chlorhexidine-Allowed for surgical procedures conducted by a veterinarian. Allowed for use as a teat dip when alternative germicidal agents and/or physical barriers have lost their effectiveness.
(5) Chlorine materials-disinfecting and sanitizing facilities and equipment. Residual chlorine levels in the water shall not exceed the maximum residual disinfectant limit under the Safe Drinking Water Act.
(i) Calcium hypochlorite.
(ii) Chlorine dioxide.
(iii) Sodium hypochlorite.
(6) Electrolytes-without antibiotics.
(8) Glycerine-Allowed as a livestock teat dip, must be produced through the hydrolysis of fats or oils.
(9) Hydrogen peroxide.
(11) Magnesium sulfate.
(12) Oxytocin-use in postparturition therapeutic applications.
(13) Parasiticides. Ivermectin-prohibited in slaughter stock, allowed in emergency treatment for dairy and breeder stock when organic system plan-approved preventive management does not prevent infestation. Milk or milk products from a treated animal cannot be labeled as provided for in subpart D of this part for 90 days following treatment. In breeder stock, treatment cannot occur during the last third of gestation if the progeny will be sold as organic and must not be used during the lactation period of breeding stock.
(14) Phosphoric acid-allowed as an equipment cleaner, Provided, That, no direct contact with organically managed livestock or land occurs.
(1) Copper sulfate.
(c) As feed supplements-Milk replacers-without antibiotics, as emergency use only, no nonmilk products or products from BST treated animals.
(3) Lidocaine-as a local anesthetic. Use requires a withdrawal period of 90 days after administering to livestock intended for slaughter and 7 days after administering to dairy animals.
(4) Lime, hydrated-as external pest control, not permitted to cauterize physical alterations or deodorize animal wastes.
(5) Mineral oil-for topical use and as a lubricant.
(6) Procaine-as a local anesthetic, use requires a withdrawal period of 90 days after administering to livestock intended for slaughter and 7 days after administering to dairy animals.
(d) As feed additives.
(1) DL-Methionine, DL-Methionine-hydroxy analog, and DL-Methionine-hydroxy analog calcium-for use only in organic poultry production until October 21, 2005.
(e) As synthetic inert ingredients as classified by the Environmental Protection Agency (EPA), for use with nonsynthetic substances or a synthetic substances listed in this section and used as an active pesticide ingredient in accordance with any limitations on the use of such substances.
(2) Trace minerals, used for enrichment or fortification when FDA approved.
(3) Vitamins, used for enrichment or fortification when FDA approved.
(1) EPA List 4-Inerts of Minimal Concern.
Nonsynthetic substances prohibited for use in organic livestock production
The following nonsynthetic substances may not be used in organic livestock production:
Over the past 24 years, 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. He has helped train hundreds of organic inspectors throughout the world. Jim serves on the Minnesota Department of Agriculture's Organic Advisory Task Force, and was instrumental in the passage of Minnesota's landmark organic certification cost-share program. Jim serves as vice-chair of the National Organic Standards Board, which advises the USDA on organic agriculture policies and regulations. Jim holds degrees in biology and political science from Grinnell College, and works part time as an organic policy specialist for Rodale's newfarm.org. In 2003, Jim was appointed Endowed Chair of Agricultural Systems at the University of Minnesota.