We’ve made great progress in enforcing the organic pasture requirement; the next step is at hand—we can’t stop now!

Thanks to more than 8000 public comments and the personal testimony of numerous organic dairy producers in support of strong enforcement of the pasture standards at the last National Organic Standards Board (NOSB) meeting, real progress was made. The NOSB passed two Rule changes that will close the current loophole—requiring all cows to graze. However, it will take many months for that process to be completed.

The NOSB added language to the draft “guidance document” setting some minimum benchmarks in order to help USDA regulators and certifiers determine whether dairy farms are at least meeting some minimum requirements for the pasture. That document is now up for public input through May 20 and we again need to flood the NOSB with comments to let them know that yes, we do want to have minimum pasture benchmarks that are to be met by all organic dairy operations.

What Is an Organic Farm?

Complaints have been filed against several large CAFOs (concentrated animal feeding operations) that are producing “organic” milk from thousands of cows. It is alleged that these “factory farms” currently confine their cattle, affording them little or no access to pasture-even though that is required by the federal organic law/regulations. The “guidance document” will help rein in these factory farms-ranging in size from approximately 3000 to 6000 cows-basically confinement feedlots. These corporate farms and their wealthy investors are jeopardizing the livelihoods of organic family-scale dairy farmers throughout the United States, along with the more modest-sized companies and cooperatives that market their milk.

The guidance document (below), and the changes the NOSB made to the wording in the organic regulations, will require all organic dairy farms to comply with the law requiring cows to graze as a key component of their feed intake. Please send in your comments to help make sure this guidance document is enacted with the minimum pasture benchmarks intact.

Make Your Voice Heard

1. Please share this action alert with your circle of friends and colleagues.

2. Contact the USDA. A sample letter is here.

Mail letters to:

National Organic Standards Board c/o Arthur Neil
Room 4008-South Building
1400 and Independence Avenue-SW
Washington, DC, 20250-0001

Fax: 202-205-7808.

E-mail: [email protected]

USDA DRAFT: Guidance for interpretation of §205.239(a)(2)

A. Organic System Plan: Ruminant livestock shall graze pasture during the months of the year when pasture can provide edible forage. The Organic System Plan shall have the goal of providing grazed feed greater than 30% dry matter intake on a daily basis during the growing season but not less than 120 days. The Organic System Plan shall include a timeline showing how the producer will satisfy the goal to maximize the pasture component of total feed used in the farm system. For livestock operations with ruminant animals, the operation’s Organic System Plan shall describe: 1) the amount of pasture provided per animal; 2) the average amount of time that animals are grazed on a daily basis; 3) the portion of the total feed requirement that will be provided from pasture; 4) circumstances under which animals will be temporarily confined; and 5) the records that are maintained to demonstrate compliance with pasture requirements.

B. Temporary Confinement: Temporary confinement means the period of time when ruminant livestock are denied pasture. The length of temporary confinement will vary according to the conditions on which it is based (such as the duration of inclement weather) and instances of temporary confinement shall be the minimum time necessary. In no case shall temporary confinement be allowed as a continuous production system. All instances of temporary confinement shall be documented in the Organic System Plan and in records maintained by the operation.

Temporary confinement is allowed only in the following situations:

1) During periods of inclement weather such as severe weather occurring over a period of a few days during the grazing season;

2) Conditions under which the health, safety, or well being of an individual animal could be jeopardized, including to restore the health of an individual animal or to prevent the spread of disease from an infected animal to other animals;

3) To protect soil or water quality

C. Appropriate Pasture Conditions: Appropriate pasture conditions shall be determined in accordance with the regional Natural Resources Conservation Service Conservation Practice Standards for Prescribed Grazing (Code 528) for the number of animals in the Organic Systems Plan.

You Have the Power

Be assured, there are those working against having minimum pasture benchmarks and we must continue to actively work to secure the passage of this guidance document. By lending your support, you will be helping to ensure that the process to strengthen the pasture standards for organic livestock will continue forward.

Please join us! For more information contact:

P.O. Box 126
Cornucopia, Wisconsin 54827



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