Organic Dairy Scorecard Criteria

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Organic Dairy Scorecard Criteria

Transparency and Disclosure
Milk Supply and Ownership Structure
Commitment to Organic Label
Pasture Management
Grass-Fed Percentage
Supplemental Feed and Ingredients
Calves
Times Milked Per Day
Deaths & Culls
Environmental Impacts and Stewardship
Animal Welfare
Organic Certifier (Informational)
Add On Labels (Informational)
Herd Size(s) (Informational)
Extra Credit
Adjustments & Notes

Transparency and Disclosure

Most brands that voluntarily participated in this survey received a high score for transparency and disclosure. Cornucopia deducted some points for leaving questions blank, for omitting information, or for declining an on-farm site visit. Brands that do not participate in our survey can receive some points in this section if they are fully transparent with a trusted third-party reviewer or if reasonably reliable information is found by our investigators.

Milk Supply and Ownership Structure

Cornucopia considered each brand’s ownership structure and history, which is one measure of the validity of marketing claims. Farmers or ranchers who live on their farmsteads and sell directly to consumers will have more control over supply than corporate buyers coordinating purchasing from dozens or hundreds of individual farms. Some brands, including private label brands marketed by grocery stores, blindly accept the claims of their dairy suppliers or finished products. Brands that buy their milk on the wholesale market (or are suspected to, without confirmation) will score the lowest.

Commitment to Organic Label

Brands are scored for their dedication to organic production. Independent organic brands that sell only certified organic products, or source from contracted farms that produce only certified organic products, are typically more dedicated to the organic label.

Brands that source conventional and organic dairy from the same property (physical location) are known as “split operations.” Split production is considered “higher risk” because these operations are more likely to be caught in fraud or mislabeling products.

Pasture Management

Pasture management scoring accounts for how the outdoor areas are managed. This rubric considers any areas where the cattle graze fresh forage and whether that pasture is managed to prevent environmental harm.

Quality of grazing depends heavily on the location and quality of pasture available to an individual brand. For those brands that get their fluid milk from multiple suppliers, their largest suppliers will be accounted for in this scoring mechanism.

In general, the brands that rate the highest have superb pasture management that directly improves soil quality, far exceeding minimum organic requirements which require pasture to be managed as any other organic crop (without synthetic pesticides and fertilizers, or sewage sludge).

This score is based on the following criteria:

1. Policies for using and protecting pasture above and beyond USDA regulations, including those that reflect forage management, reseeding, mowing, harvesting for hay, etc.
2. Enforcement/oversight of suppliers by the brand (versus certification bodies)
3. Amount of acreage available per head (stocking density) on the brand’s largest farms and whether that is appropriate for the climate and management based on soil quality
4. Any known impacts on water quality and water use, such as irrigation
5. Any impacts on natural resources other than water, including soil, wildlife, native species, etc.
6. Direct impacts on the pasture in question (i.e., evidence of overgrazing or poor management), and
7. Permissible exemptions

Grass-Fed Percentage

The grass-fed percentage criteria reflects cattle diet. The organic standards require that certified organic dairy cattle get a specified minimum amount of their diet from fresh pasture. The requirement is 30% “Dry Matter Intake” (DMI) and above during the minimum 120-day grazing season. (Learn more about DMI and how it’s calculated on eOrganic https://eorganic.org/node/5368). A dairy that does not meet these standards would be in violation of the organic standards and should be issued a noncompliance (with some exceptions).

To differentiate organic dairy products, Cornucopia assigns higher points to brands that exceed 30% DMI and/or that provide a grazing season longer than the minimum 120 days. Cornucopia tracks multiple “100% grass-fed” third-party labels in addition to the organic requirements. We view these as additional confirmation of a brand’s practices when they source from multiple suppliers. Cornucopia does not allot extra credit for third-party “grass-fed” labels. The most common grass-fed labels found on organic dairy products include:

• American Grassfed Association
• Certified Grassfed by A Greener World Note that this label is an optional addition to AGW’s Certified Animal Welfare Approved standards for beef and dairy cattle, meat and dairy sheep, and meat and dairy goat and bison. These standards do not stand alone and cannot be applied in isolation.
• Organic Plus Trust Grass-fed Organic Livestock Certification A grass-fed label specifically administered by organic certifiers including CCOF, OEFFA, and PCO at the same time as organic inspection.
• Regenerative Organic Certified Administered by the Regenerative Organic Alliance, this label requires cattle diets to include more than 50% grass (with the remainder from organic sources) to reach the bronze level, more than 75% grass to reach silver (with the remainder from organic sources), and 100% grass — including finishing — to attain gold.

Supplemental Feed and Ingredients

This scoring category focuses on the sourcing of cattle feed and supplements, apart from fresh pasture, and the sourcing of any added milk products not derived from brand suppliers. Cattle feed covered in this rubric includes grains, legumes, hay, and silage.

Brands may also purchase additional organic dairy components from other operations to add to their products. For example, a brand may buy a small amount of organic cream from another supplier to add to their organic ice cream. This scoring rubric also takes into account the sourcing for added ingredients.

Highest points are allotted to brands that produce all feed on-farm, and the lowest points are given to brands that source their feed from questionable sources. Animal feed can have a significant impact on organic integrity, of particular concern when that feed arrives at US ports by the shipload from countries with high risk of organic fraud.

Calves

Most US dairy calves are raised in individual hutches for biocontainment purposes and to help facilitate monitoring and handling. However, individual hutches typically restrict calves’ activity and social interactions. Studies show that group housing is beneficial to calf welfare and is associated with social benefits.

While the organic standards allow operations to remove calves from their mothers soon after birth, housing calves in individual housing, some dairies keep calves with their mothers for a period of time. These brands may receive extra points (more than 100) for this practice, as well as for other practices that contribute to higher welfare for calves.

Times Milked Per Day

It is standard practice for community-scale and organic dairies to milk their cows once or twice a day.

Dairies that milk three and four times a day are pushing their cows hard to maximize production. This production model requires feeding higher levels of grain and other feed concentrates, and it impacts how long cows spend time outside, grazing pasture. When pushed for high production, dairy animals typically live short, stressed, and unhealthy lives.

Deaths & Culls

Although it is not common to see older cows in dairy production, healthy and productive cows can and do live beyond ten years of age.

“Culling” refers to the removal of a live cow from the herd, often for reasons such as poor production or health issues, distinct from the death of an animal from natural causes or euthanasia. Both events occur in dairy farming but have different implications for herd management.

A dairy operation’s cull rate is one measure of how well the dairy is performing. “Voluntary culling” can be a good thing, when it means selling cows that might not be a good match for a particular farm (for example, poor condition on a grass-based diet, bad temperament, or undesirable milk quality). Culling is also used to select for specific traits that will make a herd better suited to the local climate or specific farm. “Involuntary culling” occurs when there ispoor animal health or mismanagement (for example, reproductive failure, mastitis and udder health problems, poor feet and legs, injury, disease, and death).

In intensive factory farm dairies, a cow’s life is truncated by the stress of a high-grain diet and intensive milk production. These animals typically only live to 4 to 5 years old before they are culled (and usually sent to auction or slaughter). This kind of practice is standard on conventional dairies but much rarer in organic dairy — even less likely after animal welfare regulations were included in the Organic Livestock and Poultry Standards rulemaking.

For this rating, Cornucopia took into account planned downsizing and other mitigating factors, including healthcare concerns out of producer control.

Environmental Impacts and Stewardship

This scoring category examines the environmental impact of supplier farms as well as environmental practices adopted by the brand and/or its suppliers. (All certified organic dairy farms are required to grow or buy animal feed raised without synthetic fertilizers or pesticides.

This scoring section summarizes the brands’ overall environmental impact when compared to other organic brands. From an environmental lens, organic production outperforms the industrialized conventional production that accounts for the majority of US dairy.

Brands with high quality environmental stewardship carefully handle their manure and thoughtfully maintain natural resources. Maintaining vegetation, avoiding “moonscape” (torn up ground), and protecting waterways is especially important to protect the local environment, water, and soil health.

Brands that regularly perform soil and water testing, promote biodiversity, support ecosystem services, and see their cattle as part of the on-farm nutrient cycle receive the highest points.

Among the aspects considered in this score are:

A) Manure handling and control (with practices including sustainable composting and re-use methods rating highest);

B) Soil, water, and air quality testing (where applicable);

C) Impact on local and global ecosystem services;

D) Impacts to both groundwater and surface waters (such as rivers and streams);

E) Impacts on wildlife and native species (including plant species); and

F) Any other site-specific practices that may impact the environment.

Animal Welfare

This scoring section considers several animal welfare aspects, summarizing the brand’s overall animal welfare impact when compared to other organic brands. Most organic producers provide better welfare than the most common (and dominant) conventional production. Among the aspects considered in this score are:

A) Legitimacy of outdoor access and time on pasture;

B) Known indications of cattle comfort, safety, and ability to perform natural and instinctive behavior including socialization;

C) Overall healthcare indicators like rates of foot problems, mastitis, etc.;

D) Housing factors, like the ability to freely move, stretch, turn around, and lay down along with play (especially when younger);

E) Preventative healthcare factors;

F) Whether the brand has been known to withhold treatment with prohibited substances, including antibiotics, when there is a welfare concern. Organic livestock producers must not withhold medical treatment from a sick animal in an effort to preserve its organic status (7 CFR 205.238(c)(7);

G) Stress behaviors, body condition scoring, and other physical and behavioral factors that indicate a certain level (or lack thereof) of animal welfare.

Organic Certifier (Informational)

This non-scoring section is provided for information only. All accredited organic certifiers can be found on the NOP website.

Add On Labels (Informational)

Some dairy brands opt to add other certifications on top of organic certification. While an additional label can demonstrate commitment to certain standards, some add-on labels contribute to the “greenwashing” and “humane-washing” we see in the organic milk marketplace.

Third-party add-on labels are listed for consumer information and not scored at this time, though a scoring mechanism may be added later.

The more robust add-on labels get extra points which can be found in the “extra credit” section of the scoring. For example, brands with the Animal Welfare Approved (AWA) label get 50 points of extra credit.

Herd Size(s) (Informational)

Herd size considers how many adult animals – in this case we are specifically interested in the active milking herd – are found on one distinct parcel of property. Typically, this number will be somewhat in flux as milking cows are moved in and out of production for various reasons.

The general denotation for herd sizes: large, medium, and small are based on the legal definitions of “Concentrated Animal Feeding Operation.” The definition of AFO/CAFO is also applicable for this size category.

Extra Credit

The reasoning behind any extra credit will be detailed in the notes. Common assignments for extra credit are as follows:

Environmental Bonuses

Gold Standard Add-on Labels

The more robust add-on labels get “extra credit” points

Animal Welfare Bonuses

Adjustments & Notes

Any notes relating to how this brand is being scored outside the existing scoring rubric will be listed here. Brands that receive penalties based on Cornucopia’s Scorecard Adjustment Policy will be noted here.