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Transition to Certified Organic Milk Production

Last Updated: April 04, 2011

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eOrganic author:

Lisa McCrory, Earthwise Farm and Forest

Before You Transition: Make a Plan

The following guidelines are based on the National Organic Program (NOP) final rule (United States Department of Agriculture [USDA], 2000). Farmers planning to make the transition to organic dairy production should consider all of the following areas, as well as the time and investment that will be required for compliance with certification requirements.

A farmer interested in making a transition to organic production should create a transition plan which includes a timeline from the day that organic practices have been implemented to the day that the farm will ship organic milk. This process takes a minimum of one year and can take up to three years, depending on your farm, current farming practices, and when the last prohibited substance was applied. Fields can be transitioned to organic on a field-by-field basis with each field required to be free of nonapproved inputs for 36 months before the first organic harvest. Your cows will be transitioned as an entire distinct herd and will go through a one-year transition to organic.

Before you begin your organic transition, find a market for your organic milk and decide on your organic certification agency. Your certifier will be able to refer you to Organic System Plan templates and record-keeping forms that you can use to document your transition to organic production, as well as for each year following. You will be required to supply a year's worth of production documentation for your livestock and three years worth of production information for your land when you first apply, and annual documentation when you reapply for certification each year.

You will want to choose your organic certification agency early to make sure you follow instructions for certification generated by the agency that will certify your operation. If you have questions about the requirements or about the status of a particular input, contact the certifier. All accredited certifiers are required to provide sufficient information to persons seeking certification to enable them to understand and comply with the requirements. Since there are regional differences in available inputs, climatic conditions, agronomic practices, and so forth, it is always a good idea to work with a certifier who is knowledgeable about the conditions, practices, and inputs used in your region.

Shippers or processors that buy organic milk may have contract or production requirements in addition to the NOP final rule. Be sure to learn what their requirements are before deciding who will be your organic milk buyer and going through the USDA organic certification process.

Dairy Herd Transition Guidelines

There is a once-per-farm, whole-herd transition provision for all dairy herds converting to organic production. During this 12-month transition, all animals—including existing youngstock and calves born during this time—must be managed according to NOP requirements, including compliant feed, pasture, feed supplements, housing, and health management practices. Once the transition starts, you are not allowed to purchase or add nonorganic stock during that year, since these animals would not then have the full one-year transition time along with the existing herd. If you want to add production animals to your dairy operation, you must either raise your own replacements, or purchase them from other certified organic farms. Once you have completed your year of transition and have a certified organic dairy herd, all organic dairy replacement animals must be managed organically from the last third of gestation (three months prior to birth).

Livestock Feed

For the 12 months prior to selling organic milk, feed for all production animals on the farm (milk cows, dry cows, heifers, and heifer calves) must be 100% organic, or harvested from your land that was between 24 and 36 months from the last application of a prohibited substance—in other words, in its third year of transition to organic. The 100% organic feed ration includes forages and grains as well as any agricultural products, such as oat bran, that are used as carriers or bulking agents in feed supplements. The provision for feeding farm-raised, third-year transitional feed is only allowed for herds in the transition to organic. Once you are shipping organic milk, feed from transitional land cannot be fed to any current or future organic production animals. Time your transition to have your silos, bins, and hay storage empty of transitioned crops, and full of certified organic crops when you are ready to be on the organic milk route.

All purchased grains and forages must be certified organic. "In-transition" organic feed (managed organically for 24-36 months) cannot be purchased from other farmers and fed to a dairy herd during transition. You must keep all receipts and organic certificates as documentation of your organic feed purchases, making sure that the receipts provide the seller’s name, transaction date, a copy of the seller’s certificate of organic status, and the amount of feed purchased.

All feed supplements, including minerals and salt, must be approved for use by your certifier. Antibiotics, GMO-derived products, animal by-products, artificial colors/flavors, synthetic flowing agents, and synthetic preservatives are not permitted in any feed products. If a supplement contains soy oil, wheat middlings, or molasses, for instance, these are agricultural products and must be certified organic. Please ask your certifier for a list of approved products and suppliers in your area who serve organic farmers with approved feeds and supplements.

Calves should be fed organic whole milk and organic feed. As of April 2006, the National Organic Standards Board voted to remove nonorganic milk replacer from the National List, meaning it is no longer allowed for use under any circumstances.

Pasture is mandated for all ruminants. The NOP final rule defines "pasture" as "land used for livestock grazing that is managed to provide feed value and maintain or improve soil, water, and vegetative resources" (USDA, 2000).

All animals, once they have functioning rumens (usually by six months of age), must have daily access to pasture during the grazing season. Although specific guidelines are not given as to the number of acres of pasture per cow to be provided, the animals must be able to obtain a significant portion of their daily feed intake from pasture during the grazing season. Green chop or dry hay fed to cows is not considered "pasture." A dry lot is not considered "pasture" since there is no forage on the ground that offers feed value.

Pastures must be managed in a way that prevents erosion and/or water quality problems. In addition, access to streams and rivers must be restricted and/or managed in order to prevent these problems.

Livestock Living Conditions

Housing must allow for freedom of movement and good ventilation to accommodate the health and natural behavior of animals including the following.

  1. Daily access to the outdoors, shade, shelter, exercise areas, fresh air and direct sunlight
  2. Appropriate clean dry bedding; if the bedding is typically consumed by animals, it must comply with the feed requirements and be certified organic
  3. Access to pasture; all ruminants must be on pasture during the grazing season
  4. Treated lumber is not allowed where it may be in contact with the animals or their feed once a farm is certified organic (to learn more about alternatives, please see ATTRA's publication, Organic Alternatives to Treated Lumber)

An organic livestock producer may provide temporary confinement for an animal because of inclement weather, the animal's stage of production, conditions under which the health and safety of the animal could be jeopardized, or if there is a risk to soil or water quality. While animals can be confined during extremely cold or hot periods, the entire winter season, for example, cannot be considered inclement weather as a reason for keeping animals confined.

Livestock Health Care Products

Animal health is the result of ongoing management efforts to create living soils, provide nourishing forage and feeds, provide clean drinking water, and improve the quality of livestock life. Compassionate awareness of every animal may give rise to the need for a health care treatment. Producers must keep written records of all health treatments administered, both by the producer and by a veterinarian, as well as health issues with their herd.

It is prohibited for a producer to withhold treatment to maintain organic status of an animal. If an animal is treated with a prohibited product, the milk and meat from that animal can no longer qualify as organic and the animal must be sold as nonorganic or tracked and managed as nonorganic. If the animal is sold, a receipt must be kept as proof of sale.

Dairy farmers must follow organic health care requirements during their one-year transition prior to shipping organic milk. This means that all health care products with synthetic ingredients are prohibited for use, unless they are specifically included on the National List of synthetic materials allowed for use in organic livestock production.

  • Verify with your certification agency that all health products used or planned for use on your farm are acceptable, prior to use.
  • Dehorning and castration should be performed at a time and in such a manner as to provide the least amount of stress to the animal.
  • Tail-docking is not allowed, unless there is a health problem that cannot be cured, such as a wound which does not heal.
  • All non-GMO vaccines and veterinary biologics are allowed.
  • Use of parasiticides (dewormers) are allowed only in health care emergencies and in the case of acute- and dangerously high levels of infestation. There is a 90-day withholding period for dairy cows. Currently, the only synthetic parasiticide allowed for use on organic farms is Ivermectin. Synthetic parasiticides may not be used on animals intended to be sold as organic meat.
  • Artificial insemination is allowed; however, breeding hormones are not allowed.
  • Bulls do not need to be managed organically unless they are to be sold as organic slaughter animals.

Animal Identification and Inventory

All animals on the farm at the start of transition should be listed on an animal inventory sheet. This list should be updated at least each year to include livestock purchases, births, deaths, and livestock leaving the farm. Individual animals must be identified by ear tags, neck chains, tattoos, drawings, or photographs.

If you plan to sell cull cows, young stock, or steers as organic meat, all slaughter animals must have been organic from the last third of gestation, meaning the mother cow had to have been on the certified operation, fed and managed organically, for the last three months before the slaughter animal was born. If you are feeding third-year transitional feed to your herd, the young stock born during that year would not be eligible for organic meat sales. Dairy animals that were transitioned to organic can never be sold as organic meat, but they can give birth to organic meat animals and produce organic milk. Dairy animals that were given parasiticides can never be sold for organic meat.

Field Practices

Fields, including pastures, qualify as organic if at least three years have passed since the last application of a prohibited pesticide, herbicide, synthetic fertilizer, or any planting of fungicide-treated seeds or GMO crops. If some of your fields qualify as organic, but others have had recent applications of prohibited products, your farm may still be able to get certified.

The feed from fields that have yet to complete their three-year transition would be considered nonorganic transitional feed. First- and second-year transitional feed can be sold on the conventional market or fed to nonorganic livestock on your farm, such as bull calves to be sold for nonorganic meat, or horses. Records documenting the sale or use of transitional and other nonorganic crops must be maintained. Third-year transitional feed can be fed ONLY during the one-year whole herd transition year. Transitional feed cannot be used as bedding, unless it is 3rd year transitional feed used during the one year whole herd transition.

If your farm has been purchasing feed from a neighboring farm and will continue to do so, that land needs to be certified. You can include the neighbor's land under your certification, or the neighbor can get the land certified under their name. If the land is included in your farm application, crops from those fields can only be used or sold by you.

If you rent or purchase new land, you should get a written statement from the previous owner or operator, stating the date when the last prohibited substance was applied, and the name of the substance used. If the land has not had prohibited materials applied during the past 36 months, and you obtain sufficient documentation, newly rented or purchased land can be used for organic pasture or feed production without going through an additional three-year transition.

Buffer Requirements

If an adjoining farm, golf course, development, or other land user applies prohibited substances to their land, an adequate barrier/distance between the certified crops and the neighboring land needs to be in place. The buffer needs to be sufficient to prevent prohibited substances from contacting the organic crops. Your certifier will discuss with you the distance needed for your buffer zones, depending on the risk of contamination, taking into consideration physical barriers, slope, prevailing winds, substances used by the neighbor, and methods of application. If buffer zones are needed, crops grown in those areas cannot be used for organic feed or sold as organic. Such crops can be fed to nonorganic livestock or sold to conventional markets.

Soil Fertility

The NOP regulation states, "A producer must select and implement tillage and cultivation practices that maintain or improve the physical, chemical, and biological condition of the soil and minimize soil erosion" (USDA, 2000; 7 CFR 205.203(a)).

Fertility should be managed through soil-building crop rotations, cover crops, manure, compost, plant residues, and the application of approved soil amendments. Approved soil amendments include nonsynthetic minerals such as rock phosphate, lime, Sul-Po-Mag, and so forth, that do not contain synthetic additives. If you are not certain that a material is allowed, contact your certifier before buying or applying it. Use of a prohibited material will disqualify that field from organic production for three years.

Seeds

Producers of organic crops are required to use certified organic seed if it is commercially available. Commercial availability means that the seed is available in the appropriate variety, quality, or quantity the producer needs; cost is not a factor. Conventional untreated seed may be used if organic seeds are documented as not being commercially available; they must not be treated with synthetic fungicides/insecticides, or be genetically modified, nor can they have a GMO nitrogen-fixing bacterial inoculant.

Crops grown from treated seeds cannot be sold as organic and the use of treated seeds disqualifies the field from organic production for three years. Seed treatments, such as non-GMO legume inoculants and natural clay-based pelletizing materials, can be used, provided they are approved for organic use. Contact your certifier to get a list of organically-approved inoculants and natural seed treatments.

Washing and Cleaning Protocol for Equipment Previously Used in Conventional Production

Used equipment—sprayers, fertilizer spreaders, and so forth—must be cleaned so that organic crops will not be contaminated with prohibited substances. It is recommended that organic farmers using equipment previously used for conventional production replace all plastic and rubber hoses and tips. All tanks, valves and metal parts should be washed with detergent and triple rinsed. Cleaning procedures should take into account whether substances used are oil- or water-based.

Grain combines, hay balers, and forage harvesting equipment, as well as elevators, augers and storage units, must be clean and empty prior to organic use. Open all traps and run the equipment. Sweep and vacuum all areas that can be accessed. If difficult to clean, some pieces of equipment need to be "purged" with the first organic crops harvested, in order to push any remaining nonorganic crops through the system. The purged crops cannot be used for organic feed or sold as organic.

Milk Handling and Sanitation

All types of milking systems are allowed—hand, bucket, stanchions, and parlors. In order to be certified organic, steps must be taken to prevent detergents, acids, and sanitizers from coming in contact with the milk. The system should be clean prior to milking. Some producers rinse their systems with water immediately at start up. Others purge the system with milk, "dumping" the first milk through the pipeline to insure that any remaining residues don't get into the bulk tank. Most detergents, acid rinses, and sanitizers are allowed, so long as steps are taken to prevent contamination of the organic milk. If in doubt about the products you use, check with your certifying agent. Likewise, check with your certifier to make sure that any udder washes, udder balms, and pre- and post teat dips that you use or intend to use are allowed.

Manure Management

Organic livestock operations 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 that optimizes the recycling of nutrients. This means that manure runoff must be prevented, and that manure must be properly stored, prior to application. Manure should be applied at agronomic rates, and over-application must be avoided. If manure is brought onto the farm from a nonorganic source, it cannot have had nonapproved synthetic additives added to the manure pits or piles. The nonorganic animals could have been fed or bedded with nonorganic crops, however.

Acknowledgements

The author thanks Harriet Behar and staff at Midwest Organic and Sustainable Education Service (MOSES), Nicole Dehne and staff at Vermont Organic Farmers, LLC (VOF), and Jim Riddle at University of Minnesota, for their contributions to and review of this article.

References and Citations

 

This is an eOrganic article and was reviewed for compliance with National Organic Program regulations by members of the eOrganic community. Always check with your organic certification agency before adopting new practices or using new materials. For more information, refer to eOrganic's articles on organic certification.

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