| January 12, 2004:
In light of recent developments we are dedicating the first round
of the new year to resolving issues and quelling fears surrounding
mad cow disease.
1. I am
very concerned about the case of mad cow disease (BSE) recently
found in the United States. I’m thinking of feeding organic
beef to my family. Are there any differences between organic and
non-organic beef production?
There are significant differences between organic and non-organic
meat production. To begin with, there is an absolute ban on the
feeding of mammalian and poultry slaughter by-products to organic
mammals and poultry. This contrasts with non-organic regulations,
which still allow the feeding of cattle and other slaughter by-products
to cattle and other livestock.
The FDA banned the feeding of cattle brain and spinal tissue to
cattle in 1997, but they still allow the following materials to
be fed to non-organic cattle:
- Blood and blood products (from cattle and other species);
- Gelatin (rendered from the hooves of cattle and other species;
- Fats, oils, grease, and tallow (from cattle and other species);
- Poultry and poultry by-products;
- Rendered pork protein;
- Rendered horse protein;
- Poultry manure (which may include spilled feed containing rendered
animal products); and
- Human food wastes* (which may contain beef scraps).
None of the items listed above may be fed to organic cattle or
other organic livestock.
2. What
about milk replacer? I’ve heard that non-organic milk replacer
often contains cattle and hog blood. Is this allowed in organic
production?
It’s true that non-organic milk replacer commonly contains
spray dried blood plasma and blood serum from cattle and hogs. Research
in Europe has shown that BSE can be transmitted by blood, which
is why any U.S. citizen who has traveled to a country with BSE is
prohibited from donating blood.
Most organic calves are fed organic whole milk. Milk replacer may
only be used as an emergency supplement. If milk replacer is used,
the NOP regulation requires that the milk replacer contain no non-milk
products, no antibiotics, and no products from rBST treated animals.
3. I’ve
heard that the USDA is planning to implement a nationwide livestock
tracking system. What kind of records must be maintained for organic
cattle?
Traceability is a fundamental requirement for organic certification.
The National Organic Program regulation, in section 205.236.c, requires
that all organic livestock operations must maintain records “sufficient
to preserve the identity of all organically managed animals and
edible and non-edible animal products produced on the operation.”
Section 205.103 further requires that all organic operations, including
those with livestock, maintain records which “fully disclose
all activities and transactions” and “demonstrate compliance
with the Act and regulations.”
This means that records kept by organic livestock producers must
track all animals, including the source(s) of the animals; the sources
and quantities of feed; all medications; and all products produced
and sold. These records are reviewed at least annually by an inspector
representing a USDA-accredited certification agency.
4. What
about feed mills? Are there any requirements that prevent feed mills
from mixing organic feed with feed which may contain rendered animal
by-products?
Yes. In order to produce organic livestock feed, feed mills must
be inspected and certified. If they produce both organic and non-organic
feed, they must implement procedures, documented with written records,
to prevent the commingling of organic and non-organic feed. This
includes steps to clean storage bins and mixing and bagging equipment
prior to producing batches of organic feed. Organic feed mills also
must prevent the contamination of organic feed with antibiotics,
hormones, slaughter by-products, and insecticides which may be added
to non-organic rations. They must also ensure that rodenticides
and insecticides used in the facility do not contaminate organic
feed.
5. Are
organic animals slaughtered in special slaughterhouses?
Organic beef must be slaughtered in slaughterhouses which are certified
organic. As such, slaughterhouses must slaughter organic animals
when all equipment is clean and empty. There must be no chance of
commingling organic with non-organic meat, or contaminating organic
meat with prohibited materials. Records must be maintained of all
organic slaughter activities and steps taken to protect organic
integrity. If a plant can prove that it can segregate organic animals
and meat products and take all steps necessary to protect organic
integrity, then it can be certified. It does not have to be dedicated
to slaughtering only organic animals, however.
6. Have
there ever been any cases of organic cattle diagnosed with mad cow
disease?
There were several cases in Europe where cattle on organic farms
were diagnosed with the disease. Upon further investigation, it
was established that the cattle had not been born on the organic
farms. They had been purchased from non-organic farms, and converted
to organic production.
In the United States, organic cattle must be fed and managed organically
their entire lives in order to be slaughtered for organic beef.
In fact, a calf’s mother must be fed and managed organically
during the last third of the calf’s gestation in order for
the calf to be sold as organic slaughter stock. In the U.S., the
only animals which can be converted from non-organic to organic
production are dairy cattle, breeding stock, and animals which produce
non-edible products, such as wool. If such animals are converted
from non-organic to organic production, those animals can never
be slaughtered for organic meat.
* All items from the American Association of Feed Control Officials’
brochure “Reduce the threat of BSE” available at www.aafco.org
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