Organics in the News

The crucial question: What is pasture?
National Organic Standards Board will debate pasture guidance at its upcoming meeting in Washington, D.C.

By Jim Riddle

Action Alert What exactly do you mean by pasture? The Board is seeking comments on the proposed clarifications to the definition of pasture. In particular, it would like greater specificity on what constitutes “significant portion of the total feed,” and any species-specific guidelines that may be suitable for a program that is national in scope. Send comments to: Ms. Francine Torres, USDA-AMS-TMP-NOP, 1400 Independence Avenue, SW., Room 4008-So, AG Stop 0268, Washington, D.C. 20250-0200; or by fax to (202) 205-7808; or by e-mail to francine.torres@usda.go by close of business February 22, 2005. For more information, call (202) 720-3252.

February 10, 2005: In January, the USDA National Organic Program (NOP) asked the National Organic Standards Board (NOSB) to provide guidance concerning the pasture requirements of the National Organic Program regulations. The NOP has indicated that once adopted by the NOSB, the guidance document will be distributed to accredited certifying agents and posted on the NOP website.

At this stage, the NOSB Livestock Committee has met, drawn up its recommendations, and posted a draft for public comment at www.ams.usda.gov/nop. (Go to the NOSB page, then open the Meeting Book for the February meeting.) The Livestock Committee’s recommendations are based on the NOSB’s June 2000 and October 2001 pasture recommendations and the standards currently required under NOP regulations.

“Pasture” defined

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” (7 CFR 205.2).

Pasture for ruminants is required under the Livestock Health Care Practice Standard (7 CFR 205.238) and under Livestock Living Conditions (7 CFR 239). However, the Final Rule does allow for temporary confinement in certain circumstances, including certain stages of production. The committee’s recommendations provide additional guidance on the meaning of "temporary confinement" and "stage of production."

As stated in the October 2001 NOSB recommendation, requiring pasture for ruminants ensures that organic production systems: provide living conditions in which animals can satisfy their natural behavior patterns; emphasize preventative measures for animal health care; and answer consumer expectations of humane animal management.

Organic pasture management reflects a synthesis of crop and livestock production principles that works from the soil up to promote an interdependent community of plants and ruminants. Organically managed pasture should produce the quantity and quality of edible plants suitable to the species, stage of production, and number of animals. Access to pasture assures a relationship between the animal and land that satisfies both organic principles and international standards for organic livestock.

The Livestock Committee recommendations

In its draft guidelines released for public comment the NOSB Livestock Committee recommends the following:

1. Organic System Plan

Ruminant livestock shall graze pasture during the months of the year when pasture can provide edible forage. The grazed feed must provide a significant portion of the total feed requirements. The Organic System Plan shall include a timeline showing how the producer will work 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: a) the amount of pasture provided per animal; b) the average amount of time animals are grazed on a daily basis; c) the portion of the total feed requirement that will be provided from pasture; d) circumstances under which animals will be temporarily confined; and e) the records that are maintained to demonstrate compliance with pasture requirements.

2. 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:

• During periods of inclement weather, such as severe weather occurring over a period of a few days during the grazing season;
• 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;
• To protect soil or water quality; or
• During a stage of production:
  • For ruminants, a “stage of production” that warrants temporary confinement from pasture include: a) birthing; b) dairy animals up to 6 months of age and c) beef animals during the final finishing stage, not to exceed 120 days .
  • Lactation of dairy animals is not a stage of production under which animals may be denied pasture for grazing.

Submitting comments

The NOSB will consider the Livestock Committee's pasture draft when it meets February 28-March 3 in Washington, D.C.

The Board is seeking comments on the proposed clarifications to the definition of pasture. In particular, it would like greater specificity on what constitutes “significant portion of the total feed,” and any species-specific guidelines that may be suitable for a program that is national in scope.

To be most helpful, comments calling for specific maximum stocking rates or minimum average nutrients from pasture need to be national in scope and applicability. They also need to be backed by scientific data, such as might be found in Natural Resource Conservation Service (NRCS) practice standards or in ruminant livestock textbooks.

Comments on the draft, and other topics on the NOSB agenda, may be submitted to Ms. Francine Torres, USDA-AMS-TMP-NOP, 1400 Independence Avenue, SW., Room 4008-So, AG Stop 0268, Washington, D.C. 20250-0200; or by fax to (202) 205-7808; or by e-mail to francine.torres@usda.gov by close of business February 22, 2005. For more information, call (202) 720-3252.

Comments can also be made to the board in person at the NOSB February/March meeting at The Washington Terrace Hotel, 1515 Rhode Island Avenue, NW in Washington, D.C. Comment periods are scheduled for the mornings of March 1 and March 3. While not necessary, interested parties are encouraged to notify the NOP through Ms. Torres of their desire to speak. Torres can be reached at francine.torres@usda.gov. Each speaker will be given five minutes.

Jim Riddle serves as chair of the USDA’s National Organic Standards Board and organic policy advisor for NewFarm.org. He was the founding chair of the Independent Organic Inspectors Association (IOIA).