April
20, 2004:
Introduction
– The National Organic Program
Final Rule requires organic livestock producers to implement
numerous proactive management practices, including a prohibition
on the feeding of mammalian or poultry slaughter by-products
to mammals or poultry. In order to minimize the risk of organic
livestock being fed slaughter by-products, some changes should
be made to the NOP regulation and how it is implemented.
Background
– A review of the NOP regulation reveals
that numerous requirements effectively minimize the risk that
organic livestock, and livestock producing organic products,
are not fed slaughter by-products. These regulatory requirements
include:
a) Under the NOP, organic livestock must be fed and managed
organically their entire lives in order to be slaughtered
for organic meat. In fact, an animal’s mother must
be fed and managed organically during the last third of
the animal’s gestation in order for the animal to
be sold as organic slaughter stock.
b) There is an absolute ban on the feeding of mammalian
and poultry slaughter by-products to organic mammals and
poultry.
c) 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 (such as
blood), no antibiotics, and no products from rBST treated
animals.
d) Traceability is a fundamental requirement for organic
certification. The NOP 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.
e) 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.
f) Organic livestock 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.
A closer analysis of the regulation reveals the following
pathways whereby slaughter by-products, or animals fed slaughter
by-products, could enter organic livestock production systems:
1) 205.236(a)(2) allows conventional dairy cows
to be converted to organic production, either using the
"one year" or "80/20" method of conversion.
This allowance means that animals that previously consumed
slaughter by-products could be found on organic dairy farms.
Such animals could never be slaughtered for organic meat,
but they could produce organic milk and organic calves.
2) The current interpretation of CFR205.236 (a)(2)(iii)
provides for two paths in which non-organic livestock may
enter certified organic dairy operations. One method allows
organic dairy operations to employ a one-year conversion.
This method of conversion has been interpreted to allow
dairy operations to continually introduce non-organic replacement
animals, provided that the animals are fed and managed organically
for one year prior to producing organic milk. The second
method, known as “80/20”, requires an operation
to use replacement animals which have been fed and managed
organically from the last third of gestation.
Organic dairy operations that continually introduce non-organic
animals into a herd may pose a risk of having animals in
an organic herd that were previously fed slaughter by-products.
In contrast, farms that manage all animals organically from
the last third of gestation may reduce this risk.
3) 205.236(a)(3) allows breeder stock
from nonorganic operations to be used to produce organic
offspring, provided that the breeder stock are "brought
onto the [organic] facility no later than the last third
of gestation." Breeder stock, sourced from nonorganic
farms, could have been previously fed slaughter by-products.
While it may not be practical to prohibit nonorganic breeder
stock from producing organic offspring, the NOP should clarify
that, once breeder stock have been converted to organic
production, they cannot be managed non-organically and continue
to produce organic offspring.
4) While 205.237(b)(4) prohibits the feeding of
manure (e.g. poultry litter which may contain spilled
feed with slaughter by-products) and 205.237(b)(5) prohibits
feeding "mammalian or poultry by-products to mammals
or poultry", there is no linkage to 205.604, which
is the list of non-synthetic substances prohibited in organic
livestock production. The only item listed in 205.604 is
strychnine. To clarify the prohibition of feeding manure
and slaughter by-products, the NOSB and NOP should amend
205.604 to show specific "non-synthetic" feed
ingredients and additives items which are prohibited. Such
action would be similar to the prohibition of arsenic in
both the crops section at 205.206(f) and on the National
List at 205.602(b).
5) There is confusion if the prohibition in 205.237(b)(5)
is limited to "slaughter by-products."
Taken literally, someone could feed slaughter products to
organic animals. There is no definition of "slaughter
by-products". The NOP should issue clarification stating
that the prohibition of slaughter by-products includes all
slaughter products, not just waste materials.
6) The NOSB has recommended that ingredients and
processing aids allowed by 205.605 and 205.606
for human consumption also be allowed in livestock feeds.
If enacted, this could allow gelatin and anima- derived
enzymes (and possibly other animal products) to be used
in livestock feed. If this recommendation of the NOSB is
enacted, the NOP should specifically exclude animal derivatives
for use in livestock feed by placing them on 205.604 as
prohibited for use in organic livestock production.
7) Likewise, the NOSB has recommended that feed additives
allowed by the Association of American Feed Control Officials
(AAFCO) be allowed under 205.603(d). AAFCO allows numerous
animal slaughter by-products to be used as feed additives.
If the prior recommendation of the NOSB is enacted, the
NOP should specifically prohibit AAFCO-allowed feed additives
which contain animal derivatives by placing them on 205.604
as prohibited for use in organic livestock production.
Recommendation
– In order to further minimize the risk
of slaughter by-products and animals which have consumed slaughter
by-products from being used on organic livestock operations,
the following actions should be implemented:
1) The NOP should change the regulation or reverse its
"two track" interpretation and require all dairies,
once they have converted to organic production, to use replacement
animals which have been fed and managed organically from
the last third of gestation.
2) The NOP should clarify that, once breeder stock have
been converted to organic production, they cannot be managed
non-organically and continue to produce organic offspring.
3) The NOSB and NOP should amend 205.604 to indicate exactly
which "non-synthetic" feed ingredients and additives
are prohibited.
4) The NOP should issue clarification stating that the
prohibition of slaughter by-products include all slaughter
products, not just waste materials.
5) If items on 205.605 and 205.606 are allowed for use
in organic livestock production, the NOP should specifically
prohibit animal derivatives by placing them on 205.604 as
prohibited for use in organic livestock production.
6) The NOP should specifically prohibit AAFCO-allowed feed
additives which contain animal derivatives by placing them
on 205.604 as prohibited for use in organic livestock production.
Jim Riddle serves as vice-chair of the National Organic
Standards Board, which advises the USDA on organic agriculture
policies and regulations. |
