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Pasture Rule Training Highlights

By Lisa McCrory

Added March 9, 2010. On February 25, 2010, the NOP held its first of what will be four trainings on the new Pasture Rule. The first training was held in Lacrosse, Wisconsin, just a day before Moses’ Organic Farming Conference. There were around 60 people in attendance with the majority of them being accredited certifiers, inspectors and industry people. Though the first training was encouraging attendance from primarily certifiers and inspectors, the remaining Pasture Rule trainings are open to everyone.

Miles McEvoy, Deputy Administrator for the NOP, began the day addressing the purpose of the workshop and sharing the developments within the NOP. A chart that Miles showed illustrated the
noticeable increase in resources allocated to the NOP - especially over the past couple years, which has allowed them to significantly increase staffing.

Dr. Kerry Smith, a USDA employee on detail to NOP who has been intimately involved with the roll out of the final pasture rule, presented the Pasture Rule in all of its glory. There was time for
questions and feedback during the training and the Powerpoint as well as other resources should be posted on the NOP site soon. Most of what was covered was a step by step walk through of the new pasture rule including demonstrations of how to calculate Dry Matter Demand (DMD), and the Dry Matter Intake (DMI). Many of the resources on the NOP site are there for producers to use if they choose to. It is up to the producer to adequately demonstrate that they are in compliance with the new pasture rule and documenting the DMD of the livestock on the farm and the feed available to them (purchased, harvested mechanically and harvested by the livestock) should be indicated in the producer’s Organic System plan (OSP) and in their production records. This is all about creating auditable records with an on-site inspection determining if the plan is being met. Below are some key points discussed at the Pasture Rule Training:

  • Pasture is recognized as a crop. A realistic pasture plan must be included in the OSP, and should be updated annually. Pasture Records will complement the pasture plan to show what actually happened. If a Plan states 200 days on pasture, but the operation only has 180 days, the operator should document why there’s a difference. 205.406(a)(1)(ii) covers this.
  • The grazing season does not have to be a continuous 120 days, but a minimum of 120 days must be achieved.
  • Certifiers may chose to vary their annual inspections so that pastures may be evaluated at different times of the grazing season.
  • Producers should manage their herd’s subgroups (lactating cows, young stock, dry cows) to ensure that each distinct subgroup meets the minimum requirements of 30% DMI and 120 days.
  • Initial Dry Matter Intake (DMI) should be calculated at the beginning of the grazing season for each subgroup and type of animal. Calculations should be made whenever a change occurs to determine average DMI from pasture. At the end of the grazing season, the producer will calculate the average DMI consumed and the number of days achieved. (See page 16 of the NODPA News for an example calculation worksheet.)
  • Someone asked if a farm was at 28% DMI by the end of the grazing season, would it be a minor or major non-compliance. The response was that the 30% DMI is the absolute minimum. Farms should be aiming for higher than 30% DMI so that there is room in case they fall short of their goals. If a class of animal (ie heifers, dry cows, milkers) is below 30% DMI, then that group of animals will lose their certified organic status.
  • Organic dairies may ONLY buy feed from certified organic operations, NOT from exempt operations (those selling less than $5,000).
  • A clarification on agricultural products in additives and supplements was made: In the past, the rule was interpreted to require that all agricultural ingredients in additives and supplements, as well as in 205.603 listed items, needed to be organic. Now, the NOP is saying that if the agricultural ingredient is listed on the label of an additive or supplement, then it needs to be organic. If, for example, there is a carrier or a substrate (for yeast) that is agricultural but not listed on the label, that ingredient does not need to be organic. It is believed that this clarification was made to ensure that molasses used in supplements and additives was organic. Also, items on 205.603 are recognized to be allowed synthetics, therefore agricultural components are not required to be organic. This subject will most likely stimulate more discussion in the coming months.
  • There was also a clarification around outdoor access. A freestall yard with open side curtains does not count as outdoor access. The animals in that freestall need to have access to direct sunlight and the outdoors. Though this sounds like an obvious distinction to some, there have been discrepancies between certifiers winter, that there should be some nice days they can be in the barnyard or on the land.
  • Residual Forage is defined as forage that is cut and left laying in the field. Animals must harvest the residual forage in the pasture/hayland/cropland where it is lying to be included as part of the grazing plan.
  • If a producer is already certified, or if a producer gets certified between now and June 17, 2010, then they will have a full year to get into compliance. If a producer gets certified organic after June 17, 2010, then they need tobe in compliance right away.

The NOP will be conducting additional Access to Pasture Rule training sessions in New York, Colorado and California and these trainings are open to ALL (See Calendar for more details). NOP will post more information about these sessions as they become available. Pre-registration is required. To
pre-register, contact Judith Ragonesi, Training Manager, National Organic Program at judith.ragonesi2@ams.usda.gov. For training updates, go to: www.ams.usda.gov/AMSv1.0/nop and click on Pasture Rulemaking Information on the right hand side of the page. A special thanks to
Kelly Shea and Joyce Ford for their article contributions.