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A highlight of questions asked, the responses, and further ruminations on the NODPA-Odairy discussion list
By Lisa McCrory
Added April 2, 2010. I attended the second NOP Pasture Rule training, which took place on March 24th in Albany, NY. The presentation was thorough with time for questions/clarifications on pieces of the rule.
Miles McEvoy and Dr Kerry Smith said that they will be posting questions and the NOP response in their FAQ section on the NOP website (www.ams.usda.gov/AMSv1.0/organic).The Accredited Certifiers Association (ACA) was recording the workshop live to a network of others who were not able to be there in person. Dr. Kerry Smith's PowerPoint presentation has been posted on the NOP site and is also available on NODPA’s Pasture Rule page.
Reminder: there is a training in Colorado on April 7 and in California on April 26th. It is well worth the time attending one of these trainings; being there in person will give you the opportunity to network with others and to make sure your questions are answered or your concerns are heard.
Below is a summary of many of the questions asked at the training and the NOP’s response along with some further discussions/ruminations taken from the NODPA-Odairy discussion list.
Pasture Rule Questions:
1) If your grazing season is May 5th till November 5th (180 days), does that mean that your DMI needs to average 30% for the whole 180 days? For example, when transitioning cows onto pasture in the spring, or off pasture in the late fall, the cows may only be receiving 15% during those transition periods. If these low spots were averaged into the DMI it could pull a farm below 30%.
A: Indicate the date when that forage is available for a full pasture ration. NOP will expand upon this in FAQ’s. Producer should put a narrative in their OSP that explains the beginning as well as the ends (transition periods) documenting the first day that they turn their animal out, when they are 30% or more on pasture, and then when they start supplementing and when they are off pasture.
"§205.237(c) (1) Provide not more than an average of 70% of a ruminant's dry matter demand from dry matter fed... This shall be calculated as an average over the entire grazing season for each type and class of animal. Ruminants must be grazed throughout the entire grazing season for the geographical region, which shall not be less than 120 days per calendar year."
2) Could you address the average DMI calculations, and how you see an inspection schedule based on 1x per year visits to the farms gathering accurate, verifiable numbers? (i.e.: inspectors see only a once a year snap-shot of a farm’s grazing system, and cannot verify DMI at other points in the year).
A: Inspection should take place during the grazing season. Forms/records that farmers should provide would include any significant feed changes while cows are out on pasture.
3) Please talk about the NOP interpretation of outdoor access—frequency, logistics, and time to come into compliance. For example, some farms have limited numbers of safe, manageable areas to turn out cows in the winter. There are many tie barn operations in the Northeast that typically turn their cows out daily for what has been determined to be adequate amounts of time to move around, get fresh air, etc. Do you believe that turning out heifers for a few hours while cleaning their barn, followed by youngstock, etc. is acceptable? (Referenced the question that was asked during the 3/17/10 webinar where Dr. Kerry Smith said the scenario would not comply)
A: The producer must work with their certifier in determining if daily winter turn-out meets the standards.
4) For farmers grafting calves to nurse cows, how could we justify confinement for the grafting period? §205.239(b)(2) Stage of life?, (3) Health, safety, and wellbeing?, or (5) Preventative healthcare?
A: It would be considered health and safety/well-being of the animal.
5) How finicky should we get with DMD (Dry Matter Demand)? For example, do we provide an average number for each class (lactating dairy cows, lactating beef cows, bred heifers, dry dairy goats, etc.); OR, do we split it out by time of year/lactation (i.e.: early lactation small breed dairy cows, mid-lactation, late lactation, etc.)? In this case, how do you see a farmer coming up with a valid number for their OSP, considering the always changing composition of a dairy herd?
A: If there is a significant change in the group of animals requiring a change in the supplemental ration and/or percent of pasture dry matter fed, then that would ideally be noted in the grazing records. NOP will be creating tables for small ruminants and additional data forms and tables should be fitting continuous pasture and rangeland management. NRC requirements for small ruminant animals will be posted soon on the NOP site.
6) If someone has land/fields certified and is adding a dairy after the announcement (February 12, 2010 and before June 17, 2010, do they have to comply in full right now? What if someone is adding heifers to their certification in the same time period?
A: The farm would have to be in full compliance right now if adding dairy or heifers in the situation described.
7) Is is okay if non-organic animals are raised on the organic pastureland in a rotation with the certified organic animals?
A: Manure deposited on the pasture does not have to be organic manure, so it is not an issue if non-organic and organic livestock are on the pasture together. Just maintain records of how you are meeting the needs of the organic stock.
8) Feed additives and Supplements: Agricultural ingredients in supplements and feed additives must be organic: What level of labels are we talking about? For the farmer, or for the processor? There are different labels out there depending upon where the product is in the production chain.
A: Use those labels that are readily available to the producer.
9) Situations where producers are leaving their cows in during the day during hot summer months and then grazing them at night, meeting the 30% DMI needs. Would this be allowed?
A: This is up to the discretion of the certifier. Producer must provide justification for how they are meeting the 30% DM from pasture and how their management fits within the standard.
Posted: to Organic Production on Fri, Apr 2, 2010
Updated: Fri, Apr 2, 2010