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Certified Grass-Fed Organic Dairy
Maple Hill and CROPP Cooperative launched their new third-party certified grass-fed organic dairy standard on February 21, 2019. According to a CROPP Cooperative press release, “the inaugural products including the Certified Grass-Fed Organic Livestock Program official seal [was announced] at Natural Products Expo West March 5-9 in Anaheim, CA.” The press release goes on to say that this new standard was created to establish a national organic grass-fed organic dairy standard that is beyond reproach, a standard that instills consumer confidence regarding what is behind the label, and builds on the existing NOP standards and enforcement infrastructure.
Both CROPP Cooperative and Maple Hill claim that the new standard will bring much-needed consistency and transparency to grass-fed organic dairy standards for farmers, processors, manufacturers, certification bodies, retailers and consumers. While both companies have had some success with marketing organic dairy products that are identified as coming from grass-fed cows, their self-certification process is not particularly transparent. It has contributed to consumer confusion, as they face dozens of private standards or labels, with varying degrees of transparency and traceability. Both CROPP Cooperative and Maple Hill have seen a decline in the growth of sales in the last year with Maple Hill cancelling some farmer contracts for their grass-fed program and estimates of utilization of grass-fed milk in grass-fed branded product at only 80%. The new certification is expected to boost consumer confidence in the grass-fed brands and increase sales. According to Rachel Prickett, director of certification for EarthClaims, which is managing the new program, and William J. Friedman, an organic industry lawyer and CEO of EarthClaims, Maple Hill Creamery and CROPP Cooperative “came together as a team of interested parties seeing the need for an additional certification on top of NOP organic standards due to consumer demand for such a claim, and demands from the dairy industry to improve animal welfare and meet consumer demands. Organic Valley and Maple Hill Creamery wanted to build off the USDA NOP standard as a baseline.”
This new label, officially “Certified Grass-Fed Organic Dairy,” is a privately developed, publicly available standard housed with Organic Plus Trust (OPT), a public benefit corporation that was created by EarthClaims, LLC, a global farm and food certifier. Its first program partners are the following brands: Organic Valley, Maple Hill and Natural By Nature. OPT’s sole purpose is to house the standard, and has delegated program manager duties for the standard to EarthClaims. Funding for the OPT’s work is expected to be primarily derived from small administrative fees and a licensing program for the use of its Licensed Trademarks. This new grass-fed organic dairy standard is open to all organic certifiers and certified organic farmers.
This new standard builds on expanding awareness and valuation of the health, animal welfare and conservation benefits of grass-fed dairy and meat production. There have been several previous efforts to establish verifiable standards for grass-fed livestock production in the U.S. In 2007, the USDA’s Agricultural Marketing Service released standards for a grass-fed claim on meat (organic and conventional) that many observers agreed was not perfect, but nonetheless represented a step in the right direction. However, in January, 2016, the USDA withdrew the grass-fed standard, citing a lack of authority to define the claim. Those using the USDA grass-fed standard were given 30 days to convert it to a private grass-fed standard. A number of organizations then produced their own grass-fed certification labels, including Food Alliance Certified Grass-Fed, Animal Welfare Approved (AWA) Certified Grass-Fed, and Pennsylvania Certified Organic (PCO) (source: New Label Soon for Grass-Fed Milk and Yogurt, Dr. Joseph Mercola, 4-19-16, https://articles.mercola.com/sites/articles/archive/2016/04/19/grass-fed-milk-yogurt-new-label.aspx). (See Compare Grassfed Labels chart) The lack of federally-regulated grass-fed organic dairy standards allowed a variety of labels and different brands to appear on store shelves, confusing consumers and frustrating the farming community. Trickling Springs, founded in 2001, was an early proponent of a grass based dairy supply though not strictly organic. Their initial success was hindered by a lack of capital and poor management decisions, and in 2017 CROPP Cooperative acquired the Trickling Springs grass-fed milk route.
PCO and NOFA NY saw a demand from their clients and worked together to develop “an end-to-end farm through retail” protocol for verification of grass-fed claims that were based on organic certification. During 2016 and 2017. CROPP Cooperative, Maple Hill, PCO, NOFA NY and the American Grass-fed Association worked together to develop a national standard but the AGA dropped back from this collaborative because they didn’t want the label to be restricted to being based on organic certification. In January 2018, the American Grass-fed Association (AGA) published updated Grass-fed Dairy Standards that require livestock production practices that include a forage-based diet derived from pasture, animal health and welfare, no antibiotics, no added hormones. By 2018, the initiative to form a national organic grass-fed add-on label had shrunk down to Maple Hill and CROPP Cooperative. The final details about who would own and accredit the program the program was finalized in the Fall of 2018. With the official launch, consumers will begin seeing the new seal on packaging in 2019, assuring the highest level of transparency by farmers and producers.
The new Certified Grass-Fed Organic Livestock Program builds on organic standards, meaning farms must first be certified organic to participate in the program. To then be certified under the new OPT standard, dairy cows must be fed a grass diet, with zero-grain, and given plenty of pasture for grazing. The two certifications can be bundled under one certification agency and inspection process. This new grass-fed organic dairy standard requires all animals to receive sixty percent (60%) of their dry matter intake from pasture over at least a 150-day grazing season (as opposed to 30 percent and 120 days per the National Organic Program’s organic pasture rule standards). In a joint interview, Adam Warthesen, CROPP Cooperative, and Tim Joseph, Maple Hill, said, “We don’t see this as a difficult reach because grass-fed operations are already at that level or higher, for the most part.” They added, “one big difference is that we will be allowing additional sugar-based foodstuffs, such as molasses and sugar beets to enhance nutrition and maintain animal welfare.”
The certification differs from other grass-fed certifications in that it requires full supply-chain verification to use the certification mark, creating a much higher level of transparency. Farms, processors and handlers must be certified to ensure grass-fed organic milk is segregated from all other milk, organic or conventional, from the farm to the consumer package. While EarthClaims currently serves as the program manager for the standard, this may change as 2019 is a pilot year to roll out the program and evaluate how it is working. OPT was created as a special purpose entity to house the standard and be responsible for its management; it has delegated provisional program management authority to EarthClaims for the 2019 pilot year.
“Maple Hill and Organic Valley have always been devoted to producing 100% grass-fed organic dairy in a way that exemplifies what consumers believe the words ‘grass-fed’ really mean. This new certification and seal are a giant step forward in protecting the grass-fed claim and giving consumers a true standard to measure at the shelf, and for Maple Hill the launch of the new program is a meaningful way for us to mark 10 years delivering 100% grass-fed organic dairy. It's all we've ever done and it's all we'll ever do."
--Tim Joseph, Founder of Maple Hill
What are the requirements for this new organic, grass-fed certification?
The certification applies to both producer and processor. There must be compliance from both parties so that the authenticity can be verified from the farm to the packaged product on the grocery store shelf.
2019 will be a transition year, with existing farms being reviewed as their certification becomes due. This will give the program the chance to educate everyone involved and to ensure that, by the end of year, everyone is in compliance. The certification process will begin immediately with a desk audit of all farms that are already producing grass-fed milk under the standards of their buyers and brands. Presently, valid Grass-Fed organic certificates issued by NOFA NY, Pennsylvania Certified Organic(“PCO”) and Vermont Organic Farmers (“VOF”) that bear anniversary or expiration dates prior to December 31, 2019 will be accepted by OPT, provided the certified Operation designated has applied to a Certifier to receive Certification under the OPT Program no later than October 1, 2019.
SUPPLEMENTAL GRAIN-FREE FEEDSTUFFS (OPT Program….)
|ENERGY SUPPLEMENT||SUPPLEMENT DRY MATTER PERCENT||MAXIMUM ALLOWED PER DAY ON DRY MATTER BASIS in lbs.||STARCH, %DM||ENERGY, M in Cal/lb|
|Sugar Cane- Molasses||88%||4||0.5||0.88|
|Sugar Cane Dry Sugar||100%||4||0.5||0.98|
|Sugar beets, Whole||20%||5||2.5||0.79|
|Sugar Beets, Pulp||92%||5||0.5||0.73|
|Kelp||99%||No Limits/Free Choice||N/A||N/A|
Does the new standard address the concerns over the abuses in the Origin of Livestock regulation?
The OPT standard does not address the aspect of continuous transition or purchase of transitioned dairy animals from other herds. It does distinctly differentiate between beef animals though, as does the USDA NOP regulation. While the standards do give preference to purchase of already grass-fed certified dairy animals when adding to the herd, it does allow variances if they are not commercially available. One of the stated reasons for the lack of availability is distance from the purchasing operation. This opens the door for the same abuse of the transition exemption that has played a large part in the oversupply of organic milk; a missed opportunity to safeguard this new standard from well-known and documented abuses within the NOP regulations.
According to the OPT Policy Manual:
X. Governance: Guidelines for Certification Services and Certificates of Compliance:
A. Eligibility for Certification:
1. Operations: This program is open to any livestock production or livestock product handling Operation, that is presently certified under the NOP, or eligible to concurrently be certified under the NOP and the OPT program.
2. Dairy Livestock: Eligible dairy livestock are solely those animals present at the applicant Operation at the time of the initiation of the required 90-day transition period.
Who is currently accredited to certify grass-fed operations and what are the certification fees associated with this new label?
What happens if a farm fails to meet the new standard?
Is the ownership of the label restricted to those brands that are starting the new certification program or will it be available to other brands to use?
Program Management and Oversight
EarthClaims will accredit and train certifiers and certification agencies to verify compliance by farms, handlers and processors with the standard. EarthClaims staff will review with a desk audit every single certifier’s reports prior to the certifiers being able to issue a certificate of compliance. Certification agencies must submit proof of accreditation with the National Organic Program to EarthClaims.
OPT has convened a three-person Steering Committee to oversee the ongoing work on the OPT Program Materials. The Steering Committee is presently composed of a certifier stakeholder and two stakeholder handlers. The launching press release implies that the two stakeholders are CROPP Cooperative and Maple Hill. Currently, there are no farmers on the steering committee, but this could change in the future. The steering committee’s job is to make sure the standards are implemented in a uniform manner by all accredited certifiers, which it does by revising the program manual as needed to clear up any ambiguities. The goal, as Prickett said, is to “minimize certifying agency drift.” OPT wants to minimize certification agency discretion regarding interpretation of the standard.
The Steering Committee will convene three subcommittees:
Producers will mainly communicate through their certifiers, who will then bring producer-feedback to the steering committee. From OPT Policy manual: “OPT develops its standards by an open and inclusive process that involves diverse opinions. OPT conducts ongoing review of each module’s standards by stakeholder subcommittees and receives input directly by a case-by-case petition process under which any materially affected person may petition for a change in existing OPT modules.”
Grass-Fed Certification Label: will it have an impact on producers?
The introduction of this seal comes at a time when American shoppers are becoming more aware of, and invested in, how their food is produced, including animal welfare and environmental impacts of food production. According to the program founders, grass-fed dairy aligns all of these interests, providing important health benefits, minimizing the environmental impact of the overall process and creating healthier livestock.
While the many benefits of grass-fed dairy are well known, some producers are wondering how this will impact them: how will they justify the increased cost of certification? Will they have greater market access? Will their pay price reflect their investment? Maple Hill founder Tim Joseph said that he doesn’t foresee that the new certification would impact pay price in the new future, noting that this isn’t a ‘magic bullet’ for the grass-fed dairy industry; but noted that Maple Hill is currently paying between $37.00 and $40.00 for grass-fed milk, with seasonal adjustments. Nor does he see the label helping farmers who recently had their contracts canceled because their size/distance from other farms on milk routes did not justify keeping them on. Maple Hill has recently developed a new contract, which will start on July 2019, for its producers which includes the following: a quota system; penalties for over production, plus incentives for maximizing production when milk is short; an increase of trucking charge to a $740 per month stop charge and a base price of $35 with an expected average of $38 including components. If anything, the new standard, by requiring additional segregation, could increase shipping and processing costs, which will increase cost pressures throughout the supply chain.
On one level it is an extremely positive development that CROPP Cooperative, Maple Hill and Natural By Nature partnered to create a new grass-fed organic dairy label and standard that could help the entire organic dairy industry weather a milk glut and uncertainty over what the organic label means by providing a valuable add-on standard that is consistently interpreted in all regions of the country, and by all certifiers. The standard may serve to support smaller dairies that rely on a grazing-intensive cow feeding regime as they now will be able to differentiate themselves in the marketplace like never before. However, certain features of this new program might give one pause.
First and foremost, this is a private standard, and as such simply does not carry the weight that the USDA NOP standard has. OPT was formed for the explicit purpose of this standard and is reliant on EarthClaims for all its management and operation. While EarthClaims will provide oversight of certifiers, it will not audit certifiers nor conduct spot field checks to ensure full and accurate certification of farmers and handlers by the certifiers.
Second, the fact that the standard was essentially created by two organic dairy companies suggests the potential for a conflict of interest. A true third party standard would not be linked to the milk marketing firms that buy milk from certified suppliers; it would be completely independent. This lack of independence could lead to problems down the road as CROPP Cooperative and Maple Hill would be reluctant to drop certified producers from the program if that meant loss of sales to stores.
Third, the lack of direct farmer involvement in the development and modification of the standard is a concern. The existing OPT Steering Committee responsible for decision making has two handlers and one certifier with a requirement that there is a two-thirds majority for any decision. This gives the handlers control of all decisions. Who is the standard really meant to serve? Are the standards going to help farmers who are facing a once in a generation cost-price squeeze to be able to climb out of the financial pit that is the current organic milk market and earn a fair return for their efforts?
Ideally, this grass-fed organic dairy standard would be housed within the National Organic Program, with farmers having the option of making this an add-on to the regular organic certification. Such a process would provide it more institutional support, reduce conflicts of interest, increase transparency, and ensure that certifiers are audited periodically, with NOP staff actually making field visits to verify that certifiers are correctly implementing the standard. While there is no opportunity that the current USDA administration will have the add-on integrated into the NOP, this program does nothing to remedy some basic problems and inequities within the implementation of the organic dairy regulations. It fails to provide explicit direction on the one-time transition allowance that has been used by bad actors to destroy the supply side of the organic dairy market and the opportunities of small to mid-size operations. Farmers and organic consumer advocates need to pay close attention to this new standard, and work to make it accountable and transparent.
For all the published details of the program see below
Posted: to Industry News on Mon, Apr 22, 2019
Updated: Mon, Apr 29, 2019