Organic Dairy Farmer Feedback Survey Results and Next Steps
By Ed Maltby, NODPA Executive Director and Lia Sieler, WODPA Executive Director
In 2024, the Western Organic Dairy Producers Alliance (WODPA) and NODPA worked together to publish and distribute a producer’s survey in response to frustrations communicated to us within the industry regarding changes in inspections, the amount of information required and dramatic increases in the cost. The goal of this survey was to collect information and feedback regarding the newly implemented Strengthening Organic Enforcement (SOE) Rule and the Origin of Livestock (OOL) Rule and present it to the National Organic Program. Organic Dairy farmers have seen many changes in their inspections. More specifically, they reported increase in length and specific data requested at their annual inspection, changing formats for how certifiers want information presented/ available and astronomical increasing in cost for certification.
Is this because of new regulations or increased enforcement by the NOP on how they audit their subcontracted certifiers?
Are certifiers increasing charges because of increased time required to complete certification inspection, desk audits and final certification or have many certifiers been charging too little and not improving their own infrastructure?
Have certifiers moved away from the Sound and Sensible implementation of regulation with a size appropriate response to inspections?
Relationships with certifiers have become strained and inspectors are, in some cases, feared. Organic dairy farmers care for their land and their animals with the utmost integrity and should be shown the respect they deserve, not unnecessary harassment and intimidation as some certifiers try to impose a one-size fits all certification process.
Metrics of the survey:
37 Farms participated in the survey, accounting for a total of 15,000 cows.
Length of time the operation has been certified organic was between 5 years to over 25 years.
81% of producers were familiar with the SOE and 97% with the OOL
Only 24% producers had made comments to the National Organic Standards regarding these rules.
States represented: California, Oregon, Washington, Idaho, Utah, Wisconsin, New York, Pennsylvania, Vermont and Maine
Topics raised by producers during onsite inspections that seemed more invasive or specific than usual.
Increased traceability and detailed reports of dead and sold animals with indepth mass audits of cattle (example: 2023 audit summary was 46 pages; 2024 inspection was 102 pages),
Traceability and request for organic certificates from the cattle haulers, which are not required by NOP certification.
Request for Validus & F.A.R.M. animal welfare inspection summaries, which are not required under NOP regulations,
Proof through QuickBooks or similar software programs of the payment received for organic sales, rather than accepting written records.
Written responses for simple questions required rather than verbal ones, for examples why youngstock were in confinement 12 days longer than my milking herd.
Offfarm manure affidavit was requested.
Producers’ responses to questions or requests asked by certification desk audits during the year that seemed to be non-essential or invasive.
Request for employee training logs and electronic animal inventories for the past 35 years.
Financials, invoices and past non compliance reports were requested from previous years.
Request for employee training logs
SOE has resulted in changes in the templates already provided and completed
New Fraud Prevention Plan template mandated
More detailed maps of farm facilities and pasture
They compared my pregnant heifers’ ration to what their textbook says. It was lower than their textbook said it should be so I got a noncompliance.
I received a noncompliance for not letting my tiestall animals out on Sundays even though it is written in my OSP that I do not.
Increased details for small amounts of seed.
List of past noncompliances and proof we have fixed them (going back over 5 years)
Clarifications needed:
We are still talking about how to implement the 15year-old regulation including inaccuracies around when calculating pasture/ dry matter intake, is it a weighted average over all of the pasture season or is it on a per day basis?
Example: If lactating cows are getting 40% DMI from grazing for 100 days of pasture season but then only 28% for the remaining required 20 days, would it still meet the requirements?
Do heifers, dry cows and lactating cows all have to be pastured/ grazing at the same time? Not according to the regulation.
If a material is already listed on OMRI, why does it need to be approved by certifiers individually for use on a farm prior to actually using it?
Opportunities for certifiers to help:
Summary of changes when new rules are implemented.
Clear, written answers to questions regarding rules
On time/ up to date certificates (within 12 months) given to clients/farmers (without having to ask multiple times)
More knowledgeable/trained inspectors
Feedback survey on inspectors
Opportunities for NOP to help:
Provide more FAQ sheets (printed and mailed as well as emailed)
Organic Costshare support
OSP template moving forward as rules are implemented
Annual feedback survey on certifiers
Quotes from dairy farmers:
“The certifier is asking for a lot more information that isn’t found or backed by organic regulations.”
“They are no longer employing a sound and sensible approach to certification.”
“Why do we even bother with getting organic certificates from vendors when we have to prove they are organic through invasive records anyways?!”
“Certifiers are there to protect and educate us but the inspectors come to discipline us.”
“Our certifiers aren’t there to help us. They seem like they are just playing a giant game of “gotcha”.”
“This year more than any other year, it feels as if they want to catch us doing something wrong and just get mad at us rather than helping us to comply.”
Follow-up
On June 3rd, Lia Sieler and Ed Maltby met with Jenny Tucker, head of the National Organic Program and members of her team to inform them of the results from the survey and discuss opportunities for improving the certification process. Lia presented an excellent PowerPoint that summarized the survey and discussed areas of concern and possible improvement that can be made within the certification process. She raised issues around the necessary accountability and enforcement that safeguards the integrity and consumer confidence of the label, while ensuring active enforcement of regulations consistently across all certifiers. Lia and Ed will be meeting again with Jenny and members of her team on September 11th to further the discussion about improving the certification process and ensuring that organic dairy producers’ voice is heard in decisions on the certification process.
Lia (Van Egmond) Sieler is the Executive Director of the Western Organic Dairy Producers Alliance (WODPA). She is a third-generation farmer born and raised on her family farm in California. She graduated from Chico State with a Bachelor of Science in Agriculture and worked for a cheese plant immediately out of college before accepting a position as the Quality & Field Manager for an organic milk broker. Now, she works for WODPA as the Executive Director as well as working part time for DairyWorks helping farmers with animal welfare certifications and documentation. Lia can be reached at lia.wodpa@outlook.com
Posted: to Industry News on Fri, Sep 5, 2025
Updated: Fri, Sep 5, 2025
