Certified Organic producers must follow the Organic Feed Standards. But it’s not easy. Although guidance and resources are available, the many components of a feed ration and the various rules governing these can be difficult to decipher. Working closely with your certifier, and assuring that all rations are approved before utilizing them, are the best ways to insure that your organic certification remains valid.
Jackie Sleeper, Farm Program Technical Specialist with Oregon Tilth, along with Jeff Mattocks, Livestock and Poultry Nutrition Advisor with Fertrell, presented a webinar aimed at assisting livestock producers in better understanding the nuances of certified organic livestock feed. The May 5 webinar, “Decoding Organic Feed and Supplement Requirements,” can be viewed here: https://vimeo.com/127168853
Feed can be one of the most expensive outlays for organic livestock producers, Sleeper said. For certified organic producers, reading and understanding labels, having a working knowledge of National Organic Standard regulations, and knowing when to ask an expert are crucial.
The National Organic Standards, section 205.237, covers livestock feed. The National Organic Program handbook has a compilation of guidance documents regarding feed and feed ingredients, Sleeper said. Any synthetic product allowed — or any natural product prohibited — in certified organic production will be listed on the National List of Allowed and Prohibited Substances.
However, just because an item is on the National List does not mean that it is allowed or prohibited in all organic production, only that is approved or prohibited for specific purposes. If a product carries the Organic Materials Review Institute (OMRI) seal, it is almost universally accepted by certifiers as permitted. However, products are certified organic for a certain use, and may not be considered certified organic for any other manner of use.
“Just because something is certified organic does not mean it would be allowed to be fed to an organic animal,” Sleeper said.
Food which is certified organic for human consumption, for example, may contain ingredients which are not permitted for use in animal feed. Where animal feed is concerned, all ingredients must be certified for use as a livestock feed product, or permissible as an ingredient in certified organic livestock feed.
Determining whether a ration is certified organic can be complicated. Components in a ration include the agricultural product, allowed synthetic ingredients, non-agricultural / non-synthetic ingredients, and premix multi-ingredient components.
Rations are primarily comprised of agricultural products — grain, meal, hay, silage, fodder and pasture — all of which must be certified organic. Any agricultural ingredient in feed, including those used as binding agents or supplements, must be certified organic, such as molasses or vegetable oil.
Any synthetic materials which may be included in a ration must be permitted as a feed additive. A feed additive is made available in micro-quantities, and is fully incorporated in a ration. A supplement is fed free choice, or incorporated, and may include feed additives as an ingredients. Currently, the only synthetic feed additives which are permissible are trace vitamins and minerals, or methionine. There are no synthetic feed supplements currently allowed, Sleeper said.
Non-agricultural products, which are also non-synthetic in nature, are allowed unless they are prohibited in the NOP rules, or are on the National List as a prohibited substances. Some common products which are non-agricultural and non-synthetic in nature include: kaolin clay; algae; diatomaceous earth; and fish meal.
Some ingredients, such as salt, seem to be natural. However, salt can have anti-caking agents which are not permitted in organic production. Likewise minerals can be natural — meaning they are mined and not further processed — or they can be synthetic, undergoing further processing after mining. This is often not made clear on the label, so further inquiry will be necessary.
In some circumstances, a product or ingredient is approved for use as a healthcare supplement for livestock, but not as a feed ingredient, Sleeper said. A feed product is used regularly for nutritional purposes, as a part of the ration, and all ingredients must meet the requirements outlined. But if the same product is utilized as a periodic treatment for health issues, not all ingredients have to be certified organic.
Sleeper gave an example of a producer who wished to give his livestock kombucha as a feed ingredient, but the product had non-organic sugar in it. It was not allowed as a livestock feed, but was permitted to be used as a periodic healthcare supplement to address gut health.
There are certain things a certified organic livestock producer can not do. Urea, manure or plastic pellets can not be fed. There are no drugs permitted, including hormones, for growth promotion. Ingredients can not be used at higher than the approved rates needed to meet nutritional requirements. No slaughter or slaughter by-products such as: bone or blood meal; bone charcoal; some Vitamin D-3 formulas; or gelatin; can be fed. No ionophores or antibiotics are permitted in feed. Some prohibited substances commonly found in feed are mineral oil, lysine, and amprolium.
“You can’t prevent ruminant animals from pasture during the grazing season,” Sleeper said. The “Pasture Rule” covers dry matter intake from pasture, as well as pasture access.
The NOP also has guidance documents for specific ingredients, such as yeast and kelp. For the past decade, kelp has been available as a certified organic product, Mattock said. Although thought of as a wild harvested product, producers have been able to monitor water quality and establish a sustainable supply chain from harvest to processing. Certified organic kelp is wild harvested, but monitored.
Yeast and bacteria do not currently require organic certification, but there are restrictions in place for certified organic growers. Only non-GMO strains can be used, and in some cases, only strains not grown on GMO substrates can be used. Producers must be careful and do their investigating, as well as get certifier approval, before using these products, he said.
Fish meal is also a primarily wild-harvested product, and is used in poultry in swine feed to balance amino acids and as a source of protein. However, methionine can be added. Another concern is ethoxyquin, a common preservative, which is prohibited in certified organic production. There are some certifiers who will approve plant extract preservatives, which can be used as an alternative in some fish meal formulas, but not all will allow their use. And the potential for farm-raised fish meal product brings GMOs into the equation.
Mattocks strongly suggests producers learn to communicate well with their certifiers and with their nutritionists. Provide the certifier with as much information as possible, and never rely on anyone else’s opinion on whether a product will be permissible.
Any input and all inputs found in certified organic livestock feed must be approved by the certifier. OMRI approved and labeled commercial products must be approved for the manner in which the producer intends to utilize them. Producers must keep accurate records, and follow their Organic System Plan. Even one misstep can void organic certification, so getting everything approved first, before using it, is prudent.