Everything you asked for, and then some ...
Insights about the Pasture Rule from sessions at the recent NODPA Field Days
By Lisa McCrory, NODPA News and Web Editor
The Pasture Rule was unveiled just before Valentine’s Day last February, offering many of us ‘everything we asked for’. The consequence of getting what we asked for is that now we have some added record keeping to do, and producers and certifiers alike need to get used to it. There will be growing pains, but I think that we will pull through and the organic dairy industry will be better for it.
The pasture rule requires that measurable amounts of pasture is consumed by ruminant livestock during the grazing season with a minimum of 120 days and 30% dry matter averaged over the grazing season. Within the rule there are additional pieces added to the livestock feed and living conditions, and this is the area that I feel could have the greatest economic impact on some organic dairy farms.
Not everyone is interpreting the pasture rule in the same way (no surprise), but inviting NOP staff to events such as the NODPA Field Days provides an opportunity for further clarification, feedback and discussion. On day two of the NODPA Field Days, Melissa Bailey, NOP Director of Standards gave a presentation on the Pasture Rule covering the various nuts and bolts about the rule, and highlighting areas within the rule where the NOP tends to receive the most feedback.
In Livestock Feed 205.237 (a)(2)(i), she suggested that producers check with their certifier to determine if the supplements/additives that they are using are organically approved for use. In Livestock Feed 205.237 (b) (8), Melissa stated that if an operation is grazing in the daytime and keeping their cows in the barn at night (or the reverse of this), then this is allowed by the NOP provided the producer is meeting the 30% dry matter from pasture. Make sure to include this management in your OSP. In Livestock Feed 205.237 (c)(1), she wanted to make it clear to all that pasture consumption is calculated as an average over the entire grazing season for each type and class of animal.
The issue of who defines the grazing season was clearly addressed during the workshop session. It is the producer who defines the number of grazing days in their OSP. Due to topography, fertility, micro-climates and management the grazing season can vary quite a lot even within a small geographical area. Whatever the season length a producer defines, it needs to be defendable and reasonable. If a certifier does not agree with the producer, they should let the producer know and come to some sort of an agreement. In the event that an agreement is not made, a certifier could give a minor non-compliance and the producer could rebut.
Livestock Living Conditions 205.239 got some attention as the NOP has yet to take a clear stance on outdoor access. There are some farms that have roofed barnyards and others who have green house barns, and though the cows are not housed inside a building with walls, they are not able to stand outside with access to direct sunlight. Some certifiers would consider roofed barnyards as outdoor access where other certifiers would not. At this point in time, the NOP is still working on a stance, which is needed in order for producers to be treated consistently from one certifier to another. If roofed barnyards are not considered outdoor access, then there are some producers who will have to make some (potentially) costly changes to their operations before June 17, 2011.
Following the presentation, Melissa Bailey and Miles McEvoy, Deputy Administrator of the National Organic Program, fielded questions. The 75-minute workshop was packed with good information, and lots of excellent questions from the audience. A couple of questions on outdoor access will soon need a formal answer, as the pasture rule implementation date is fast approaching.
NODPA is doing what it can to make sure that producers understand what is being expected of them and that accredited certifiers are enforcing the new rule fairly and reasonably. It is always best when one can ask a question directly to NOP staff. Oftentimes they are clarifying an area that producers and/or certifiers were unclear about and sometimes a question asked can highlight areas that still need to be clearly addressed by the NOP. Thank you Miles and Melissa for participating in this years NODPA Field Days.