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Pasture Rule Training March 24, 2010:
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.

NODPA-Odairy Ruminations:


"§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."
  • This section of the rule does imply 30% average over the entire grazing season. But as mentioned, extending the grazing season at reduced intake levels could  penalize the average.  The NOP needs to define the proper interpretation of the rule that meets the intent w/o a penalty effect.
  • We want to be able to define the grazing season by the time frame where cows could conceivably meet 30%, and not penalize a farmer for leaving cows out longer!  We like cows out on pasture, right?
  • So for example, if the farm is in an area where they can turn their cows out on pasture and they GRAZE for 165 days, perhaps we should be documenting the number of days when a farm is able to have their animals out on a full pasture ration, which would have to be not less than 120 days and an average 30% DMI from pasture.
  • From what I understand, the pasture rule intent is to meet the 30% DMI for a minimum of 120 days.  These are the basic common denominators that were framed in the rule that we agreed by consensus was achievable everywhere.  Given that the transition into and out of the grazing season may fall below the 30%DMI, this should be above the minimum criteria if not a part of the 120 days.         - Let's remember how little 30 % DMI is !   
    • 30 % DMI  for a 1000 lbs cow using the 4% of BW figure is only 12 lbs of pasture.  Using the estimate of 300# DM / inch of plant material (decent dense sward), 50 cows on 2 acres need only top off 1 inch of growth in 24 hours !  If you have 30 paddocks for a 30 day rotation, doing some rising plate meter measurements, you will find you start achieving pasture growth rates exceeding 10# DM/acre/day (what is needed to provide another 300#/acre DM every 30 days) very early and very late in the season.  When you start to mow your lawn, if you are not already grazing, the growth rates are already ahead of what you can keep up with.   
  • My hope for this rule is that it will raise the bar on pasture use and pasture management, not foster squeaking by with just the minimum.  Showing the way this rule requirement will be meet in the OSP will force producers to think about what the pasture is producing and what the potential is.  We are good at calculating rations we dump from the mixer into the feedbunk, but we (collectively as graziers in the USA) have much to learn about pasture feed rations and management (and could benefit from the KIWIs who can tell you on any given day what the feed budget and feed wedge is and what the pasture intake is and the feed conversion rates).
  • I'll share MOSA's certifier perspective.  We've been in contact with grazing specialists in all the regions we certify in with the idea of identifying what the typical grazing season is in that area.  When my staff talked to these grazing specialists they were looking to identify what the grazing season would be for the operation that doesn't put extra effort into extending it...in other words, not the grazing season of those who plant turnips for extending in the fall and rye for early start in the spring.  This gives us reference points of somewhere between 120 days for northern Minnesota and 200 days in southern Illinois.  The producer is going to provide their understanding of what the grazing season is on their Organic System Plan and we'll compare it with the baseline info we gather.  Right here in southern Wisconsin, the season would be 150 days.  The producer would be expected to get at least 30% average over these 150 days.  If their grazing on their farm is more like 165 days due to their management practices for extension, we're going to still only hold them to getting 30% over 150 days.  If there were a drought that reduced the grazing season by 20 days, they would be averaged over 130 days.  Now, if there were a drought that reduced the grazing season to 115 days, they would not be in compliance.
  • SO, from what we have been thinking about at MOFGA Certification Services, the MOSA tack makes sense.  However, we didn't want to get into telling producers what their grazing season is...  So, how to ask for the information without unduly penalizing a producer who is basically proud to keep their cows out way late into the season.  I think the wording we have come up with is something like: dates when cows can receive a significant portion of their forage from pasture (>30% DMI)...  and also collecting turnout/barn-up dates... 

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.