Trends and Challenges in Certified Organic Livestock Operations

By Margaret Scoles


When the first reported U.S. case of a bovine spongiform encephalopathy (BSE)-infected cow occurred in December 2003, organic meat demand rose sharply and immediately. All U.S. livestock operators (non-organic and organic alike) braced themselves in anticipation of plummeting U.S. cattle prices. Canadian cattle markets were already suffering drastically after BSE was found in a Canadian herd last summer and many Canadian export markets were forced to close, including those to the U.S. Soon the infected U.S. cow found in Washington State was traced to Canadian origin and the U.S. Department of Agriculture (USDA) assured consumers about the safety of U.S. beef.

Surprisingly, U.S. livestock market prices for non-organic meat failed to follow the Canadian freefall. Markets hesitated but recovered. Consumer confidence in conventional beef products remained largely unshaken, in spite of media coverage exposing the woefully inadequate BSE testing program in the U.S. and the common practice of slaughtering older and “downer” cattle for meat. The BSE incident had a major positive impact on the organic market, though, and not all consumers were assured by the USDA media blitz. In Canada, according to an April 22 report by analyst firm Research and Markets, the Canadian meat market expanded by 35% in 2003 and similar growth was expected in the U.S. in 2004.

New-to-organic consumers were attracted to organic beef by the promise of food safety. Feeding of mammalian and poultry slaughter by-products to organic livestock has long been prohibited by organic standards. Organic producers benefit from increasing consumer awareness of that detail. Since 1997, the U.S. has enforced a ban on feeding materials such as bone meal or other by-products, but some companies have violated the rule. Since BSE may not express itself in infected cattle for many years, verification that a cow or herd is BSE-free through testing may not provide assurance to consumers.

Organic meat prices are stronger and demand is up as a result of the BSE scare, however, few suppliers were ready when the opportunity arose. The sudden interest in this product category has been a boon to those organic livestock producers who were ready. Ten exhibitors at the “All Things Organic” conference in Chicago, IL, May 2-4, 2004, were listed as meat suppliers, twice the number that displayed their wares at the 2003 ATO conference. While this segment of the organic food industry is experiencing newfound demand in the marketplace—both from consumers and from organic processors that are developing multi-ingredient foods containing meat products—organic livestock producers still must overcome some important challenges to meet the new demand.

Identifying the Challenges
The greatest obstacle to increasing supply to meet the increased demand is the length of time it takes to produce a certified animal. To become certified organic, slaughter stock (except for poultry) must be under organic management from the last third of gestation. (Poultry must be managed organically from the second day of life and are slaughtered or produce eggs just months later. Therefore, producers can gear up for organic poultry and egg production much more rapidly.) Getting certifiable takes time. For cattle, the mother cow must be managed organically approximately three months before giving birth to an organic calf. The organic calf won’t be ready for slaughter for about 18 months.

Organic management means access to the outdoors for all livestock and pasture for ruminants, the use of 100% certified organic feed and only approved feed supplements and minerals, and the application of a preventive health care system designed to minimize the use of off-farm inputs and maximize good management practices—in short, good old-fashioned animal husbandry, excellent nutrition and minimized stress. In addition, organic slaughter stock may not be treated at any time of life with any synthetic parasiticides, antibiotics, growth hormones or other materials not specifically allowed by federal regulations. While animals on an organic operation are occasionally treated with prohibited materials, these must be clearly marked and designated for the non-organic market. Historically, organic beef producers were only able to market a percentage of their animals as organically grown. The remainder were usually sold to conventional markets at non-premium prices. When the organic beef market surged in late 2003, those with finished, ready-for-slaughter stock found a ready market for all of their animals.

Another major challenge for organic livestock producers is the consumer misperception that “natural” equals “organic.” Natural meats are much cheaper to produce, so the product can be marketed at a lower price and more dollars can be invested in marketing and advertising. Consumers generally are most concerned about antibiotic-free and growth hormone-free animal products. The demand for animal products produced without hormones or genetic engineering extends beyond meat to dairy products. demand for organic milk surged several years ago with the advent of Monsanto’s genertically engineered bovine growth hormone (rbGH). This product, recently removed from the market, increased milk production. The market impact is analogous to the impact of BSE on organic meat demand. “Natural” producers can often substantiate their claims to both hormone- and antibiotic-free, even though their products may be raised using genetically engineered feed and pesticides. Also, organic producers must meet the challenge of providing a year-round supply of organic feed in the face of natural disasters and feed shortages. “Grass fed,” “grass finished,” and “free-range” claims add to consumer choice and consumer confusion regarding the differences between the multitudes of “near-organic” label claims.

Perhaps the biggest challenge of all for organic livestock producers is that of interpreting the murky water of USDA organic rules. Organic standards for livestock were not as well developed as crop standards by the time the USDA National Organic Program (NOP) regulations were released in October 2002. A few murky examples:

• Fishmeal is an allowed feed supplement. It is used as a protein supplement. However, most fishmeal contains a synthetic preservative called ethoxyquin. At higher percentage levels, ethoxyquin must appear on the label. At lower concentrations, it might not be evident and might end up in organic feedstuffs. During an April meeting of the National Organic Standards Board (NOSB) in Chicago, the NOP program director stated that all fishmeal is allowed as a feed supplement. Synthetics are prohibited unless specifically allowed, but it was not clear whether synthetic preservatives are or aren’t allowed in fishmeal.

• Antibiotics. The Code of Federal Regulations (CFR) 7, 205.238(c)(1) clearly states: “The producer of an organic livestock operation must not: (1) Sell, label, or represent as organic any animal or edible product derived from any animal treated with antibiotics….” However, CFR 7, 205.236(a)(2) specifies the process for converting existing dairy herds to organic, stating: “Milk or milk products must be from animals that have been under continuous organic management beginning no later than 1 year prior to the production of the milk or milk products that are to be sold, labeled, or represented as organic.” This discrepancy in the regulations led to confusion about whether antibiotics may be used on an organic farm for young dairy calves that can be later converted to organic milk production. An April 13, 2004, website posting from the NOP “clarified” that all animals that are managed for at least 12 months may produce organic milk. Many organic dairy industry representatives vehemently opposed this interpretation at the April NOSB meeting in Chicago, voicing consumer choice for milk from animals that have not received antibiotics.

• Parasiticides. A similar situation exists for beef calves, lambs and other young livestock. CFR 7, 205.238(c)(4) states that organic producers “must not… administer synthetic parasiticides on a routine basis.” Also, young stock is required to be managed organically from the last third of gestation. However, some producers wish to use synthetic parasiticides, such as Ivermectin, prior to the last third of gestation, especially in low-lying water areas where internal parasites or liver flukes are prevalent. Different interpretations of this rule lead to inconsistency in production.

• Treated wood. Wood treated with copper chromium arsenate (CCA) and other prohibited materials is prohibited for new installations or replacement purposes in contact with soil or livestock. Does this mean that CCA-treated fence posts are prohibited? The most common interpretation is yes, prohibited, for new installations.

• DL-Methionine. During 2003, the NOP adopted the first changes since the rules were released. Among those changes was the addition of this synthetic amino acid to the National List of allowed synthetics for livestock. It is allowed only for poultry and with a “sunset” provision that sets Oct. 21, 2005. The NOSB is beginning to review all materials on the list. The future of methionine as an approved material is uncertain. It was approved largely due to the lack of natural alternatives.

There are other common mistakes and problematic issues in organic livestock operations that also will have to be addressed by producers who want to take advantage of the new demand for their products. These include:

• Buffer areas. Animals must not have access to areas where prohibited materials have been applied by adjoining operations. Unlike crops, animals are mobile and inspectors must verify carefully that animals have been on organic pasture and feed for their entire lives.

• Bedding. If consumable by the species, bedding must be organic.

• Feed salt. Flowing agents and synthetic dyes can render an allowed material unsuitable for organic production.

• Feed processing. All feed manufacturing facilities must be inspected and certified.

• Internal and external parasites. Most organic livestock producers reduce infestation and parasite loads by a combination of sanitation and intensive pasture rotation. About 80% of parasites live in the first 5 cm of vegetation, so controlled grazing limits the infestation. Some operators use fly traps, beneficial parasitic wasps or other non-toxic materials, such as olive oil or vinegar and soap for flies.

• Mastitis in dairy animals. Alternatives to antibiotics often seen on organic farms include colostrums, frequent and repeated stripping and homeopathy.
• Physical alterations. These must be done only in a manner to minimize stress and only for physical welfare of the animals.

• Inadequate animal tracking. Larger animals must be identified individually. Usually this is accomplished with ear tags, tattoos and sometimes, branding. Swine are especially difficult to identify permanently.

• Inadequate records of feeding or medications. Organic producers must carefully track all animals through sale, especially if any animals are removed from organic management.

• Faulty manure management. Manure must not contribute to contamination of crops, soil or water by plant nutrients, heavy metals or pathogenic organisms. Organic producers are regulated more strictly than non-organic producers.

Organic meat processors also face challenges in ensuring that they continue the chain of organic process integrity. Slaughter plants must be inspected and certified to handle organic animals. Fortunately, few changes are generally required for slaughter plants to meet the requirements of organic certification. These facilities are overseen by state or federal inspectors, are commonly cleaned with high-pressure hot water, and are accustomed to carcass identification. Individual carcass identification is required. A complete cleandown must be done before processing organic animals. Most plants slaughter organic animals first in the day. Materials used for fly control, both to flush flies from the animal’s back prior to slaughter and for killing flies in the slaughter area, are a primary concern. There are very few approved organic pesticides and other non-organic regulations prohibit flies in the slaughter area. Facilities must be able to document all of their procedures to show that they prevent contamination with prohibited materials such as sanitizers and commingling with non-organic meat.

Multi-ingredient products that require spices or other additives also present challenges to the further meat processor in the organic category. Products such as sausages, for example, must use organic spices unless they are not commercially available in organic form. Specific blended spice mixes that are certified organic are sometimes available only in larger quantities that are not feasible for application in small operations. Some handlers are opting to produce “made with organic meat” sausages, which allows for the use of non-organic spices and/or casings. Popular organic meat items such as ham and bacon must be produced without the common additives found in their conventional counterparts. In no case may ingredients for “organic” or “made with organic” products be produced with sewage sludge, irradiation or excluded methods.

Since it is a highly perishable product, most meat is provided to organic consumers in frozen form or heat-sealed in Cryovac-type packaging. This heat-sealed packaging lengthens shelf life but darkens the appearance of the meat in the retail counter until the package is opened. Studies show that consumers most frequently choose lighter colored red meats from the case over darker colored products, believing them to be “fresher.” This is a marketing and packaging challenge that organic meat processors will have to overcome.

Mooving On
It is safe to say that the market for organic beef will remain strong in light of continuing concerns about the prevalence of BSE in the U.S. But organic meat producers cannot rest on their processes alone. As organic policy analyst and member of the NOSB, Jim Riddle pointed out in a recent Independent Organic Inspectors Association (IOIA) professional online forum, although the organic sector has taken many precautions to minimize the risks of organic cattle being infected, it is prudent to take a hard look at the NOP regulation to determine if there are likely entry points whereby BSE could be detected in organic livestock. Riddle notes that there are potential pathways allowed in the regulation by which BSE could be detected on organic farms, including section 205.236(a)(3), which allows breeder stock from non-organic operations to be used to produce organic offspring and the “two track” interpretation of 205.236(a)(2)(iii), which increases the likelihood that BSE infected animals will be detected on organic dairy farms. Riddle has asked the NOSB and NOP to address these issues.

Federal regulatory agencies continue to move torward country of origin labeling rules, and more sophisticated animal identification and traceability systems are also on the horizon. More than 130 producer and consumer groups recently signed onto a National Farmers Union letter urging legislators to reinstate the Sept. 30, 2004 implementation date for mandatory country-of-origin (COOL) labeling as set by the 2002 Farm Bill. This bill has support from farm groups and consumer advocates who believe labeling would provide a marketing advantage for independent farmers and ranchers. It would reverse a two-year delay mandated in the omnibus 2004 spending bill passed last February. Regarding traceability, hot iron branding of the Old West may be on its way out as the industry moves to electronic eartags with radio frequency signals and even retinal scanning technology.

Ultimately, the consumer demand for more value-added, convenient, shelf stable, multi-ingredient organic meat products will spur organic product developers to increasingly use these ingredients in their companies’ certified organic ready-to-eat meals, frozen entrees, snack foods or canned stew and chili product lines. If organic meat producers stay abreast of the issues and work to meet the challenges, they should be able to meet this exciting new demand for their products.

Margaret Scoles is Executive Director and Training Manager of the Independent Organic Inspectors Association (IOIA), a non-profit association of trained farm and processing inspectors dedicated to the verification of organic production processes based in Broadus, MT. Scoles has 16 years of organic inspection experience for numerous certifiers, including inspection of farms, livestock and processors. She and her husband own a cow/calf operation in southeastern Montana. Contact Scoles at info@ioia.net or visit www.ioia.net.