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Ask The Certifier - OCIA
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by Maralee Maldavs
02/01/07 Organic Producer
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I am looking at using several feed supplements for my cattle. Are there any ingredients I should specifically watch out for? What happens if I feed them a supplement that contains a non-approved ingredient?
The first and most important thing to remember when you are considering the use of a new product is that you must obtain a full ingredient list from the manufacturer. This is the only way to determine if all components of the product are allowed for use in organic production.
The National Organic Program Final Rule (NOP) standards for livestock feed 205.237(a) state “…nonsynthetic substances and synthetic substances allowed under 205.603 may be used as feed additives and supplements. These substances are as follows:
205.603(C) As Feed Supplements – Milk replacers without antibiotics, as emergency use only, no nonmilk products or products from BST treated animals
205.603(d) As Feed Additives
1. DL-Methionine, DL-Methionine-hydroxyl analog, and Dl-Methionine-hydroxyl analog calcium (CAS# 59-51-8; 63-68-3; 348-67-4) – for use in organic poultry production until October 1, 2008.
2. Trace minerals, used for enrichment or fortification when FDA approved
3. Vitamins used for enrichment or fortification when FDA approved.
Some things that you should watch out for are ingredients that will tell you immediately if the product is prohibited: mineral oil, synthetic preservatives, artificial colors or flavoring agents, urea, plastic roughage, hormones, manure and mammalian or poultry slaughter by-products. There are many other ingredients that will make a product prohibited but the above substances are easy to spot and take no further investigation from the producer or certifying agency.
So, how do you determine if a substance listed in the ingredients is a FDA approved vitamin or mineral? This is not an easy task but there are resources available to help you. The Association of American Feed Control Officials Incorporated (AAFCO) releases an official publication every year which outlines all the regulations and requirements for livestock feed, feed additives and supplements. The AAFCO book can be used as a reference tool to help identify what is or is not a mineral or vitamin. Generally speaking these substances are allowed however, a word of caution, this is not foolproof, as AAFCO does not specifically identify those products allowed for use in organic systems. You should continue to check with your certifying agency before using any product.
Now we come to the issue of what you must do if you have fed a prohibited substance to your organic livestock. This affects not only feed but healthcare supplements that are given orally/internally as well. First and foremost, you must withdraw those animals from certification. There is no way around this, if an animal has been given a healthcare treatment, feed supplement or feed additive that is not allowed, it must be removed from organic production and physically segregated from other organic livestock. There seems to be some confusion in the organic industry as to whether or not an animal that has been removed from organic production can ever be certified again, simply stated, it may not. Once an organic animal has been removed from organic production and handled non-organically, neither the animal nor its products (i.e. milk) may ever be sold, labeled or represented as organic.
The NOP Livestock health care practice standards state:
205.238(b) When preventative practices and veterinary biologics are inadequate to prevent sickness, a producer may administer synthetic medications: Provided, that, such medications are allowed under 205.603. Parasiticides allowed under 205.603 may be used on:
1. Breeder stock, when used prior to the last third of gestation but not during lactation for progeny that are to be sold, labeled or represented as organically produced; and
2. Dairy stock, when used a minimum of 90 days prior to the production of milk or mild products that are to be sold labeled, or represented as organic.
205.238(C) 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, any substance that contains a synthetic substance not allowed under 205.603, or any substance that contains a nonsynthetic substance prohibited in 205.604.
The standards are pretty clear. If it is not listed as allowed, it is prohibited. You must remember that even if a product says that it’s “all natural” or “safe for use in organic production” this may not be the case. All ingredients must be checked before a product can be used.
These are tough standards and making a mistake when it comes to giving your animals a feed or healthcare supplement can be extremely costly! The most important thing to remember is to always check with your certifying agency before giving/using any new product in your operation. It will save many headaches down the road!
You may access information regarding the National Organic Program Final Rule and the FDA approved feed ingredients at the following websites:
www.fda.gov/cvm/animalfeed.htm
http://www.ams.usda.gov/nop/indexIE.htm
www.ocia.org
Please send me your questions! All submissions will be reviewed and questions selected at random to be answered in each issue.
Send inquiries to: Maralee Maldavs ; mmaldavs@ocia.org
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