Need a quick reference guide for how to get started with understanding organic rules for livestock feed, supplements and nutrition? Oregon Tilth’s condensed Quick Start Guide series is designed to answer your big questions quickly, give examples and point to helpful tools to get started
Quick Start Guide:
Feed and Supplements
for Organic Livestock
Oregon Tilth’s Quick Start Guide series is designed to provide
clients with all of the basics necessary to jump right in and get
started on certification-related actions immediately.
Oregon Tilth | (503) 378-0690 | www.tilth.org
Feed and Supplements
For Organic Livestock
Decoding livestock feed and supplements in organic production requires knowledge of
calculations, special circumstances and how to meet the nutritional needs of your animals
while still remaining compliant with the standards. This Quick Start Guide for Feed and
Supplements for Organic Livestock is intended to ask (and answer) the most important
questions as well as provide you with mini case studies, templates and tools to use when
starting the process on your own.
Important
questions & guidelines:
What
can I feed my
organic
livestock or
poultry?
What
is the National
List and how
does it affect
what I feed
my organic
livestock?
What
can’t I feed
my organic
livestock or
poultry?
What’s
the difference
between a feed
supplement and
a healthcare
input?
What
are some tips
for working
with my
certifier, feed
supplier and
nutritionist?
What
are some feed
ingredients
with unique
considerations?
Where
can I find
more about
organic animal
nutrition?
Let’s get started!
_ __
Oregon Tilth | (503) 378-0690 | www.tilth.org
What can I feed My organic
livestock or poultry?
Understanding the make up of feed – from agricultural ingredients (forages,
concentrates), supplements and additives, and other ingredients to improve
delivery (palatability, efficacy) – is critical under organic standards. Feed for
organic livestock must be composed of certified organic agricultural products;
this includes all agricultural ingredients in feed supplements or additives. The
two biggest takeaways from this guide are to be thorough in understanding your
labels and always check with your certifier before using an unapproved feed in
your operation.
defined:
1
2
3
Feed
feed
additive
feed
supplement
Edible materials which are consumed
by livestock for their nutritional value.
Feed may be concentrates (grains)
or roughages (hay, silage, fodder).
The term, “feed,” encompasses all
agricultural commodities, including
pasture ingested by livestock for
nutritional purposes.
A substance added to feed in
micro quantities to fulfill a specific
nutritional need; i.e., essential
nutrients in the form of amino acids,
vitamins, and minerals.
A combination of nutrients added
to livestock feed to improve the
nutrient balance or performance of
the total ration and intended to be:
•
•
•
Diluted with other feeds when
fed to livestock
Offered free choice with other
parts of the ration if separately
available
Further diluted and mixed to
produce a complete feed
Oregon Tilth | (503) 378-0690 | www.tilth.org
What can I feed My organic
livestock or poultry?
The National Organic Standards on livestock feed, §205.237, can be fairly complicated.
Here are the key requirements broken down:
Feed for livestock must be composed of
certified organic agricultural products.
A feed ration must be composed of Certified Organic
Agricultural products, e.g. any agricultural products
being used in a feed are required to be certified
organic. Examples of agricultural ingredients include:
grains (e.g. corn, oats, barley), meals (soybean meal,
cottonseed meal), hay, silage, fodder, and pasture.
Feed rations may include allowed National
List synthetic materials as feed additives or
feed supplements.
The only allowed synthetic feed additives on the
National List are DL-Methionine, used in poultry
rations at a specific amount per ton for each species
of poultry; and trace vitamins and minerals, used for
enrichment or fortification when FDA approved.
• Additives are to be fully incorporated into a ratio
& used in minimal quantities.
• Supplements may be incorporated into a ration,
but may also be provided as a free choice option
(e.g. a mineral block for cattle).
• A supplement may include a feed additive as an
ingredient (such as trace minerals in a premix).
Any agricultural ingredients used in feed
supplements or additives for organic
livestock must be certified organic.
Whether using a purchased feed supplement product
– which must identify all agricultural ingredients as
organic on the ingredient statement – or if you are
mixing a supplement yourself, you need to be sure
you document and use organic agricultural ingredients
only. This includes carriers or binding agents such as:
molasses, wheat middlings, rice hulls, and vegetable
oil.
Feed rations may include non-agricultural
nonsynthetic (natural) materials as feed
supplements that are not prohibited or
certified organic.
Provided there is nothing in the Rule and National List
that prohibits it, you can use a non-synthetic, nonagricultural material in feed rations. Examples include:
blue-green algae, diatomaceous earth, kaolin clay,
fishmeal, probiotics and enzymes.
TOOL TIPS: ENSURING A PRODUCT IS APPROVED FOR USE AS FEED (BEFORE YOU USE IT)
Oregon Tilth can help you determine if a feed product is approved for use within the regulations. Check with the
Organic Materials Review Institute (OMRI) – Oregon Tilth is a co-founder – and the Washington State Department of
Agriculture (WSDA) to see if a product is usable. Always check with us prior to use to verify that it is acceptable for
your organic production.
OMRI Website | WSDA Website
What is the National List & How
does it affect my livestock?
The National List specifies any synthetic materials that may be used in organic
production or processing and what it can be used for, as well as any non-synthetic
(also called natural) materials that are prohibited from use.
W h y d o e s i t m at t e r ?
The National List provides the only allowable synthetic materials for use in your production for specific
purposes. All feed rations and feed ingredients must comply with the National List in order to be used
in organic livestock production.
How do I determine specific rules
for livestock production?
Sections §205.603 and §205.604 are specific to livestock production – 603 lists all allowed synthetic
materials for organic livestock productions, with specifics about restrictions on their use, while 604
provides a listing of all prohibited non-synthetic materials (currently strychnine is the only listing). Any
substances on 603 listed as feed supplements or feed additives may be used in organic livestock feed,
in accordance with any annotations they carry. Be sure to match any supplement or material to your
intended use. For instance, a material listed as an allowed “topical treatment” on this list may not be
allowed for feed use.
What types of things are
on the National List?
§ 205.600-606
Section of the National Organic Standards that lists the allowed
and prohibited inputs for the different scopes of organic
production. Basically, any non-synthetic substances are allowed
in organic production and handling unless they are on this list as
prohibited, and all synthetic substances are prohibited unless
they are on this list as allowed.
§ 205.603
Lists allowed synthetic materials for organic livestock
production, including any annotations that restrict use.
§ 205.604
Lists prohibited nonsynthetic (natural) materials.
TOOL TIPS: UNDERSTANDING THE NATIONAL LIST
The National List is not fixed – it may be amended to
add or remove products, or to change a restriction,
by National Organic Program (NOP), based on
recommendations from the National Organic Standards
Board (NOSB). NOSB is a federal advisory committee,
and they depend on organic stakeholders – yes, you! –
to share comments, experience and expertise through
a public comment process so the NOSB may make
informed decisions about materials. Learn more about
the current National List and how you can petition the
NOSB to have materials added, changed or removed
from the list.
What’s the difference between Feed
supplements & Healthcare Inputs?
Certain products could be considered either feed ingredients or healthcare
materials – they may provide nutritional value as well as a health benefit.
S o w h y d o e s i t m at t e r
h o w t h e y a r e c l as s i f i e d ?
1
Feed supplements
must meet the organic livestock feed requirements,
including use of certified organic agricultural ingredients.
2
Healthcare materials
are not restricted by the livestock feed requirements,
and may use non-organic agricultural ingredients.
Wh at does this r eally mean ?
wh at d o e s t h i s r eal ly m e a n ?
Some products can be classified as a feed supplement or a
healthcare product, depending on how they are marketed
or used. They might be used to provide nutritive value in
the diet or used periodically to treat, mitigate and prevent
disease. These products tend to blur the line between feed
and healthcare products. This is further complicated because
feed supplements must use only certified organic agricultural
ingredients, but healthcare products are not required to have
agricultural ingredients be organic.
Certifiers take into account how a producer will be using a
product. For instance, if a producer wants to use a product as
part of the feed ration in order to meet the nutritional needs
of the animal, then it would be considered a feed ingredient
and would need to meet the feed requirements. But, if the
producer used it specifically to treat a periodic health concern
and did not administer it to all animals with regularity, then it
would be reviewed under the healthcare standards.
Mini Case study
Healthcare input versus feed supplement
Let’s examine a specific and unique example. A farmer requested the use of a kombucha product as both a feed
supplement and a healthcare treatment for his dairy cattle. When we reviewed the ingredients list, we found that they
were using a number of certified organic ingredients, but had one non-organic ingredient (sugar). We were able to
approve it for periodic health treatment use for his cattle for digestive health under the healthcare input standards, but
we did not approve it as a feed supplement. The farmer is now working with the kombucha manufacturer to get the
product certified organic so he may re-submit it to us for use as a feed supplement in the future.
What ARE some feed ingredients
with unique considerations?
Ke l p Me a l
Y eas t + Bact e ria
C u lt ur es
Kelp is an agricultural product per the National
Organic Program and must be certified organic for
use in livestock feed
Yeast and bacteria cultures used in livestock feed
do not require organic certification but do require
non-GMO verification
fis hme a l
M et h i on i n e
Several fishmeal products are preserved with
ethoxyquin — a synthetic material not allowed in
organic production — and other compounds that
might require certifier verification
Fish and crab meal are the only acceptable animal
protein sources of methionine in organic livestock
feed rations, so it is allowable as a synthetic feed
additive at a specific rate per ton of feed.
TOOL TIPS: MAINTAINING COMPLIANCE AND GETTING CERTIFIER APPROVAL
Compliance through communication
Communication with your certifier about
your feeding program will prevent you
from making a costly mistake that could
potentially disqualify your animals from
organic production or jeopardize your
certification.
All inputs must be reviewed and approved
by your certifier prior to use
Compliance through recordkeeping
Compliance through recordkeeping
Records provide verification and
demonstration of feed and supplement
compliance, such as: production and harvest
records for farm grown feed, purchase
records, organic certificates for purchased
organic feed and edible bedding, feeding
records by production group, feed labels,
and documentation for ruminants to verify
the Pasture Rule compliance
Compliance through OSP
Update your OSP when: Implementing
any significant change to your feed rations,
such as: new feed additives or supplements
or changing rations during grazing season
(ruminants) that may effect your DMI from
pasture, changes to the sources of agricultural
ingredients, or adding a new production
group that requires new rations.
What can’t i feed my organic
livestock or poultry?
The National Organic Standards §205.237(b) specifies what
organic producers cannot do with regard to livestock feed.
PROHIBITED
•
•
•
•
•
•
•
•
Synthetics that do not appear on the National List
Drugs, including hormones, to promote growth
Feed supplements or additives beyond the animal’s
nutritional needs
Anything that violates the Federal Food, Drug and
Cosmetic Act
•
•
Plastic pellets for roughage, urea or manure
Mammalian or poultry slaughter by-products to
mammals or poultry, including blood, meat, or
bone meal, bone charcoal, and substances that
are derived from slaughter byproducts like Vitamin
D3 and gelatin
Any minerals that have been proteinated or derived
from slaughter by-products or GMOs
Premixes/vitamin-mineral packs that have not been
reviewed by your certifier or OMRI
Non-certified organic kelp
Using a temporary variance to provide non-organic
feed or other inputs that are required to be from
certified organic sources
•
•
Antibiotics or ionophores
Preventing ruminants from grazing pasture during
the grazing season per the requirements of the
Pasture Rule, §205.237(c) and §205.240
MINI CASE STUDIES
Dissecting a noncompliant feed ration
Red flags when looking at a feed tag or ration sheet:
• Agricultural ingredients that are not identified as organic
• Synthetic substances that are not on the National List
• Certified organic products intended for human consumption – beware, they may not necessarily
be compliant for livestock feed
tips for working with
certifiers & Feed suppliers
Creating a common language
It can be a challenge for you (farmer) to speak the same language as your certifier,
nutritionist or feed suppliers when it comes to discussing organic feed requirements.
A few things to keep in mind:
Nutrients + vitamins + minerals
a re n ot a l l c r e at e d eq ua l :
Feed
organic
Supplier
certifier
Thinks in terms of nutritional content of
the final mixed ration and is unconcerned
with which ingredients are used to get
these nutrients.
Thinks in terms of where nutrients are
coming from (which ingredients are used),
and if the ingredients are compliant with
the organic regulations.
Both viewpoints are necessary ways of looking at organic livestock feed in
order to maintain high quality animal nutrition and organic compliance. Keeping
both of these perspectives in mind when talking to your certifier and your feed
supplier/nutritionist will give you much needed context for those conversations.
Feed ingredients and healthcare products are both important aspects of your
animals’ well-being, and can be viewed as part of one holistic approach, but
healthcare inputs must be reviewed and documented separately from feed in
order to maintain compliance.
tips for working with
certifiers & Feed suppliers
avoiding usual mistakes
The biggest and most expensive mistakes can easily be avoided just by communicating
with your certifier whenever you are unsure about a substance, material or product.
A few things to keep in mind:
ensure organic ingredients
me e t t h e N O P Sta nda r d s
c o n ta c t
organic
Feed
certifier
Supplier
Always double check a product not just
based on ingredient listings but also against
your certifier and / or a material review
organization like OMRI or WSDA
Develop relations with your product
salespeople and nutrition advisors that your
production is certified organic and requires
excellent documentation for compliance
Assuming that a salesperson’s understanding of “organic” ingredients
meets expectations of the NOP is an preventable pitfall.
tips for working with
certifiers & Feed suppliers
Be patient & open with your certifier
Certifiers are tasked with decoding and clarifying enormous quantities of ingredients in thousands of products, materials
and supplements. Sometimes it can take time to work with a manufacturer to get a clear understanding of a product.
Sometimes it requires consulting others to ensure consistency in certification approaches to a particular material.
You can help by:
c o n ta c t
organic
Feed
certifier
Supplier
Check in with your certifier prior to using
any new unapproved or unknown material
Give specific details about materials, good contact
information and even pose the first questions
to your manufacturer to get the ball rolling
It’s vital to understand that even a small amount of a prohibited substance is
enough to void your certification. Certifiers, material review organizations
and others should be viewed as support structures to helping guide you
through decisions before making a mistake. It’s generally a good rule to:
• Check twice and then ask a lot of questions for any material
• Rely on your certifier to determine allowable versus prohibited
where can i find out more about
organic animal nutrition?
The NOP rule §205.238(a)(2) provides vague guidance for what “sufficient” feed rations in terms
of meeting nutritional requirements can and should be. Nutritional guidance ought to be found
through a variety of peer-reviewed or quality third-party sources.
A few examples include:
• Organic Livestock Producer Guide (from NOP Handbook)
• Nutrient Requirements of Dairy Cattle
• Feed Stuffs Magazine (Reference issue on all species)
• Morrison’s Feeds and Feeding Reference
• ATTRA/NCAT
TOOL TIPS: ADDITIONAL RESOURCES
• Livestock, Nutrition, Husbandry, and Behavior
• eOrganic
• Oregon Tilth Webinar: The Pasture Rule
• USDA National Agricultural Library,
Alternative Farming Systems Information Center
Oregon Tilth | (503) 378-0690 | www.tilth.org
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