NOP Requires Grazing

Summer 2010
By Gwyneth Harris, dairy certification specialist, MOFGA and Diane Schivera, M.A.T., organic livestock specialist, MOFGA

The National Organic Program’s new Pasture Rule becomes law on June 17, 2010. It will be enforced for currently certified producers on June 17, 2011, while new applicants for livestock certification must meet all aspects of the new rule when they become certified. Those who are adding livestock after June 17, 2010, to their currently certified land also need to comply immediately.

The pasture provisions apply to all ruminant livestock, including beef, dairy cattle, goats, sheep, bison, water buffalo, deer, llamas and alpacas. Producers of non-ruminant livestock (poultry, pigs) are affected by new provisions for feed, supplements, living conditions and outdoor access.

One notable point is that all agricultural products used for bedding, except wood products and sand, must be certified organic.

The rule begins by defining terms used in the rule, including but not limited to pasture, grazing season, inclement weather, stage of life, dry matter and shelter, residual pasture, yard or feeding pad.

Key requirements for all ruminant animals over 6 months of age are that they must graze enough to obtain a minimum of 30 percent of their dry matter intake from pasture; they must graze for 120 days or longer each year; and they must have year-round access to the outdoors. In other words, not more than an average of 70 percent of a ruminant’s dry matter demand can come from stored feed over the entire grazing season.

Farmers will now have to provide information about their animals’ dry matter intake on their certification applications. This can be calculated by using the winter ration as the base number. MOFGA Certification Services LLC (MCS) is creating new Organic System Plan and Inspection Reports to accurately collect the information necessary to track grazing, forage and grain rations.

Your Organic System Plan (OSP) must now include:

• grazing systems and methods – mob grazing vs. intensive rotational vs. limited rotations vs. extensive grazing with no rotation – and how you ensure enough edible forage through the grazing season;

• maps showing fences, water sources, the barnyard, lane ways, areas of erosion control and of wetland/riparian protection;

• an outline of your summer and winter rations (average) described in such a way as to be able to track dry matter intake from pasture, including any significant variations in your feeding/ration that reflect changes in the grazing forage available over the season.

Some other important changes are:

• All livestock over 6 months of age must have outdoor access, even in winter;

• After 6 months of age, dairy calves must be housed/grazed in groups;

• Animals may be confined only for very specific reasons, which are defined in some detail in the rule, including:

inclement weather, defined as weather that might cause physical harm (e.g., sleet). Weather that lowers the production rate of the animal below its maximum is not considered inclement; conditions that jeopardize animal health and safety (e.g., icy barnyard);

risk to soil/water quality (e.g., prolonged muddy spell);

preventive health treatment;

sorting or shipping of animals;

for dry-off of dairy animals, for up to 1 week; and up to 3 weeks pre- and one week post-parturition;

for shearing fiber animals (for short periods).

Confining slaughter stock is prohibited, as is denying them access to pasture. However, they are exempted from the 30 percent/120-day requirement for up to one-fifth of their lives, or 120 days (whichever is shorter) for finishing. For example, they may be fed, in a dry lot, a ration exceeding 70 percent of their total dry matter intake, but they still must have access to edible pasture during the grazing season.

FAQs about the New Pasture Rule

What if it rains from April through July, and I can’t get my animals on my pastures? How do I make up the 120-day grazing season in just three months?

§205.239 allows confinement of an animal because of (b)(4) Risk to soil or water quality. You can also request a temporary variance from MCS/NOP, under §205.290 (a) (2), if this is a generalized weather pattern or “state of emergency” (i.e., flooding, drought) affecting a larger region.

A cow has been injured and in the hospital pen for a month and a half – how can she ever meet the 30 percent, 120-day requirement?

As above, temporary confinement, under 205.239(b)(5) Preventative healthcare procedures or for the treatment of illness or injury.

I don’t know how to calculate dry matter. How can I find out what is in my feeds without complicated calculations or expensive sampling?

Dry matter is the actual dry weight of feed, after water has been removed. Do a simple test: Take a given weight of feed (silage, pasture, hay, etc.) and dry it overnight in your oven, using the lowest possible setting. Weigh it again, and calculate the percentage of the initial weight. For example, if 1 pound of haylage weighed 1/2 pound after drying, then this batch of haylage is 50 percent dry matter (0.5 lbs. dry/1 lb. wet = 0.5 x 100 = 50 percent).

There are also published numbers for average dry matter for different feeds if you don’t want to measure actual dry matter.

Knowing the dry matter content of your feed can help you better balance your ration and may already be provided to you if you use a nutritionist to balance rations or send forage samples to be analyzed.

What is the difference between Dry Matter Demand (DMD) and Dry Matter Intake (DMI)?

Dry matter demand is an estimate of how much feed your animals will need. DMD is most likely to be a value from a table of charts, or provided by a nutritionist. At the most basic level, it will take into account the type of animal (cow vs. goat), class of animal (growing lamb vs. milking ewe) and size of animal (Jersey vs. Brown Swiss). Unless you have a strongly seasonal dairy herd, you will probably take an average DMD for the whole season of your always-changing herd composition. However, it is important that you choose a number that best represents your herd. Again, MCS will provide a set of values for you to choose from, or you can use values provided by a nutritionist.

Dry matter intake is what your animals actually eat. The DMD number provides a baseline of what to expect a given group of animals to eat – DMI actually measures the average summer and average winter rations. Your OSP will ask you to show how many pounds of each type of feed you are giving to each group of animals. For those who feed TMR, this information should be easily available. For folks who feed out round or square bales on an “as needed” basis, expect to keep track of what you are feeding (how many bales, how often and to how many animals in each group).

How will I know if I am meeting the 30 percent DMI required from pasture?

The DMI for your animals will be calculated as an average for the entire grazing season and the entire non-grazing season. Your part in this is collecting the right numbers for use in your OSP. Worksheets will be provided that will break down the ration for each age class of animals (i.e., heifers 6 months to 1 year, dry cows, milkers, bred heifers). MCS can do the final calculations for you or assist you, and simple formulas will be on the worksheet to help you. Basically, the DMI in winter is taken as a base and should be close to the DMD that you chose. The summer ration list will include only fed feedstuffs. If this is subtracted from the winter ration, the remainder not fed (i.e., grazed from standing, clipped, or residual forage in the field) is the estimated DMI from pasture.

How do I decided what my grazing season is?

This should include two sets of numbers: first, the dates when your animals have access to pasture – e.g., out of the barn May 5, back into the barn/barnyard access only on December 15; second, the dates when your animals harvest a significant portion of their feed from pastures. This will ensure that you are not penalized for keeping the animals on pasture during times of the year when DMI is minimal (i.e., if you stockpile forage, go to extensive grazing, or graze limited late-season crops from September 30 through December 15, but realize only about 10 to 15 percent of your DMI through this time). This second set of numbers allows us to calculate DMI from pasture during the primary grazing season. Using the full “pasture access” season might significantly lower your average DMI from pasture by including low DMI times when transitioning onto or off of pasture.

If any of the below apply to the livestock management on your farm, you need to take a close look at your pasture system:

• Your total animal units (1,000 pounds of live weight) are more than 1 or 2 per acre;

• You are feeding a similar ration in the barn winter and summer;

• You are not rotating pastures or have only “night” and “day” pastures, and have less than 2 or 3 acres per animal;

• Your young stock over 6 months of age have not been a part of any pasture rotation or have limited pasture access;

• Your animals are off pasture for more than half of any 24-hour period (including milking and barn or bunk feeding);

• Your own rough calculation of DMI is below 40 percent;

• You have periods of the summer when you are extremely short on forage, due to soil or local climate variations;

• Your grazing season is around 120 days and could fall below that in an unseasonably but not extremely dry, wet or cold year;

• You commonly fill in periods of low production by feeding extra grain, hay, etc., in the barn. (This will probably be a concern only if you are close to being below 30 percent DMI from pasture.)

MCS will be sending out a variety of forms and worksheets to help develop record-keeping strategies and a grazing plan for next year. It is critical to evaluate your pasture system this season, because enforcement begins at the beginning of the 2011 season.

Many resources are available to help develop or improve a pasture system to work with this new rule, including:

Diane Schivera, MOFGA, organic livestock specialist, 568-4142, [email protected]

Rick Kersbergen, University of Maine Cooperative Extension, 1-800-287-1426, [email protected]

Dee Potter, University of Maine Cooperative Extension, 1-800-287-1421, [email protected]

Maine Grass Farmers Network,

USDA Natural Resources Conservation Service. Contact your local field office.

What’s the best thing about the new rule? Improving your grazing system may save you money and labor!

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