Under the “access to pasture” rule, producers wishing to market dairy products under the USDA’s National Organic Program (NOP) must provide livestock with year-round access to the outdoors.

They also must recognize pasture as a crop, establish a management plan for pasture, incorporate the pasture management plan into their organic system plan, provide livestock with pasture throughout the grazing season for their geographical location (but no less than 120 days), and ensure livestock derive no less than 30 percent of their dry matter intake requirement from pasture grazed over the course of the grazing season. This rule became effective June 17, 2010, and was to be fully implemented by June 17, 2011.

The USDA’s Office of Inspector General (OIG) recently reviewed how the Agricultural Marketing Service (AMS) implemented this rule for organic dairy cattle and assess compliance with USDA organic regulations.

The OIG found AMS generally implemented the access to pasture rule, but identified several areas where the agency could make improvements. These include:

  • NOP officials had not clearly defined how producers should demarcate herds of organic milk-producing cattle, which means some certifying agents allowed producers to add cattle to organic herds. Once a conventional dairy herd is converted organic, all dairy animals added to the herd must have been born to an organically managed cow.
  • The NOP needs to include organic feed brokers within the NOP certification process to ensure that organic feed is not commingled or contaminated.
  • Certifying agents conducting yearly inspections of organic milk operations did not take consistent enforcement actions when their inspectors or reviewers identified possible noncompliance issues with USDA organic regulations.
  • Smaller operations were often unaware of recordkeeping requirements of the access to pasture rule regarding livestock confinement, grazing, or the cattle’s dry matter intake.

AMS concurred with all of the recommendations.

The full report is available online from USDA/OIG.