May 15, 2017
To all CCOF-certified dairy producers,
We appreciate the incredibly hard work and dedication it takes to operate an organic dairy.
Many of you are aware of media reports regarding pasture practices at a dairy in Colorado. We are not aware of any information beyond those reports. However, we are committed to maintaining consumer confidence in organic, and promise to do our part to ensure your hard work is not in vain. As we progress through the grazing season this year, we thought it appropriate to reiterate our expectations regarding grazing practices under the USDA National Organic Program Standards.
The intent of the organic livestock standards is to provide a healthy pasture-based system ensuring maximum grazing throughout the grazing season for organic animals. Operations should not prevent, withhold, restrain, or otherwise restrict ruminant animals from actively grazing pasture during the grazing season except for specific conditions such as inclement weather, animal health and safety, or the animal’s stage of life. Importantly, we will be monitoring and working with operations to ensure that they make full use of their regional grazing season, pasture potential, and the resources and tools available to ensure a robust grazing system.
Due to variance in geographical pasture systems, and to guarantee that organic ruminants receive at least 30 percent of their diet from pasture during the grazing season, minimum pasture requirements were set in the National Organic Standards. To prevent minimums from becoming the bar, operations are required to maximize grazing potential as appropriate to the region and climate. Additionally, they cannot withhold pasture from ruminants unless specific conditions are met. Operations with unique conditions, access to irrigation, or who are subject to weather and pasture health that supports grazing outside the anticipated grazing season or after 120 days are expected to make use of those opportunities to the fullest extent possible.
If temporary confinement is used, the reasons for confinement must be outlined in your Organic System Plan approved by CCOF, and documented when confinement occurs.
Over the next 12 months we may focus inspections on pasture observations and verify appropriateness of the grazing season based on the operation’s unique conditions, location and resources. All organic operations should have systems in place to ensure optimal grazing. Operations should also ensure records regarding confinement from pasture during the grazing season are maintained, complete, and sufficient to verify compliance with the standard. We understand that every operation is unique, every region has unique challenges, and every year has changing climatic conditions. These nuances underscore the significance of good records that document these instances.
We are happy to work with you to address specific concerns or discuss your situation as each year evolves. If you have any questions, please contact the CCOF Livestock Department by reaching out to your certification service specialist.
We value the work you do and hope to make it meaningful for years to come.
 Allowed reasons for temporary confinement under the USDA Organic Standards are described in 205.239(b) and (c.)
 See 205.237(b)(8) of 205.239(b) and (c).