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CCOF Launches Innovative Pasture Compliance and Feed Audit Inspection Program

by Jake Lewin |
To support organic integrity and ensure compliance with the National Organic Standards pasture rule for ruminant animals, CCOF is introducing a new Pasture Compliance and Feed Audit inspection program (PCFA). 
On May 15, 2017, CCOF published a Certification News article titled “Dairy Grazing Season Clarification.” This notice reiterated expectations for certified operations, in addition to identifying areas where we planned to add additional focus on in the next year. In addition, the National Organic Program (NOP) published an Organic Oversight and Enforcement Update on May 24, 2018, which announced the initiation of a pasture surveillance project in which the USDA conducts unannounced visits to assess compliance with the pasture standards. CCOF’s program will allow us to support the NOP’s efforts and provide more robust information if requested.
CCOF has always taken compliance with the pasture rule very seriously and will continue to do so. CCOF pioneered the Livestock Unannounced Compliance Initiative inspections (LUCI) and has used these to ensure verification of grazing and other management practices. These LUCI inspections will continue as they provide a type of observation that is not possible with a scheduled inspection. However, in our assessment, and in conjunction with the NOP’s initiative, CCOF found a need for an additional schedule-based inspection option that is focused on an area that is difficult to fully assess in the context of a single annual inspection per year.
The Program
The Pasture Compliance and Feed Audit (PCFA) inspection program launches July 1, 2018 and is an improved approach to pasture rule compliance. We will perform between one and three additional pasture rule-focused inspections at operations whose complexity, sophistication, and/or climate place them at increased risk to compliance. We expect to perform approximately between six and 10 of these inspections overall at fewer than 10 operations each year, with flexibility as we learn throughout the process.
PCFA inspections are scheduled to ensure that both the operator and inspector have enough time and preparation to fully review the operation’s system. This increases CCOF’s commitment to organic integrity by: 
  • Having an inspector observe a pasture management plan during additional time(s) during and/or after the grazing season;
  • Ensuring a better assessment of days-on-pasture;
  • Allowing sufficient time to directly observe the pasturing system in detail including review of actual milking and pasture movement;
  • Allowing for thorough audits on each class of animal;
  • Supporting appropriate time for verification of records of feed as fed to all production groups/classes for both the grazing and non-grazing season.
PCFA inspections will be timed to occur during the grazing season to observe pasturing systems. Alternatively, they may occur after the grazing season to fully review records and assess compliance with the appropriateness of their grazing season to their region (minimum 120 days) and 30 percent DMI requirements of the standards.
Operations subject to these inspections will be informed proactively and receive the same notifications as standard inspections. Operations are encouraged to prepare for these inspections by requesting and reviewing a copy of the inspection report template.
We believe CCOF-certified operations are doing an excellent job with pasture utilization and compliance. Additional inspections will help us work together to ensure that there are not inadvertent mistakes or areas of potential improvement, and support CCOF having a fully comprehensive understanding of the operation’s system. These efforts, along with our LUCI inspections, are the central focus of our livestock program in 2018. They contribute to a level playing field and will be appropriate to the scale of the operation and the complexity of the rule itself. 
Visit for more information about the pasture rule and to view helpful CCOF resources.