Taking the organic leap

CHIPPEWA FALLS, Wis. — Becoming certified for organic dairy production may seem overwhelming, Emily Fowler said, but if taken step-by-step, it does not have to be.

Fowler, the certification director for Nature’s International Certification Services, shared this message at Marbleseed’s Organic University, March 26 in Chippewa Falls.

“I was a certified organic dairy farmer starting in 2006, and was conventional before that,” Fowler said. “I was not born into a farming family, I came to dairy farming by choice.”

Moving from the perspective of organic production into organic inspection and certification gives her unique perspective of the process, Fowler said.

“I really do understand what certification feels like at the farm level,” she said. “Certification can be a little wordy, but it’s based on regulation and law. This whole movement happened starting with the passage of the Organic Foods Production Act of 1990, which gave authority to the National Organic Program.”

The past three years have included a series of major regulatory changes in organic production, which impact dairy transition, Fowler said.

Fowler said organic compliance is broken into two parts — the initial certification, and recertification, which needs to be completed by the producer’s certification anniversary date each year.

“Recertification is really important because in NOP certification, your certificate does not cease or expire unless it is surrendered, suspended or revoked,” Fowler said. “It’s really important to understand that while it doesn’t expire, you are required to go through the recertification process, annually. The inspector is going to verify that what you have on paper is what is happening in practice, on-farm.

In both the initial certification and recertification process, Fowler said the role of the inspector is to verify that activities are as stated in the organic system plan, which she described as the backbone of an organic application.

“They’re going to bring up concerns if they see a disparity or a potential compliance issue,” Fowler said.

The organic system plan details practices and procedures adhered to, as well as the inputs that are used on the farm Fowler said. Monitoring practices and procedures, including the frequency at which they will be performed are laid out, as well as a description of the recordkeeping system implemented. The plan also includes a description of management practices and physical barriers established to prevent contact of organic production and products with prohibited substances.

“Having a practices and procedures (plan) in place to protect the organic integrity of your operation and products is a big responsibility for organic farmers,” Fowler said. “It’s not something all realize when they enter into it. There are not mechanisms out there in the world that protect us, sometimes it’s the opposite.”

One of the first concerns a producer should consider when contemplating a transition from conventional to organic production is sourcing livestock Fowler said. She said regulations regarding sourcing have changed recently.

“When you’re new or transitioning, you have two options,” Fowler said. “You can purchase or raise organic animals, or you can transition non-organic animals to organic production, once. Once the certification is complete, you may only add animals that have been organically managed from the last third of gestation. You cannot source transitioned animals from another operation. Transitioned animals are certified organic for the products they produce, meaning their milk and offspring. They are not certified for their body or meat.”

Fowler said for an animal to be considered transitioned, they must be under continuous organic management for a minimum of 12 months prior to the production of milk or milk products that are to be sold, labeled or represented as organic.

Sourcing organic feed, particularly through the transition period, can be challenging, Fowler said.

During the 12-month transition period, dairy cattle and their offspring can consume third-year transitional crops from land included in the organic system plan of the operation the transitioning animals are a part of. Fowler said one transitioning farm cannot use feed from another transitioning farm.

The grazing dry matter intake requirement of organic production plays into the feed requirements, Fowler said. Ruminant animals are required to be grazed for the entirety of the grazing season, in their geographical area — at a minimum, 120 calendar days per year. During that time, not more than 70% of their dry matter needs are to be provided, rather they must get it from pasture or forage.

Practices for livestock care and production need to be determined, including preventative health care practices, medications and parasiticides, parasite control plans and euthanasia protocols, Fowler said. Administration of vaccines and other veterinary biologics, along with all necessary surgical procedures are to be done using best management practices to promote an animal’s wellbeing, and to minimize pain, stress and suffering. Housing must be provided with sufficient sanitation practices to minimize the occurrence and spread of disease and parasites.

Everything in organic production, both for initial certification and for recertification, hinges on recordkeeping, Fowler said.

“When I was an organic dairy farmer, I really began to see the recordkeeping as beneficial for me as a business owner, farm manager and a certified operation,” Fowler said. “The beauty of it is, the rules don’t tell you how you have to keep records. You can make it work for you, whether you like paper, using a computer or having everything on your phone. There are lots of tools out there that can make recordkeeping painless and efficient.”

In a process that can feel overwhelming, Fowler said producers should step back and remember why they are choosing to be organic certified.

“The whole idea of organic is very consumer-driven,” Fowler said. “The rules to ensure integrity seem strict and stringent, but people want organic products. And it is our responsibility to ensure we can meet the highest of standards.”