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Newsletter of Penn Dutch Cow Care October 2008

Hi Folks,

Just a quick reminder to wait for any frost to lift before sending animals out to legume pastures and to try to feed them something before going out there so they won’t greedily eat legumes and bloat.

This month I’d like to talk about some aspects of the organic certification process. I have recently been involved with some farmer client concerns about materials for livestock healthcare. It is obvious that farmers can become very frustrated about the way things go in the realm of certification issues. In this newsletter, I am speaking only as an advocate for the farmers I work with in regards to certification issues and related questions you bring up when I am on the farm or over the phone. (I just need to be clear that I am not speaking in this newsletter as Chair of the Livestock Committee of the USDA National Organic Standards Board.) There are 90 USDA accredited certifiers across the globe – about half are located here in the United States. Farmers can choose freely among. They are all equal in the eyes of the USDA. This means that when a farmer has a valid certificate from an accredited certifier, a milk processor can legally accept the certified organic milk produced on that particular farm.

As most of you know, the first inspection is generally the most rigorous with the following annual inspections generally update and verify the already certified operation. The Organic System Plan (OSP) is the legal mechanism by which a certifier looks at a farm and is the way to make sure that the farm is constantly improving every year. All materials that you regularly use or that you may potentially use must be on the OSP. If you use a material that you have not placed in the OSP, the certifier can declare a non-compliance. They can demand that you address and correct the situation within whatever time frame they decide. For dairy farmers, this applies to any soils, crops and livestock materials. From some recent discussions with a few certifiers, the name brand of all products on the OSP must be shown, not only the general category. In other words, on the OSP you cannot simply say that you will use electrolytes for milk fever cases - you must state exactly which brand of electrolytes you will be using to treat potential milk fever cases. Some certifiers have lists of materials that they have reviewed whereas other certifiers do not. If possible, always use materials that have the OMRI seal of approval since OMRI is the gold standard in material reviews. The USDA has recently recognized OMRI as an official private agency of outstanding and exceptional integrity. Many private certifiers already rely upon OMRI for their own material reviews. However, it should be stated that if a material is not on the OMRI list it does not mean that the material is not necessarily prohibited – this is an important point to remember. This means that if a certifier says a material is not OMRI certified and that the certifier will then not allow it, you can lodge a complaint to the USDA about that certifier. If needed, I will help you do that if I feel there is a good and strong professional relationship with you i.e. a valid veterinary client patient relationship (VCPR).

Now I’d like to cite some specific examples of current frustrations that some of you have had. The other day a farmer asked me what the status of calcium for milk fever was in regards to treating milk fever cases. As most of you know, I always write down “electrolytes” on a bill if I am called to treat a milk fever. This is because electrolytes are completely allowed according to the law (7CFR205.603). However, if you keep bottles of calcium in your cabinet, the certifier’s inspector can write down which you have and the certifier may potentially review each and every ingredient in them since calcium products have never gone through the official approval process and therefore never have gotten FDA NADA status (New Animal Drug Approval). FDA NADA status ensures that a medicine will perform effectively without harm to the patient if used correctly. Some examples are Naxcel®, Micotil®, Lutalyse®, Cystorelin® (all these are prohibited for use on organic farms by the way.) Calcium products have been grand-fathered into the entire dairy industry just as aspirin, activated charcoal and propylene glycol have been. If a material has FDA NADA status and are allowed for use in organic livestock, as flunixin is (i.e. Banamine®, Flunixamine®), then all stabilizers and excipients in that product FDA NADA product are allowed. But if a material allowed in organic livestock health care does not have official FDA NADA status, then certifiers may look at each and every ingredient in a material. Some certifiers do, but not all. Therefore, if a calcium product may have propylene glycol in it as a preservative (in minute amounts) a certifier can prohibit that particular brand of calcium while other brands of calcium may be allowed. In other words, not all injectable calcium products for IV milk fever treatment are created equal – in the eyes of the certifiers, though each brand can potentially save the life of a flat out milk fever cow.

Another livestock health care product which some certifiers look at in excruciating detail is injectable vitamin C. Why? This is because injectable vitamin C also does not have FDA NADA status. And in actuality, a careful reading of the law also shows that only vitamins as feed additives (not necessarily injectable forms) are the only kinds allowed. It is stated as 7CFR205.603 (d) as feed additives. (2) Trace minerals, used for enrichment or fortification when FDA approved. (3) Vitamins, used for enrichment or fortification when FDA approved. The term “FDA approval” hinges upon AAFCO approval, but again, only for feed additives. While most all certifiers I know of allow injectable vitamin C due to vitamin C allowed by AAFCO (for feed additive purposes), some certifiers do not see things this way – even though the injectable vitamin C bottles say for nutritive needs. These same certifiers then look at all ingredients as fair game to be scrutinized. Some excipients then turn up to be not allowed and that brand of vitamin C is then prohibited. Yet all have 250mg/ml ascorbic acid (vitamin C) as their active compound and it’s the vitamin C we are using it for. For goodness sake, why can’t we simply say that vitamin C is allowed and for all brands! Mind you, injectable B-complex and injectable A,D and E could be prohibited with this kind of ridiculous thinking. Fortunately, MuSe® (vit E & selenium) does have FDA NADA status and therefore the excipients with it are spared from such scrutiny. I truly feel for hard working farmers that are doing everything that you know how to do in the best possible way for your cows and become frustrated about these picky details that not all certifiers agree on. Believe me, it is very frustrating to me as someone who is trying to deliver the best possible health care for organic livestock with already one hand tied behind my back due to the complete prohibition on some other life saving substances

But for those of you that have thought about or thinking about switching certifiers, I would caution you before jumping too quickly. Remember that, yes, you can freely choose from among 90 accredited certifiers. But also remember that not all certifiers operate in the same ways. All certifiers have their own odd peculiarities regarding certain aspects of the law according to what I hear from farmers regionally and nationally. Some factors to keep in mind are: length of time to process your application from initial request for inspection to final certificate (or renewal), whether or not they provide meaningful educational programs throughout the year, whether or not they clearly state why they proceed to review materials the way they do (transparency), whether or not they understand the way farmers in the area actually farm, whether or not they send out inspectors that understand the ins and outs of dairy farming generally, whether or not they seem to be consistent in reviewing materials from year to year, and finally the cost of the certification process. While all accredited certifiers are equal in the eyes of the USDA, the way certifiers carry out their duties to their paying clients (you, the farmer) can vary widely.


For Bovinity Health, information on functional alternatives to antibiotics see:

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