Inside the Review Process: Inputs for organic livestock

By Peggy Miars, OMRI Executive Director/CEO

Sales of organic livestock products such as meat, eggs and dairy are growing rapidly, but the certification process remains relatively time consuming and complex compared to the process for other organic products. Recent developments and guidance from the National Organic Program (NOP) are helping to make organic livestock certification smoother and more consistent, but it has been suggested that OMRI could list more livestock products in order to simplify the process for certifiers and transitioning farmers. For this post, I interviewed OMRI’s newest Livestock Review Panel member Johanna Mirenda to hear her thoughts about the issues affecting input products for organic livestock production, and how these issues are evolving over time.

As Policy Director at Pennsylvania Certified Organic (PCO), Mirenda spends every day deciding which individual livestock inputs are allowed for organic production. Because so many feed ingredients, health care products, and other products for organic livestock have not been verified ahead of time by OMRI or another organization, certifiers like Mirenda review these products on their own for each organic operation. As a result, PCO has assembled one of the largest internal databases of compliant livestock inputs, with Mirenda continuously investigating the minutia of each ingredient to make sure it abides by the organic rules.

Now, as a member of the OMRI Livestock Review Panel, Mirenda is also helping OMRI to evaluate the most complicated livestock product applications. Mirenda says that new guidelines from the NOP are improving the pace, efficiency and standardization of reviews. "They're drawing the line on how far back we go, so that enables all certifiers to be consistent, and it also clarifies which ingredients we need to focus on."

Organic stakeholders have repeatedly emphasized the need for a more robust public list of approved products for livestock feed and care. The OMRI Products List© contains the longest public list of verified inputs for livestock producers but, at 193 products, it represents only a small fraction of the products certifiers must look at every day. The List is increasing steadily and OMRI applications for these products tripled between June of 2011 and June of 2013. The number remains small but the trend is encouraging.

Mirenda explains that input manufacturers may avoid verified review for several reasons. Some are not familiar with organic certification in general, including the materials review process and the opportunities presented by fully verified engagement in the organic marketplace. For others, organic sales represent just a small fraction of a manufacturer's customer base, making organic verification a lower priority for some large players. It is also very common for manufacturers to hesitate to share proprietary formulas, even though both OMRI and Washington State Department of Agriculture (WSDA) offer completely confidential product review.

In the meantime, individual certifiers nationwide continue to separately evaluate each unlisted product, making the certification of organic livestock operations more cumbersome. “It definitely involves communicating with manufacturers and sometimes explaining what organic certification is and why we need this information. If we're not getting responses from the manufacturer, that can really slow down a review,” says Mirenda.

Still, the prevalence of unlisted organic livestock inputs creates real time implications for livestock producers. “It’s very time sensitive,” she says. “The animals are always being fed, they're always being managed, they're moving in, they're moving out. As certifiers, we oftentimes have an operator call us, and they have their veterinarian standing right there. They say: 'I've got to treat this cow right now. What do I use?'”

The issue raises particular difficulties for producers who want to transition to organic practices. Natural immunities build slowly when herds are transitioning, often requiring more health aids and inputs than established organic herds, with consequences for unintentional missteps. “When you're in transition, oftentimes it’s material use that could make or break you. If you use one material containing one ingredient that's not allowed, you could have to start over,” says Mirenda.

Another challenge in the livestock input review has been consistency. Policy clarifications by the NOP have recently come to play an important role in creating a consistent certification process. For example, the recent NOP Guidance 5030  clarifies that minor, incidental sub-ingredients, such as carriers in individual vitamins, are allowed as part of approved vitamin and mineral sources without further review. In the past, getting information about these carriers and mineral sources has been a difficult task, and a major deterrent for input manufacturers who might otherwise apply for OMRI listing. Applications to list livestock feed ingredients will certainly be reviewed more quickly with the new clarification, and it’s possible that more products will now be eligible for the OMRI Products List.

Variability in interpretations of the organic rule can lead certifiers to differing decisions, which is one reason why the new guidance from the NOP is so important. Ultimately the consumers of these products can expect to start seeing the results of a smoother process. "Any movement towards more consistent review criteria between certifiers and with OMRI is a step in the right direction," says Mirenda. "It's better for us, it's better for the operators, less confusion. I think the guidance that's coming from the NOP, slow and steady, has been really helpful."

Peggy Miars came to OMRI in 2010 from California Certified Organic Farmers (CCOF), where she served for six years as the Executive Director/CEO. She holds a Bachelor of Business Administration degree from Western Michigan University and completed post-graduate courses in nonprofit management at Regis University in Colorado Springs. Peggy has worked in the organic industry for more than 17 years, previously in marketing and management positions with Earthbound Farm, Whole Foods Market, Granary Market, various nonprofit organizations, and her own marketing consulting business. She completed IOIA inspector training for crops in 2007.

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