A USDA Agricultural Marketing Service comment period on a proposal to amend the NOP’s “origin of livestock” requirements for dairy animals under federal organic regulations closes on Dec. 2, 2019. Advocates for changes to the rule charge inconsistent enforcement has plagued the transition of livestock from conventional to organic production. While some organic certifiers strictly adhere to the policy, others have allowed farmers to remove calves from organic herds, raise them using conventional practices prohibited under organic regulations, and then transition them back to organic management when they are ready to be milked.
A rule was originally proposed in 2015 but withdrawn in 2018. The USDA had previously indicated that it planned to release a new rule in 2019, then decided instead to reopen the older rule for public comment.
As originally proposed, the rule clarifies requirements for organic dairy farms transitioning conventionally raised animals to organic production. After completion of a one-time transition, any new dairy animals a producer adds to a dairy farm would need to be managed organically from the last third of gestation or sourced from dairy animals that already completed their transition into organic production.
Access the rule and submit comments via the Federal eRulemaking Portal.
According to Benson, the USDA Office of Inspector General (OIG) published an audit report on organic milk operations stating that certifying agents were interpreting the origin of livestock requirements differently. Three of the six certifiers interviewed by OIG allowed producers to continuously transition additional animals into a herd after the initial herd made the transition to organic milk production, while the other three certifiers did not permit this practice. OIG recommended that a proposed rule be issued to clarify the standard and ensure that all certifiers consistently apply and enforce the origin of livestock requirements.
A Cornell study compared the costs of production for organically raised calves from day one to those raised conventionally and transitioned to organic before freshening. The study showed that the loophole allowed dairies whose certifiers allowed conventional raising of the newborn calf to 1 year of age to save $884 per animal for feed and labor.
The New York Organic Dairy Program is connected with Cornell’s School of Agriculture and Life Science and Cornell Cooperative Extension.
After meeting in December 2018, the New York Organic Dairy Task Force directed and provided funding for Benson, Cornell Cooperative Extension educator and project manager for the Cornell Organic Dairy Program, to complete a study of what it costs for dairy farmers who raise dairy replacements organically. Data for the study was collected from three certified organic dairies in central New York.
Benson used a cost analysis created by Jason Karszes, farm business specialist with Cornell’s PRO-DAIRY Program. Cost and data collected included labor, feed, buildings, machinery, animal health, trucking, manure handling and culling.
Realizing that cost of feed accounts for over 50% and labor 12% of the cost of raising a dairy replacement, any changes to those dramatically impacts the total cost to raise that animal. The study showed that 18 conventional dairy heifer growers in New York averaged costs of $1,060.92 per heifer during the first year of an animal’s life. Costs of the three organic farms who took part in the study ranged from $2,312.20 to $3,638.85 per heifer.
Among practices leading to higher costs, calves raised conventionally were fed milk replacer or milk for 50 days, while heifer calves raised organically averaged 89 days (ranging from 70 to 112 days) on milk replacer or milk. Both the longer feeding period plus the higher cost of organic milk replacer or milk increased feed and labor costs on operations raising dairy heifer calves organically.
Conventional dairies averaged $3.60 per day per calf in milk replacer/milk costs and $1.50 per day per calf in labor costs, resulting in the total feed and labor cost of $255 to raise a heifer calf to weaning.
Among the three dairies raising heifer calves organically, milk replacer/milk costs ranged between $5.05 and $8.05 per calf per day, with labor ranging between $3.12 and $4.93 per calf per day. As a result, the total feed and labor cost of raising a dairy heifer calf to weaning using organic practices ranged between $698 and $1,139 per calf. The organic herd with the highest cost per calf had the longest milk replacer/milk feeding period and the smallest herd, so labor costs were spread over fewer animals. 
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Dave Natzke
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