July 3, 2015 by Chris

Proposed New Rules for Organic Dairy Animals

Comments are due July 27, 2015 for a recently proposed USDA rule that would update the agency’s organic regulations by, inter alia,

explicitly requiring that milk or milk products labeled, sold or represented as organic be from dairy animals organically managed since at least the last third of gestation, with a one-time exception for transition. This exception would allow a producer, as defined by the regulations, to transition nonorganic dairy animals to organic milk production one time, under specific conditions.

This proposal would specify that a producer (e.g., an individual or corporation starting or operating a dairy farm) could transition nonorganic dairy animals to organic milk production one time over a single twelve-month period. The proposal would require that all transitioning animals end the transition process at the same time. This twelve-month period is consistent with OFPA’s requirement that there be a minimum period of one year of organic management before milk from dairy animals can be sold as organic (7 U.S.C. 6509(e)(2)).

If that’s in your wheelhouse, be sure to whey in. But for those of us not intimately familiar with the nuance of rearing livestock, yet otherwise appreciate the use of “heifer” in a government report and enjoy the aggregating work of a good government factotum, the proposed rule’s cost-benefit analysis contains some interesting data.

According to Table 4 (reproduced below) the 1,824 certified organic dairy farms in the United States combine to produce nearly 3 billion pounds of milk.

Production levels, however, are skewed.

The four states with the largest number of certified organic dairy farms (Wisconsin, Pennsylvania, New York, and Vermont) account for 57 percent of the total farms. However, those states represent less than 30 percent of national organic milk production. By contrast, the West and Southwest account for the highest milk production per farm. The two highest-producing states (California and Texas) represented only 4.3 percent of total certified organic dairy farms, while producing 31.9 percent of the total organic milk nationally. According to 2010 ARMS data, the mean size of an organic dairy farm nationally was 77 cows. In the Northeast and the Upper Midwest, the mean number of organic cows per farm was 64. In the West, the mean number of organic cows per farm was 288.

It will be interesting to see whether this trend holds. Large organic operations could continue to give California and Texas an edge over dairy states like Wisconsin and Vermont, but the proliferation of organic practices in the latter could see production levels increase.

Either way, expect more news on the proposed rule as the situation develops.