Jim Riddle, Organic Independents LLP
In order to be sold in the United States as organic, all agricultural products–including domestic and imported poultry products–must comply with Federal regulations. The United States Department of Agriculture (USDA), in cooperation with accredited certification agencies, regulates the production and labeling of organic poultry products under the Organic Foods Production Act of 1990 and the National Organic Program (NOP), Section 7 of the Code of Federal Regulations (CFR), Part 205, also known as the NOP Final Rule.
This article explains the requirements for the production and labeling of poultry products as organic in the United States. In short, all organic poultry operations that sell over $5000 of organic products per year, and those who wish to sell their products to be used as organic ingredients or organic feed by others, must be certified by a USDA-accredited certifying agent. To sell organic eggs or poultry meat, birds must be fed and managed organically from the second day after hatching. All agricultural components of the feed ration, including kelp and carriers in feed supplements, must be 100% organic. All poultry must have access to the outdoors.
Organic poultry producers must establish preventative livestock health management practices. Medical treatment cannot be withheld from sick animals or flocks to maintain the birds' organic status. The use of growth hormones, antibiotics, genetic engineering, and animal cloning is prohibited, as is the feeding of slaughter byproducts. All organic poultry production and processing operations, including slaughter plants and egg handling facilities, must be certified by USDA-accredited certification agencies. Detailed records of all feeds, medications, and transactions must be maintained. Organic integrity must be protected by preventing organic birds and poultry products from coming in contact with prohibited substances or being commingled with non-organic products.
Organic Production: The NOP Final Rule defines organic production as "a production system that is managed…to respond to site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity." This means that, in order to be certified for organic production of livestock or poultry, producers must use cultural, biological, and/or mechanical practices and employ ecological principles, such as natural resource conservation and recycling of resources.
Livestock: Under the NOP Final Rule, livestock are defined as “any cattle, sheep, goat, swine, poultry, or equine animals used for the production of food, fiber, feed, or other agricultural-based consumer products; wild or domesticated game; or other non-plant life, except such term shall not include aquatic animals and bees for the production of food, fiber, feed, or other agricultural-based consumer products.”
Conversion of Birds to Organic Production
In order to be sold as organic, NOP Final Rule Section 205.236 requires that poultry or edible poultry products must be from poultry that has been under continuous organic management beginning no later than the second day of life.
Organic poultry, including birds used for meat or eggs, lose their organic status if they are removed from the organic farm and managed on a non-organic operation. They cannot be rotated back into organic production.
Section 205.103 of the NOP Final Rule requires that all organic operations, including poultry producers, must maintain records that: (1) disclose all activities and transactions; (2) are auditable; (3) demonstrate compliance with all applicable requirements; (4) are maintained for at least five years; and, (5) are made available to organic inspectors and certification agencies.
In addition, §205.236(c) of the Final Rule requires that, “the producer of an organic livestock operation must maintain records sufficient to preserve the identity of all organically managed animals and edible and non-edible animal products produced on the operation.” This means that all organic poultry must be grouped in flocks, or otherwise identified, with corresponding records maintained of all health events and medications or activities; all feeds and feed supplements purchased and consumed for all stages of life; housing and pasture rotations; etc. Records must also be maintained of all products produced, including meat and eggs.
Organic System Plans
NOP Final Rule § 205.201 requires that, in order to be certified, all organic producers–including poultry producers–complete an Organic System Plan (OSP) that:
- Describes their production practices;
- Lists and describes all substances used and planned for use by the operation;
- Describes the monitoring practices used to assure that the operation follows the requirements;
- Describes their recordkeeping system;
- Describes steps taken to prevent contamination or commingling; and,
- Provides other information requested by the certification agency.
OSPs must be updated annually, and certifiers must be informed at once of any changes to the operation that may impact its compliance with NOP requirements, including application of a prohibited substance to any field, facility, livestock, or product that is part of the organic poultry operation.
Feed and Feed Additives
Section 205.237 of the Final Rule requires 100% organic feed for all organic poultry. Feed is defined as “edible materials, which are consumed by livestock for their nutritional value. Feed may be concentrates (grains) or roughages (hay, silage, fodder). The term, “feed,” encompasses all agricultural commodities, including pasture ingested by livestock for nutritional purposes.” In other words, all agricultural components of the ration must be certified organic. Fields, including pastures used for organic poultry and lots used for outdoor access, must be certified. Records must be kept of all farm-raised and purchased feed and feed additives. Crop producers who grow livestock feed for sale to organic poultry producers must be certified, and cannot sell their feed as organic under the $5000 small farmer exemption.
Non-synthetic (natural) substances, such as oyster shells, calcium carbonate or fish meal; and synthetic substances that appear on the National List, may be used as feed additives and supplements. The only specific synthetic feed additive on the National List for poultry is DL-methionine. The National List allows the use of DL-Methionine, DL-Methionine-hydroxy analog, and DL-Methionine-hydroxy analog calcium (CAS #'s 59-51-8, 583-91-5, 4857-44-7, and 922-50-9) for organic poultry production at the following maximum levels of synthetic methionine per ton of feed: Laying and broiler chickens—2 pounds; turkeys and all other poultry—3 pounds.
FDA-approved trace minerals and vitamins are allowed in poultry rations, so long as they are not derived from slaughter byproducts and do not contain any genetically engineered ingredients, which are referred to as "excluded methods" in the NOP Final Rule. No synthetic colorings, flavorings, dust suppressants, or flowing agents are allowed, since none appear on the National List.
Feed used for organic poultry production must not contain:
- Animal drugs, including hormones, to promote growth;
- Feed supplements or additives in amounts above those needed for adequate nutrition and health maintenance;
- Plastic feed pellets;
- Urea or manure;
- Mammalian or poultry slaughter byproducts fed to mammals or poultry;
- Feed, additives, or supplements in violation of the Food and Drug Administration; or
- Feed or forage to which any antibiotic, including ionophores, has been added.
Organic poultry producers must establish and maintain year-round living conditions which accommodate the health and natural behavior of the birds, including:
- Year-round access for all birds to the outdoors, shade, shelter, exercise areas, fresh air, clean water for drinking, and direct sunlight, suitable to the species, its stage of life, the climate, and the environment;
- Appropriate clean, dry bedding (which must be organic if roughages are used for bedding); and
- Shelter designed to allow for:
- natural maintenance, comfort behaviors, and opportunity to exercise;
- temperature levels, ventilation, and air circulation suitable to the species; and
- reduction of potential for livestock injury.
Yards, feeding pads, feedlots and laneways used for organic poultry must be well-drained, kept in good condition (including frequent removal of wastes), and managed to prevent runoff of wastes and contaminated waters to adjoining or nearby surface water and across property boundaries.
Organic poultry producers may provide temporary confinement or shelter because of:
- Inclement weather
- The animal's stage of life
- Conditions under which the health, safety, or well being of the birds could be jeopardized
- Risks to soil or water quality
- Performance of preventative health care procedures or treatment of illness or injury
- Sorting or shipping animals
- Presentation at fairs or events
If it is determined that temporary confinement of birds is needed to protect the health, safety, or welfare of organic flocks, then producers and certifiers may work together to determine an appropriate method and duration of confinement of organic poultry flocks without a loss of organic certification. The method of temporary confinement to be used must be approved by the certifying agent and should provide the necessary protection to the birds while meeting the remaining requirements of the NOP Final Rule. Continuous total confinement of any animal indoors is prohibited, according to the NOP Program Handbook.
Please note that the NOP Final Rule requires that all organic producers must take steps to prevent the contamination of water and minimize soil erosion. Organic poultry producers must make sure that their birds do not cause erosion or contaminate water resources. Organic poultry operations must manage manure so that it does not contribute to contamination of crops, soil, or water by plant nutrients, heavy metals, or pathogenic organisms, and that it optimizes the recycling of nutrients.
Organic poultry producers must not use lumber treated with arsenate or other prohibited materials in contact with soil or birds for new installations or replacement purposes. The prohibition applies to lumber used in direct contact with organic poultry, and does not apply to lumber used for fence posts or building materials as long as the birds are isolated from the lumber by use of electric fences, netting or other methods approved by the certification agent. If treated lumber was present prior to application for certification, it may remain, but no new installations are allowed where the birds are able to consume forage immediately around the posts, or rub up against the wood in structures such as pens, runs or buildings. Rot-resistant, untreated woods such as cedar, white oak, or black locust; and metal or concrete posts, may be used. Certifiers are not typically concerned about paints, sealers, or whitewash used in barns or other housing facilities.
Section 205.238 of the Final Rule requires that organic poultry producers must establish preventative health care practices, including:
- Selection of species and types of poultry that are suitable for site-specific conditions and resistant to prevalent diseases and parasites;
- Provision of a feed ration sufficient to meet nutritional requirements, including vitamins, minerals, protein and/or amino acids, fatty acids, and energy sources;
- Establishment of appropriate housing, pasture conditions, and sanitation practices to minimize the occurrence and spread of diseases and parasites;
- Conditions that allow for exercise, freedom of movement, and reduction of stress appropriate to the species (no caged laying hens, for example);
- Physical alterations as needed to promote the poultry's welfare, performed in a manner that minimizes pain and stress; and
- Administration of vaccines and other veterinary biologics.
As stated earlier, physical alterations may be performed if they are done to promote the poultry's welfare, and in a manner that minimizes pain and stress. Before performing physical alterations, organic producers should check with their certifying agent to make sure that the practice is allowed, and describe the practice and reasons for its use in the operation's Organic System Plan.
The following physical alterations are typically allowed, provided that the conditions described above are met:
Turkeys: Wing clipping or toe clipping.
Laying hens: Beak trimming or wing trimming.
Proposed Changes: The National Organic Standards Board (NOSB), who advises the USDA on implementation of the NOP regulations, adopted a recommendation on December 2, 2011 that advocates prohibition of the following: (i) De-beaking, de-snooding, caponization, dubbing, and toe trimming; (ii) Toe trimming turkeys unless performed with infra-red at the hatchery; and (iii) Beak trimming unless performed within 10 days of age. The NOSB recommendation has not been implemented by the USDA.
The NOSB has also recommended that: (a) ammonia levels should be less than 10 ppm and must be less than 25 ppm indoors; (b) the confinement of birds in cages is not permitted under any circumstance; and (c) minimum indoor and outdoor space requirements be established for organic poultry.
The 12/2/2011 NOSB recommendation advises the NOP to establish the following avian minimum space requirements:
- Laying hens and breeders: 2.0 sq ft/bird indoors, 2.0–5.0 sq ft/bird outdoors
- Pullets: 2–3 lbs/sq ft indoors, 2–3 lbs/sq ft outdoors
- Broilers: 1–5 lbs/sq ft indoors, 2–5 lbs/sq ft outdoors
- Turkeys and Geese—breeding, laying, or meat birds (pounds): Not specified in final recommendation
- Ducks—meat: Not specified in final recommendation
- Ducks—laying: Not specified in final recommendation
- Ducks—breeder: Not specified in final recommendation
For health care, §205.238 of the Final Rule states that, “when preventive practices and veterinary biologics are inadequate to prevent sickness, a producer may administer synthetic medications, provided that such medications are allowed under §205.603 (the National List).” Use of these medications may have specific withdrawal or “veterinarian prescription only” restrictions, and use of these medications without following the specific restrictions can result in loss of certification.
Section 205.238 requires that an organic poultry operation must not sell, label, or represent as organic any animal or edible product derived from any animal treated with antibiotics, any substance that contains a synthetic substance not allowed under §205.603, or any substance that contains a non-synthetic substance prohibited in §205.604.
Section 205.238 also prohibits the use of animal drugs, other than vaccines and other biologics, in the absence of illness; hormones for growth promotion; synthetic parasiticides on a routine basis; parasiticides for slaughter stock; or the use of animal drugs in violation of the Food, Drug, and Cosmetic Act.
Section 205.238(c)(7) requires that organic poultry producers must not, “withhold medical treatment from a sick animal in an effort to preserve its organic status. All appropriate medications must be used to restore an animal to health when methods acceptable to organic production fail. Livestock treated with a prohibited substance must be clearly identified and shall not be sold, labeled, or represented as organically produced.”
Examples of allowed synthetic substances on the National List include: ethanol and isopropanol as disinfectants; aspirin; atropine; butorphanal; flunixin; furosemide; magnesium hydroxide; vaccines and biologics; poloxalene; tolazoline; xylazine; chlorhexidine for surgical procedures and as a teat dip; chlorine materials and peroxyacetic/peracetic acid as sanitizers; electrolytes; glucose; hydrogen peroxide; iodine; magnesium sulfate; phosphoric acid to clean equipment; copper sulfate; lidocaine; hydrated lime; mineral oil; procaine; excipients in livestock drugs; and the inert ingredients included on the EPA List 4.
As stated, many of the substances listed above contain restrictions on their use or must be followed by extended withholding times. Check the restrictions or annotations that accompany the substance, as stated on the National List, before use. Make sure that the substance is listed on your Organic System Plan and keep records of all uses. If you have any doubts about the status of a particular brand or formulated product, check with your certifier before purchase or use.
Section 205.604 of the Final Rule contains a short list of natural substances that are prohibited in organic livestock production. The only item presently on the list is strychnine.
Please note that excipients are allowed in medications given to organic poultry, but only when the excipient is: identified by the FDA as Generally Recognized As Safe (GRAS); approved by the FDA as a food additive; or included in the FDA review and approval of a New Animal Drug Application or New Drug Application.
Excipients are defined as: “any ingredients that are intentionally added to livestock medications but do not exert therapeutic or diagnostic effects at the intended dosage, although they may act to improve product delivery (e.g., enhancing absorption or controlling release of the drug substance). Examples of such ingredients include fillers, extenders, diluents, wetting agents, solvents, emulsifiers, preservatives, flavors, absorption enhancers, sustained-release matrices, and coloring agents.”
At the present time, the only parasiticides on the National List are fenbendazole (CAS # 43210-67-9), ivermectin (CAS # 70288-86-7) and moxidectin (CAS # 113507-06-5). Parasiticides may only be used on: (1) Breeder stock, when used prior to the last third of gestation but not during lactation for progeny that are to be sold, labeled, or represented as organically produced; and, (2) Dairy stock, when used a minimum of 90 days prior to the production of milk or milk products that are to be sold, labeled, or represented as organic. No parasiticides are allowed for organic egg or meat production.
Processing and Labeling Organic Poultry Products
In order to be labeled organic, poultry slaughter and egg handling and processing operations must also be certified. Organic products must not be commingled with non-organic products or come in contact with prohibited substances during handling or processing. All ingredients and other substances used in or on organic poultry products during processing must appear on §205.605 or §205.606 of the National List. Records must be maintained of all processing activities.
Product labeling must be legal and show a lot number or date code traceable back to the flock or the operation where it originated. Though its use is not mandatory, all operations certified by NOP-accredited certification agencies can use the USDA Organic seal on products that contain at least 95% organic content and meet all applicable labeling requirements.
Section 7, Part 205 of the Code of Federal Regulations contains detailed requirements for the production, processing and labeling of organic poultry products. All organic poultry operations that sell over $5000/year of organic products, and those who wish to sell their products to be used as organic ingredients or feed by others, must be certified by a USDA-accredited certifying agent. Poultry producers who receive organic certification are rewarded by identification of their products as organic and are able to participate in the fast-growing organic market.
References and Citations
- Agricultural Marketing Service National Organic Program Handbook [Online]. United States Department of Agriculture. Available at: https://www.ams.usda.gov/rules-regulations/organic/handbook) (verified 8 Jan 2020)
- Fanatico, Anne. 2008. Organic poultry production in the United States. ATTRA publication, NCAT, Fayetteville, AR. (Available online at: https://attra.ncat.org/attra-pub-summaries/?pub=177) (verified 8 Jan 2020)
- National Organic Standards Board, Livestock Committee Final Recommendation. Animal welfare and stocking rates. December 2, 2011. (Available online at: https://www.ams.usda.gov/sites/default/files/media/NOP%20Livestock%20Final%20Rec%20Animal%20Welfare%20and%20Stocking%20Rates.pdf) (verified 8 Jan 2020)
- United States Department of Agriculture. 2000. National organic program: Final rule. Codified at 7 C.F.R., part 205. (Available online at: http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&sid=3f34f4c22f9aa8e6d9864cc2683cea02&tpl=/ecfrbrowse/Title07/7cfr205_main_02.tpl) (verified 30 July 2013)