Devon Patillo, CCOF
Dr. Jacquie Jacob Ph.D., University of Kentucky
Organic poultry producers are required to keep records to demonstrate compliance with USDA National Organic Program (NOP) requirements. Depending on the scale of operation and the method by which eggs, meat, or live birds are sold, certain records may be more appropriate than others.
Organic certification requirements allow recordkeeping systems to be adapted to a particular operation. However, all operations must keep records in enough detail to demonstrate to organic inspectors and certifiers that all requirements of the organic regulations are met. Recommended records are described below. Your certifier will determine your compliance with National Organic Program standards. Be prepared to work with your certifier and adjust your recordkeeping system to meet the required standards.
Poultry producers must meet the organic regulations summarized below. To read the full text of the organic regulations, visit The Electronic Code of Federal Regulations (e-CFR).
§ 205.103 Recordkeeping by certified operations
Below is the full text of the recordkeeping requirement of the National Organic Program.
(a) A certified operation must maintain records concerning the production, harvesting, and handling of agricultural products that are or that are intended to be sold, labeled, or represented as “100 percent organic,” “organic,” or “made with organic (specified ingredients or food group(s)).”
(b) Such records must:
(1) Be adapted to the particular business that the certified operation is conducting;
(2) Fully disclose all activities and transactions of the certified operation in sufficient detail as to be readily understood and audited;
(3) Be maintained for not less than 5 years beyond their creation; and
(4) Be sufficient to demonstrate compliance with the Act and the regulations in this part.
(c) The certified operation must make such records available for inspection and copying during normal business hours by authorized representatives of the Secretary, the applicable State program's governing State official, and the certifying agent.
§ 205.236: Animal Origin
Section 205.236(c) 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.”
- Animal purchase records
Birds must be managed organically starting no later than the second day of life. Keep records to show: date(s) of purchase, number of birds purchased, and the age of animals at time of purchase.
- Mortality and cull records
These records ensure that non-organic birds are not added to your flock. Document observed deaths and intentional culls. Bird deaths and culls subtracted from the number of purchased birds need to correspond to the number of birds being certified. Your certifier may use this information to list the number of birds on your certificate and to ensure that non-organic birds have not been added to your flock. (Purchases – Mortality & Culls = Size of current flock)
This means that all organic poultry must be grouped in flocks or otherwise identified, with corresponding records maintained of all feeds and feed supplements purchased and consumed for all stages of life; all health events and medications or activities; housing and pasture rotations; etc. Records must also be maintained of all products produced, including meat and eggs, or feathers for organic fishing flies.
§ 205.237: Feed
- Feed Production or Purchase Records
All feed provided must be certified organic. Feed production and/or purchase records need to demonstrate that all feed provided was certified organic. Keep copies of all purchase documentation. Ensure that the total number of pounds purchased is easy to determine. Feed and feed supplement records should include type of feed purchased, quantity purchased, dates purchased, source, and agency that certified the feed as organic. If mixing your own feed, you need to document the same information for each feed ingredient used. You need to list all supplements, including vitamins, amino acids, minerals, etc. used and the reason they were used.
- Feed labels, ingredient statements, and certification information
Keep documentation to demonstrate that the feed you purchased was in fact organic. Keep retail labels that include a “Certified Organic by [certifier’s name]” statement. These will appear under the manufacturer’s name on the retail label. If purchasing bulk feed without a retail label, you will need to obtain a list of ingredients in the feed formula and a copy of the manufacturer’s organic certificate, in addition to the purchase invoice and delivery ticket.
- Feed supplement and additive purchases
Only approved feed supplements and additives are allowed. Seek approval of feed supplements prior to use. Once approved, keep documentation of your purchases. Ensure the purchase records include the name of the product(s) purchased, quantity purchased, and date.
§ 205.238: Health care and treatment
- Health care product purchases (medicines, vaccines, drugs)
Only approved health care materials are allowed. Seek approval of any health care materials prior to use. Once approved, keep documentation of your purchases. Ensure the purchase records include the name of the product(s) purchased, quantity purchased, and date.
- Mortality/cull records
These records provide an indication of the health of your birds. Document observed deaths and intentional culls. If documented on a calendar, be sure to transfer the information from your calendar to a single location before your inspection so it will be easier to see trends or patterns.
A preventive health care program should include control of possible disease vectors including rodents, insects (e.g., external parasites, flies and darkling beetles), and internal parasites. The methods of control should be outlined with a record of monitoring and action(s) taken. Predator control measures should also be documented.
A preventive health care program also includes keeping equipment used clean as well as cleaning and disinfecting between flocks. A record must be kept of all sanitation and cleaning products used and when. Use of any vaccines must be recorded with the date used and source of the vaccine.
Any physical alterations used such as beak trimming, de-snooding, toe trimming, and wing trimming must be recorded with explanation of when performed and why.
As part of your biosecurity program you should limit visitors to your farm. If there are visitors, you should document who and when, and where they had been prior to the visit.
§ 205.239: Living conditions
- General information
Certifiers may require specific data about living conditions provided to birds. It is a good idea to have the following information available for your certifier. It is recommended to note the following information on a drawing of any coops or houses:
- Perch space (inches per bird)
- Stocking density: Space per bird indoors (square feet per bird)
- Stocking density: Space per bird outdoors (square feet per bird)
- Number of birds per nest box (birds per nest box)
Organic poultry are required to have outdoor access depending on their stage of life. The outdoor access area must also be maintained as organic and records kept to document that it has been. This includes a history of how the fields have been used. Section 205.203 requires that all organic producers must take steps to prevent the contamination of water and minimize soil erosion. Soil and water tests should be done to monitor quality. For pastures this will also include the type and source of seeds used. It is also important to document at which age chicks are first given access to the outdoors.
§ 205.105: Other substances
- Cleaning/Disinfecting records
Only approved sanitizers are allowed when cleaning houses or facilities between flocks. Some sanitizers must be rinsed, while others do not require a rinse. Work with your certifier to determine sanitizers that are allowed. Document cleaning of houses and include date, sanitizer(s) used, and any other information required by your certifier.
As with any commercial operation, the number of eggs or birds produced should be recorded. This documentation is required for organic certification, but also gives the producer an idea of the level of production and early detection of any sudden drops. Daily feed consumption and water intake should also be monitored.
If non-organic products are being raised on the same farm, there must be documentation showing how the commingling of organic and non-organic products is prevented.
The type and amount of bedding material used (e.g., pine shavings) needs to be documented. If bedding materials are consumed by the birds, then the bedding materials must be organic, and records must be maintained to verify organic status.
Manure management is an important part of an integrated farming operation. Manure is a valuable byproduct of poultry production operations and a good source of nutrients for organic crop production. The amount of manure produced, and how it is used, needs to be documented.
Whether you are producing poultry meat or eggs, the products must be handled organically while being shipped for processing. For meat birds, this includes the certification of the facility where the birds are slaughtered, as well as the method and condition of transport to the slaughter facility. The slaughter facility must be certified organic, and its current certificate and documentation must be kept in your records. Similarly, if there is off-farm egg processing, the facility must be certified organic or covered under your certificate in order for the eggs to be labeled as such. If you are processing and packaging the eggs on-farm, the egg handling area and any materials used must be included in the overall organic plan for the farm.
Adapt your recordkeeping system to your own operation
Different producers may need to keep different types of records to demonstrate compliance because of their activities or scale. While certain records are essential for most operations—such as feed purchase records—certifiers may require other records for some producers and not others if they feel that additional information is required to determine compliance with the regulations. In general, larger operations are required to keep more records than smaller operations. Again, your certifier will determine your compliance with National Organic Program standards. Be prepared to work with your certifier and adjust your recordkeeping system to meet the recordkeeping standards.
The records you are required to keep may also depend on how you market your eggs, live organic birds, or meat. If you sell on a wholesale basis to a single buyer, a summary of sales or transportation of birds may be adequate. Total income will also need to be reported. Certifiers rely on this information to ensure that non-organic product is not being sold as organic.
Producers marketing directly to consumers or to a variety of accounts are also required to document total sales. Sales information must include both the quantity of product sold and income from sales. Certifiers rely on this information to ensure that non-organic product is not being sold as organic.
You are required to make your records available during normal business hours to your certifier, state organic program (California only), and authorized representatives of the USDA. You are also required to keep your records on file for no less than five years.
How records might vary for large vesus small producers
- Outdoor Access Logs
Identify dates and reason(s) for confinement. Be specific. Most certifiers will require that you record animals' outdoor access on a daily basis. Additionally, a stated policy or standard operating procedure should describe any time periods when birds are typically confined, including the reason for such confinement (e.g. pullets until feathered).
- Facility records
- Diagram of each house
- Length and width of building
- Location and size of all doors
- Outdoor access areas, to scale
- Locations of feeders/waterers (indoors and outdoors)
- Temperature logs
- Cleaning/disinfection of houses between flocks
- Ammonia levels
Small producers (all birds outside more often than not)
- Outdoor Access Logs
Document dates and reason(s) for confinement. Marking days on calendar, with the reason for confinement noted, will most likely be adequate to demonstrate compliance.
- Bird movement or location records (optional)
Small producers that move birds around pasture may wish to record the days when birds are moved. This can provide assurances to certifiers that the ground on which birds trod does not become contaminated by excess manure.
References and Citations
- 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?tpl=/ecfrbrowse/Title07/7cfr205_mai...) (verified 13 April 2013)