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The National Organics Program

October marked the tenth anniversary of the full implementation of final federal standards and rules developed in response to the Organic Foods Production Act of 1990; in other words, October 2002 was the month that farmers and other food producers would begin affixing the round USDA Organic label to their products.

The United States Department of Agriculture’s National Organic Program (NOP) oversees the national organic rule that went into effect in 2002. The NOP establishes consistent national standards for organic production, facilitates interstate and international commerce, assures that organic products meet a consistent standard, and protects consumers from fraudulent organic claims. The NOP is a dynamic program;rules, policies and procedures have and will continue to change, as necessary, over time. The USDA is currently promulgating specific standards to govern organic aquaculture, apiculture, mushrooms, pet food, and origin of livestock.

The USDA doesn’t administer the NOP program alone. The National Organic Standards Board, appointed by the Secretary of Agriculture, is a Federal Advisory Committee with important functions with respect to the NOP. It is comprised of the following members of the organic community: four farmers/growers, three environmentalists/resource conservationists, three consumer/public interest advocates, two handlers/processors, one retailer, one scientist (toxicology, ecology, or biochemistry), and one USDA accredited certifying agent.

The current Board members hail from all regions of the U.S., even Hawaii, and include affiliations with organic businesses with “name recognition,” such as Organic Valley, Driscoll’s Berries, and California Certified Organic Farmers. Wisconsin has a member, Wendy Fulwider, PhD, from La Farge. She is a UW alumnus and the Animal Husbandry Specialist for the Organic Valley Family of Farms. (

I bring up the NOSB because the Organic Foods Production Act grants the NOSB sole authority to recommend (to the USDA) adding materials to or removing materials fromthe National List of Allowed and Prohibited Substances that may and may not be used in organic crop and livestock production. It also lists the substances that may be used in or on processed organic products. The List is an important resource for maintaining organic integrity in certified organic products, and occasionally has been a source of controversy. The List is not modified easily, requiring long periods for public and industry comment and NOSB/USDA discussion before changes are made.

The NOP also partners with certifying agents to review, inspect and certify the practices of organic farms and processing facilities. These agents may be private entities, states, or foreign governments. There are more than 50 accredited agents headquartered in the US. These certifying agents are the workhorses and the gatekeepers of the NOP program: they inspect the farms and food processors to ensure compliance with the federal organic law and standards. You will often see their names on the boxes, bags and containers of organic products. The third largest, and one of the first, certifying agents is the Midwest Organic Services Association, headquartered in Viroqua, Wisconsin. Oregon Tilth and the California Certified Organic Farmers are also large American certifiers. Agents can also certify imported organic products.

According to the USDA, sales of organic foods in the U.S. have grown from $1 billion in 1990 to an estimated $31.4 billion in 2011. That’s far too many zeros for me to do the math, but I can appreciate the numbers represent an upward trend in sales. In the past decade the percentage growth of the organic food sector has outpaced that of the conventional food sector by a large margin, and the amount of certified cropland and livestock has had similarly impressive gains.

Consumer demand remains the major driving force for organic production. Consumers want product characteristics that include safety, convenience, and quality, and production attributes such as environmental quality, land conservation, animal welfare or lack of genetic modifications. Consumers of organic food want to feel confident that they are buying food that not only was grown organically, but also has kept its organic integrity at each stage in its journey to the market.

Organic labeling: A brief review
The USDA has developed four categories of organic labels, based on the percentage of organic content in a product.

  1. 100 Percent Organic: Products produced using exclusively organic methods, containing only organic ingredients, are allowed to carry a label declaring “100 percent organic.” They may display the USDA organic seal.

  2. Organic: Products that contain at least 95% organic ingredients; may use the USDA Organic seal.

  3. Made with organic: Products with 70% to 95% organic ingredients may display “Made with organic [with up to three specific organic ingredients]” on the front panel. 
    Any non-organic ingredients used in the above labeling categories may not be produced using genetic engineering, irradiation or sewage sludge.

  4. Ingredient Panel: Products with less than 70% organic ingredients can only list the organic items on the ingredient panel.

Animals and the organic food system
Animals are unique in the organic food system. They are a part of the system, as food or producing organic food and fiber for people and also consumers of organically produced products, mostly feed. Or, they can just be consumers. Livestock and poultry fit the dual profile; your family pet is a consumer only! Let’s start with the family pet.

Organic Pet Food
People choose to buy organic pet foods for the same reasons they choose organic for themselves: they want a product that is going to promote the health of their pet, the environment, and the welfare of the animals that make up the food. Feeding organic pet foods has been linked to reduced allergies and other improved health indices, such as coat condition, in pets. And, many people want their pet to eat like the rest of the family! Some people will feed their pets a homemade raw or cooked organic food diet, using organic meats and other ingredients, but most people still look to pet food companies for processed canned or dry diets. By law, USDA certified organic pet foods must follow the same requirements and standards established for organic human foods. This means these foods must be grown and processed without the use of: toxic and persistent pesticides, artificial flavors, colors and preservatives, synthetic growth hormones, antibiotics, genetically modified organisms, irradiation, or sewage sludge.

Certified organic pet food operators are also required to maintain detailed records of all production and processing activity to maximize traceability, and be regularly inspected by a USDA-accredited agent.

Here are a few important points to keep in mind with regards to organic pet foods:

  • The National Organic Program (NOP) lacks the legal authority to regulate “organic” label claims on pet food, except when pet food operations voluntarily choose to meet organic food standards, gain NOP certification, and use the USDA Organic seal. As a result, some organic pet food products are certified to the USDA NOP and follow the same labeling guidelines as organic food for humans, as explained above.

  • Some “organic” pet food products are not certified to any standard.

  • Only pet food products that contain at least 95% of organic ingredients can display the USDA organic seal and display the “certified organic” statement. These products also need to disclose the name of the USDA-accredited certifying agent (e.g., Newman’s Own Organics uses Oregon Tilth and states so on the label).

  • The use of certified organic ingredients does not mean that the product itself is certified organic, i.e., meets all the NOP requirements.

You may be asking yourself, as I did, what does it mean that the NOP lacks the authority to regulate pet foods, yet I see the products on the shelf? The first bullet point above states the work-around: pet food producers use the same organic standards as human food. The USDA explains this apparent conundrum in their October 2012 newsletter:

“Since the National Organic Program began in 2002, sales of organic pet food have steadily climbed. In 2011, organic pet food sales reached $101 million, increasing 7.3 percent from 2010 (2012 Organic Industry Survey, Organic Trade Association). This market growth has occurred while theindustry awaits standards for organic pet food. Currently, pet food is certified using portions of the handling and livestock feed sections of the USDA organic regulations, which has presented hurdles for the organic pet food sector. For example, the USDA organic regulations prohibit feeding mammals by-products from other mammals or poultry. These by-products are important nutrient sources and their allowance in pet food would create new markets for organic by-products not likely to enter the human food chain.”

In 2008, the National Organic Standards Board approved a recommendation for organic standards specific to pet food. The recommendation aims to align pet food composition and labeling with the USDA organic regulations, U.S. Food and Drug Administration (FDA) requirements, and state pet food regulations. The NOSB recommendation was enabled by the work of the Pet Food Task Force, which included individuals from pet food manufacturing, organic consulting, and federal agencies. The pet food industry has eagerly awaited standards providing clear and consistent composition and labeling requirements for organic pet food.” (USDA, Organic Integrity Quarterly, October 2012.)

Remember I mentioned above that changes to the NOP take time? This is a good example, as the proposed standards have been in the pipeline for over four years now. Fortunately, the industry has figured out how to develop certifiable organic products in the interim. At the Co-op we sell two pet food brands—Newman’s Own Organics and Castor and Pollux—that have several certified organic foods in their product range.

Farm Animals
“Organic farming is a whole systems approach encompassing health of the soil, water, air, and the vast array of life existing in each. Health of our livestock is impacted by crop production and land management practices. When crops are grown without toxic herbicides, pesticides and chemical fertilizers, life in the soil and water, birds and honeybees, livestock and wildlife that live on the land and graze the crops all flourish. This whole system approach leads to and benefits an abundance of life! At the very heart of organic farm management is a healthy, sustainable agro-ecosystem with healthy and contented livestock.” (Dr. Wendy Fulwider, Organic Valley Animal Husbandry Specialist, 2.12.11

We all know the juggernaut of the Wisconsin agricultural system is dairy, and the same holds true for the organic segment of this system. The following chart is taken from the USDA 2011 Organic Production Survey. (

Clearly, we have a lot of farm birds and animals to be concerned about in Wisconsin, and the organic animal-based industry is happily responsible for creating demand for organic plant-based agriculture.

Organic production practices seek to be earth- and animal-friendly. In conjunction with input from concerned consumers, American Humane Association (AHA) and the Humane Society of the United States (HSUS), the National Organic Standards:

  • Require preventative health care practices such as adequate feed, nutritional supplements, sanitary housing and freedom of movement.

  • Prohibit withholding medical treatment in cases of animal illness.

  • Require access to outdoors and call for conditions that accommodate the natural behavior of the animal, including grazing requirements.

  • Require appropriate clean and dry bedding.

In addition to other management requirements, organic producers “must provide…a total feed ration composed of agricultural products including pasture and forage, that are organically produced and... organically handled.”(NOP) Organic feed must not contain: animal drugs, including growth-promoting hormones; plastic pellets for roughage; urea or manure; mammalian or poultry by-products; feed, feed additives, or feed supplements in violation of the Federal Food, Drug, and Cosmetic Act; sulfites, nitrates or nitrites added during the production process.

Ruminant animals—your cows, sheep and goats—additionally must have mandatory access to (organic) pasture during the grazing season, which must be at least 120 days per year or more as allowed by climate. Producers must have a pasture management plan and manage pasture as a crop to meet the feed requirements for the grazing animals and to protect soil (i.e., erosion from overgrazing) and water quality. Sheep used to produce certified organic wool must also be raised to the same NOP livestock standards.

Organic poultry must be raised cage-free and have access to the outdoors and to areas for scratching and dust bathing (a.k.a., natural behaviors). Litter, if likely to be eaten, must be organic.

Willy Street Co-op doesn’t sell livestock foods, but we do sell organic soy-free poultry food for your backyard chickens.  

We worked closely with the nutritionist at Heartland Country Co-op in Westby, WI to develop our Organic Soy-Free Heritage Breed Layer Feed, a proprietary ration specially formulated for heritage breed chickens. Eggs from chickens raised on soy are high in omega-6 fatty acids. A healthy omega-6 to omega-3 ratio is about 1:3, but typical Western diets provide a ratio of up to 30:1, increasing the risk of heart attack, stroke, and cancer. Willy Street Co-op’s soy-free feed is made with whole flaxseed, increasing omega-3 levels in eggs, and helping to correct the omega imbalance in our diets.

Diversifying your chicken’s diet with soy-free feed is good for the Earth. Soy is the second largest agricultural crop on the planet. Domestically, over 80 thousand acres of farmland are devoted to soybeans, 90% of which are genetically modified. Growing soy, or any crop, on such a large scale leads to ecosystem degradation and loss of plant biodiversity. In fact, tens of thousands of acres of rain forest are lost every year to meet the global demand for soy.

I recently visited with Susan Troller, Dane County’s own backyard chicken expert, at her store, called Cluck, down in Paoli. Susan is the author of the one of the few books celebrating backyard chickens, Cluck: From Jungle to City Chicks. She’s also a former Capital Times food writer and current board member of the REAP Food Group. Her store is a gathering of supplies, artwork, gifts and housewares with a chicken theme. She is a passionate believer in raising chickens organically, primarily as a way to support organic, sustainable agriculture and of course as a source of organic food. She sells organic and carefully selected conventional feed in her store. Susan also sells organic chicken litter, and she can hook you up with organic sources of nesting and bedding materials.

Choosing to support farms that consciously caretake the environment and the animals they raise in an ethical manner, is always a positive way to spend your food dollar. Animal agriculture produces surprisingly large amounts of air and water pollution internationally, and the often-hideous treatment of factory-farmed animals has been well documented. By supporting sustainable and organically produced products you also support the larger community of which we are all a part. There are many lists of “top (insert number here) reasons” to buy certified organic products, but with respect to animals I’ve distilled these reasons from numerous sources:

  1. Organic animal products are raised free of antibiotics, added hormones, GMO feed and other drugs. They have been shown to be nutritionally better and the food is less likely to cause human or animal health issues.

  2. Animals are fed only organic feed with no added ground-up mammal or poultry pieces, possibly protecting people and livestock against mad cow disease.

  3. Organic rules support more humane and ethical treatment of animals, which, unlike most factory-farmed animals, have demonstrably better living conditions, including access to the outdoors and mandatory grazing requirements.

  4. Animal waste is recycled for nutrients and soil improvement and produces less environmental contamination.

  5. Organic farmers must prepare pasture plans that protect local environmental and soil conditions.

  6. Fewer chemicals used, especially synthetic pesticides. Mark Bittman, the New York Times food columnist, wrote a compelling cautionary piece about the threats to human heath caused by pesticides, citing health authorities like the American Association of Pediatrics. He stressed that buying organic food is the one strategy to protect ourselves from pesticides that is available to us right now. He declared that, “If I were of child-rearing age now, or the parent of young children, I would make every effort to buy organic food.” I highly recommend this article, found online at

  7. Support diversity in our food supply by buying food made with a representative of a wider gene pool. Consider purchasing organic heritage goat or sheep milk cheeses, or raise an exotic backyard chicken that lays blue eggs! Even buying a brown egg helps support agricultural diversity.

  8. You can direct your dollars to local organic farms and businesses, contributing tothe economic well-being of your community.

  9. You help grow the market! Consumer demand pushes the market as shown by the growth of organic human and animal foods over the past two decades.