MOSA provides our clients with much more than just certification.

Joe Pedretti

MOSA Client Services Director

Certification Policy Update

Certification Policy Update

Jackie DeMinter, Certification Policy Manager

Organic Livestock and Poultry Practices Final Rule Update! On May 10th, the Agricultural Marketing Service (AMS) of the USDA announced that the effective date for the final rule has been delayed for another 180 days until November 14th, 2017. At the same time, the USDA is also seeking comments on a proposed ruling. You can find both federal register notices on the NOP WEBSITE - and on the MOSA website. We urge you to comment now.

The final rule delaying the effective date states: “Because there are significant policy and legal issues addressed within the final rule that warrant further review by USDA, AMS is further delaying the effective date of this rule by 180 days to November 14, 2017. In addition, AMS will publish a proposed rule that solicits public comments on the direction that USDA should take with respect to the rule.”

The accompanying proposed rule requests public comment. “... the public is being asked to comment on which of the following four actions they believe would be best for USDA to take with regard to the disposition of the FR. Specifically, the public should submit their comments on the following options:

(1) Let the rule become effective. This means that the rule would become effective on November 14, 2017.

(2) Suspend the rule indefinitely. During the suspension, USDA could consider whether to implement, modify or withdraw the final rule.

(3) Delay the effective date of the rule further, beyond the effective date of November 14, 2017.

(4) Withdraw the rule so that USDA would not pursue implementation of the rule.”

We feel the implementation of new clarifying rule language is important to strengthen the organic regulations and enable consistency among certification agencies and certified operations. This new rule clarifies the requirements for handling of livestock and poultry to ensure their health and well-being throughout life, including transport and slaughter, specifies which physical alterations are allowed and prohibited in organic livestock and poultry production, and establishes minimum indoor and outdoor space requirements for poultry. This rule is a result of years of work, including several opportunities for public comment. We have reached out to you for your thoughts over the years and the majority of comments are in support of adding clarity to the regulation. MOSA is strongly in support of option one (1), and we encourage you to comment in support of the same.

Comments are due by June 9th! Submit your comments online or by mail following the instructions below.

Online:Federal eRulemaking Portal: Follow the instructions for submitting comments.

By Mail: Paul Lewis Ph.D., Director

Standards Division, National Organic Program


1400 Independence Ave., SW, Room 2642-So., Ag Stop 0268

Washington, DC 20250-0268.

Instructions: All submissions received must include the docket number AMS-NOP-17-0031; NOP-15-06A, and/or Regulatory Information Number (RIN) 0581-AD74 for this rulemaking. Your comments should clearly indicate whether or not you support an option presented in this proposed rule. You should clearly indicate the reason(s) for the stated position. All comments received and any relevant background documents will be posted without change to

At MOSA, we’ll continue our work for a November 14th effective date. If the rule is finalized, we’ll plan for our implementation later in the Fall. We will keep you posted via our newsletter and website. Again, we encourage you to comment! Please let us know if you have any questions.

Biosecurity and avian influenza are again topics to pay attention to with confirmed cases of highly pathogenic avian influenza (HPAI) in Tennessee. As a reminder, the NOP has advised us that if local, state, or federal health authorities determine that additional action is needed in the areas we certify, we are to work with our clients to determine what emergency measures are necessary, and for how long. If you become aware of a threat in your area, contact MOSA to discuss your plans.

Do you use auction facilities for sale or purchase of organic animals? If so, you should be aware that facilities taking over management of the livestock (housing, feeding, bedding, etc) must be certified as organic livestock handlers. For sales where management is not assumed by the facility, the National Organic Standards do still allow for confinement of livestock for sorting, shipping, and sales, given the animal is maintained under continuous organic management, including organic feed, throughout the extent of their allowed confinement. Contact us with any questions regarding requirements for the facility you use.

It’s planting time! A reminder on Seed, Seedlings, and Planting Stock in Organic Crop Production: As the inspection season approaches, organic producers must compile complete documentation for all seeds, seedlings, and planting stock. Documentation verified during the annual inspection includes:

  • A Seed Table form listing all varieties of seeds, seedlings, and planting stock planned for use this year and new clients or updating clients with new land must also list all seed, seedlings, and planting stock used within the past 36 months
  • Receipts documenting the purchase of all seed, seedlings, or planting stock, at least one seed tag for each variety purchased
  • Organic certificates documenting the organic status of all annual seedlings, planting stock (if applicable), and seed (such as garlic) purchased from another organic operation (if applicable).
  • If treatments or inoculants are planned for use, they must be listed on the Crop Input Inventory form and approved before use.
  • If nonorganic seed or planting stock is purchased, an Organic Search form, or the catalogs that were consulted, must be available, along with untreated documentation and non-GMO verification for crops with GMO potential.

Planning for micronutrient applications this spring? Remember to have documentation showing deficiency of the nutrients you are planning to apply. Trace minerals include zinc, copper, boron, manganese, molybdenum, selenium, cobalt and iron. If you are using soil or tissue testing for documentation, some best practices to follow include:

  • Plan for testing with the same lab to maintain consistency.
  • Check your fertility product label. Are all nutrients included being tested for? If not, be sure to request testing. Some labs will not include all traces, like molybdenum and cobalt, in a standard test.
  • Are samples are taken from representative areas of fields where products will be used?
  • Soil tests should also include organic matter levels.
  • Talk to your inspector or contact MOSA about other forms of documentation accepted.

Remember new products need MOSA approval prior to use. We’ll always inform you of any applicable restrictions.