Certification Policy Update

CERTIFICATION POLICY UPDATE

by Jackie DeMinter, Certification Policy Manager

Organic Livestock and Poultry Standards Published

The organic livestock and poultry production requirements have been updated with specific regulations regarding indoor and outdoor space for avian species, animal health care practices, confinement, transportation, euthanasia, and slaughter. Though most of the rules are in line with existing MOSA policy, some are new and some new types of records are required. This article covers the main areas requiring additional information and where there will be new compliance requirements to meet.

MOSA will be sending you the updated National Organic Standards soon. When you get them, please read through the updated Livestock section (205.238 - 205.242). This rule updated the mammalian and non-avian standards (205.239), introduced a new avian standards section (205.241), and added a transportation and slaughter section (205.242). We have updated our OSPs to incorporate the National Organic Standard updates and will be collecting new information from many livestock and livestock handling operations to verify compliance. Please review your Livestock OSP and ensure all applicable questions are answered. Our reviewers and inspectors will be assessing the new information this season. We will also be introducing a Poultry OSP, geared for poultry operations with only outdoor access and no other organic crop or livestock production.

This rule is to be fully implemented by January 2, 2025 for all operations, with a few exceptions:

- Layer (and pullet) operations certified before January 2, 2025 must comply by January 2, 2029 with outdoor stocking density and soil and vegetation requirements.

- Broiler operations certified before January 2, 2025 must comply by January 2, 2029 with indoor and outdoor stocking density and soil and vegetation requirements.

- All poultry operations certified before January 2, 2025 must comply by January 2, 2029 with exit area requirements.

New Metrics for Avian Living Conditions:

• Birds must be provided with year round living conditions that accommodate their natural behaviors including access to the outdoors, shade, shelter, exercise areas, fresh air, direct sunlight, clean water, materials for dust bathing and adequate outside space. Indoors must be sufficiently spacious to allow all birds to move freely, stretch both wings simultaneously, stand normally and engage in natural behaviors.. Continuous total confinement of poultry indoors is prohibited, though temporary confinement for allowed reasons will continue to be allowed.

• Chickens must meet indoor and outdoor stocking densities. Stocking density can be calculated two ways for compliance verification. Sq ft/bird or lbs of bird/sq ft.

Indoors for chickens:

Indoors for layers =

• Mobile housing = 4.5 lbs/sq ft or 1.5 sq ft/bird

• Aviary housing = 4.5 lbs/sq ft or 1.5 sq ft/bird

• Slatted/mesh floor = 3.75 lbs/sq ft or 1.8 sq ft/bird

• Floor litter housing = 3 lbs/sq ft or 2.2 sq ft/bird

• Other housing = 2.25 lbs/sq ft or 3 sq ft/bird

• Indoors for pullets = 3 lbs/sq ft or 1.7 sq ft/bird

Indoors for broilers = 5 lbs/sq ft or 2 sq ft/bird

Outdoors for chickens:

Outdoors for layers = 2.25 lbs/sq ft or 3 sq ft/bird

Outdoors for pullets = 3 lbs/sq ft or 1.7 sq ft/bird

Outdoors for broilers = 5 lbs/sq ft or 2 sq ft/bird

Other Metrics and Monitoring Practices:

• Perch Space: Layers must have at least six inches of perch space per bird and all layers must be able to perch at the same time, except in aviary housing where 55% of the birds must be able to perch at the same time. The alighting rail in front of next boxes may be included; floors in slatted/mesh flooring housing may not be included.
• Dust Bathing and Scratching areas: Dust bathing areas must be made available. Non-mobile housing with slatted/mesh floors must have at least 15% solid floor area for dust bathing without crowding.
• Artificial Light: May be provided to prolong the day length to provide up to 16 hours of continuous light per 24-hour period; 8 hrs of continuous darkness in a 24 hour period is required. Light intensity should be lowered gradually, and artificial light spectrum may not be manipulated to increase feed intake and growth rate.
• Soil and Vegetation: 75% of the outdoor space must be soil, and vegetation must be maintained as appropriate.
• Ammonia Monitoring: Weekly monitoring is required, with testing conducted at the birds’ head height. Levels over 20ppm must be mitigated and levels must not exceed 25ppm.
• Exit Areas: 1 linear foot of exit area (i.e. door width) for every 360 birds, measured across the base of the exit; no less than one exit for flocks less than 360 birds. Alternative plans may be allowed by MOSA which provide less than this required metric, if the plan is described in the OSP and demonstrates ready access to the outdoors is provided to all birds.
• Induced Molting is prohibited. In other words, the only molt that a flock can do must be a natural process.

Temporary confinement may be allowed when:
• Temperature: Below 32 or above 90.
• Age: broilers = up to 4 weeks; Pullets = 16 weeks; all other birds may be temporarily confined until they are fully feathered.
• Conditions where bird safety, health or well-being could be jeopardized.
• Risk to soil or water quality.
• Healthcare.
• Sorting/shipping.
• Nest box training for no longer than required for birds to establish the proper behavior, must not exceed 5 weeks total.
• For youth events (such as 4H, FFA) 1 week prior and 24 hours after the event.

For all livestock:
• Provide a full description in the OSP explaining how you monitor, treat, and mitigate lameness.
• Group housing is required for hogs, except farrowing/suckling sows, boars, and hogs with multiple documented instances of aggression or for recovery from an illness.
• Have records for all physical alterations and, specifically for pigs, if needle teeth clipping or tail docking is used, records must show that alternative methods to prevent harm failed. Update OSP with information about these alterations.
• Be sure to record the disposition of milk and meat during withdrawal periods if restricted inputs with a withdrawal period are used.
• Over a 24 hour period, shelter must provide sufficient space to lie down, turn around, stand up, fully stretch, and express normal behavior. For group housed cattle, bedded packs, compost packs, tie-stalls, free-stalls and stanchion barns are all acceptable as part of the overall OSP, however no animals may be housed for the entire day in a confined way.
• If you transport animals for any reason, provide information on the length of transportation and emergency measures you would have in place in case of an emergency, such as a vehicle breakdown or significant detour.
• All certified operations must have a written plan in your OSP for prompt, humane euthanasia for sick or injured livestock suffering from irreversible disease or injury, including practices to ensure animals are dead. Note that some forms of euthanizing animals are prohibited.
• When outdoors includes soil, vegetation must be maintained as appropriate for the area and species of livestock.
• Specifically for operations slaughtering livestock, have records showing FSIS/PPIA compliance verification and new verification requirements for PPIA exempt facilities.

More information can be found on the NOP’s website: https://www.ams.usda.gov/rules...
Contact us with any questions pertaining to the compliance of your operation.
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Strengthening Organic Enforcement

The compliance date of March 19, 2024 is right around the corner. Are you ready? Have you assessed your supply chain to ensure that all operations that need to be certified will be certified by the compliance date? Avoid supply chain upsets by making sure you have an organic certificate from all suppliers that need to be certified. MOSA is actively working toward full compliance as well. A few things to take specific note of:

• MOSA will soon be printing your organic certificate from the Integrity database. It will look a little different, but the information will be pretty much the same as it has always been.

• If you submitted your Fraud Prevention Plan (FPP) already, thank you! We will let you know if we have questions. If you have not yet submitted a FPP, submit it right away as we will otherwise be asking you to submit it as a pre-decision requirement at final review along with any other updates needed to assess compliance with the new regulations. Not getting your FPP submitted may delay us getting you your updated certificate.

• Do you use nonretail containers to ship or store certified organic products? Nonretail containers moving through the supply chain must display identification of the product as organic along with the production lot number. Furthermore, audit trail documentation for nonretail containers must identify the last certified operation that handled the agricultural product. The only nonretail containers that are exempt are those that are used to ship or store retail labeled products with visible organic identification. Be sure that your updates are submitted, approved and you have a plan for use prior to March 19, 2024.

• Exempt handlers will need to complete MOSA’s new Exempt Handler Affidavit. Exempt operations that must complete this form may include handlers that are supplying organic product to you or those that you use in your own supply chain. All organic products must be traceable back to the last certified handler, which may be through several uncertified handlers. It will be your responsibility to provide the documentation through all uncertified handlers in your supply chain.

• If you import organic products, import certificates issued out of the Integrity Database will be required as part of your documentation.

More information about the new strengthening organic enforcement regulation can be found on the MOSA website here: https://mosaorganic.org/streng....