Changes to the National List in the Organic Standards regarding Methionine for Poultry
By Mark Geistlinger, Certification Specialist
Methionine is an essential amino acid, a building block of protein, that is not produced by animals and is limited in the grain-based diets typically fed to commercial egg-laying or meat poultry. Since methionine is required for basic cell development, birds that are deficient in methionine do not convert feed efficiently, grow quickly, or produce as many eggs. Also, because methionine is a significant component of feathers, a methionine deficiency can result in poor feather growth and increased pecking in a flock.
There are three synthetic forms of methionine that are included in the National List of synthetic substances allowed for use in organic livestock production, though the amounts of synthetic methionine that can be fed are restricted (limited) according to the type of poultry: 2 pounds per ton of feed for laying chickens, 2.5 pounds for broiler chickens, and 3 pounds for turkeys and all other poultry. At the end of January, a significant change went into effect in the National List entry for methionine: these maximum rates can now be averaged per ton of feed over the life of the birds in the flock rather than being maximum amounts in each ration, as the restriction previously required. This change will allow poultry producers to feed more methionine at certain stages of a bird’s life, such as during the critical early weeks of development, as long as the producers then feed a reduced amount of methionine during other stages, so that the average amount of synthetic methionine fed over the lifespan is not greater than the allowed average amounts.
This change means that poultry producers and MOSA can no longer simply view the methionine value on a ration label to determine if the producer is complying with the methionine restriction in the National List. For producers who decide to feed a variable rate of synthetic methionine, more information will need to be provided to MOSA so we can verify that the producer has a feeding plan that allows compliance with the new restriction.
For 2019, MOSA will ask all poultry producers during Initial Review—the desk audit MOSA performs of a client’s application before it is sent to the annual inspector--if they intend to feed a variable rate of synthetic methionine. Poultry producers will receive a “More Information Needed” letter during Initial Review which we hope will allow clients to quickly inform MOSA of their intention regarding providing methionine in their rations this year. Based on responses to these questions, there will likely be three groups of poultry producers regarding methionine: those who do not feed any synthetic methionine, those who do feed methionine but at a fixed rate, and those who feed methionine at a variable rate.
MOSA will also be asking our MOSA-certified feed manufacturers questions regarding methionine during the Initial Review process. We will need to know if they intend to change the methionine rates in their stock feed formulations and if they will be offering variable rate methionine ration plans to their customers who purchase custom feed blends. While the organic poultry producer is ultimately responsible for maintaining compliance with the new National List restriction, MOSA appreciates the vital role certified feed manufacturers play for their feed customers, so will be verifying that any variable rate rations they provide are part of a compliant overall plan.
For those poultry producers and feed manufacturers who do intend to feed or produce rations with a variable rate of methionine, MOSA will require during Initial Review that they provide a written plan—or complete a new form that MOSA has developed for their type of operation--that provides the details necessary for MOSA to determine compliance with the new restriction. These plans will be especially important regarding rations for poultry, such as laying hens, that may not have completed their lifespan during one annual organic certification cycle.
For the next step after Initial Review in the certification process, the on-site Inspection, MOSA will verify if poultry producers and feed manufacturers are following their stated plan regarding feeding or producing rations with synthetic methionine. For those clients feeding or producing rations with variable rates of methionine, the inspector will also verify that the client is maintaining the records necessary to show that they are following the plan they provided to MOSA, and will perform an audit of these records to determine if the plan is being followed. Some producers may need to record information that they have previously not maintained so the inspector can use the feed records for the flock (such as receipts from the manufacturer) to determine average methionine-feeding rates per bird. Examples of this information include the average number of birds eating each ration and the dates each ration was fed.
Finally, MOSA will assess whether manufacturers and producers have complied with the new restriction, or are on track toward compliance, during the last step of the annual certification process, Final Review. Any clients who are providing methionine at a rate higher than the allowed average amounts, and do not appear to be following the plan they provided to MOSA, will be required to alter their feeding protocols to come into compliance with the National List restrictions.
The new language for the methionine entry in the National List will provide poultry producers and feed manufacturers greater flexibility in how they distribute synthetic methionine over the lifespan of the poultry in their operation. With this new flexibility, though, comes challenges for MOSA and our clients in verifying and documenting compliance with the new allowance. MOSA intends to educate clients regarding the rules change, assist them in developing recordkeeping tools to track their efforts to comply with the rule, and then determine if they are, in fact, maintaining compliance. We hope to partner with our clients to perform these tasks efficiently and smoothly over the course of this inspection season, and welcome questions and comments from clients affected by this new change regarding methionine.