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August 2011 Archive for 100% Grass-Fed

RSS By: Randy Kuhn, Beef Today

Our family farming history began with my great-great-... (nine generations ago) grandfather Johannes. He, his wife and three children left Saxony, Germany, on April 20, 1734, aboard the ship St. Andrew, mastered by Capt. John Stedman. They landed at Philadelphia on Sept. 22 and eventually settled our family’s first "New World" farm near Society Run in Frederick Township, Montgomery County, Pa., in 1743. Pig farming was our family’s specialty until the mid 1950s. A lot has changed since then. Our BQA cow–calf operation includes 100% grass-fed registered Red Angus, Hereford and purebred Beefalo; 30 to 35 pastured Duroc and Spot pigs; 100 Freedom Ranger broilers; and 90 Golden Comet and Buff Orpington layers. We organically maintain 80 acres, comprising 15 acres in rotational pastures, 15 acres in tillable cropland, and alfalfa/mixed grass hay on the balance. We have never used chemical pesticides or herbicides on our pastures or hay fields. We are not a "certified" organic farming operation, but we prefer the natural/organic approach to help promote sustainability.

Organic or Conventional?

Aug 26, 2011


What is meant by organic production?


Organic production is a system that is managed in accordance with the Organic Foods Production Act of 1990 and regulations in Title 7, Part 205, of the Code of Federal Regulations to respond to site-specific conditions by integrating cultural, biological and mechanical practices that foster the cycling of resources, promote ecological balance and conserve biodiversity.



How does organic livestock production differ from conventional livestock production?


The National Organic Program (NOP) regulations specify requirements for livestock products to be sold, labeled or represented as organic. Organic management of livestock includes: (1) requiring organically produced livestock feed and forage; (2) prohibiting the use of antibiotics and hormones; (3) maintaining specific living conditions including access to pasture for ruminants and access to the outside, direct sunlight, fresh air and freedom of movement for all livestock; and (4) practicing preventive health care to minimize the occurrence and spread of diseases and parasites. Furthermore, organic livestock producers must develop an organic system plan, maintain production records and undergo annual on-site inspections to verify compliance with the organic regulations.

All animal agriculture systems, whether organic or conventional, must consider the dry matter demand and nutritional requirements of the class of animal for a given stage of life. One key difference with organic animal agriculture systems is that all ruminant systems must be pasture-based (i.e., actively grazing on a daily basis during the grazing season and with access to the outdoors and not confined during the non-grazing season). Many conventional livestock systems are also pasture-based but are not required to be pasture-based.


What resources are available for producers who are seeking more information on access to pasture requirements?


The NOP conducted four training sessions in 2010 for certifiers and organic producers on components of the new Access to Pasture rule. The trainings occurred on Feb. 25, 2010, in LaCrosse, Wis.; on March 24, 2010, in Albany, N.Y.; on April 7, 2010, in Denver, Colo.; and on April 26, 2010, in Woodland, Calif. All of these presentations are available on the NOP website at

Information on calculating dry matter intake (DMI) and associated worksheets and tables are available in the NOP Program Handbook, available at the website. These resources include: (1) a step-by-step guide to help producers understand the dry matter intake calculation requirements; (2) a worksheet to help producers perform DMI calculations easily; (3) reference tables for determining the dry matter demand for different types and classes of beef and dairy animals; and (4) a pasture worksheet to help producers establish a rotational grazing system by calculating the pasture acreage, number of paddocks and size of each paddock that an operation will need in order to balance the forage demands of their animals with the production capacity of the pastures. The National Research Council has additional resources for nutrient requirements for small ruminants (see, for example,

The NOP worked with the National Center for Appropriate Technology to develop new templates for organic system plans (OSPs) and other resources targeted to both producers and certifiers that will incorporate the new pasture requirements. These materials have been available since early 2011.



Organic Standards Part II

Aug 19, 2011

Organic Standards Part II

As you all know from time to time I review past blog posts and include your comments and questions.

This week we will be doing a follow-up to last week’s blog that was titled "Certified Organic? Sure! I Think?"

On Tuesday I received a n e-mail from Soo Kim of the Dept. of Agriculture in response to that blog.  I am always appreciative when someone points out inconsistencies in information or way’s to improve our farming practices and this is one of them.  Soo’s response is as follows’.  I hope this help’s you as it has helped me.

Hi, Randy. I came across your blog titled "Certified Organic? Sure! I think?" and hoped I could clarify some aspects of the organic standards. It seems you cited the proposed rule and public comments received during rulemaking, a necessary component of the rulemaking process before issuing a final rule (this helps to ensure that the public can have a chance to provide their insight and play a participatory role). In February 2010, the USDA’s National Organic Program published a final rule addressing organic livestock production and related provisions to ensure that livestock production regulations are clear and specific about feed requirements and living conditions and that they establish a pasture practice standard for ruminant animals. The final rule also address consumer expectations that ruminant livestock animals graze on pastures during the grazing season.

While there are lots of resources on the NOP website concerning the pasture rule, I can generally state that producers have to provide year-round access for all animals to the outdoors, recognize pasture as a crop, establish a functioning management plan for pasture, provide ruminants with pasture throughout the grazing season for their geographical location, and ensure ruminants derive not less than an average of 30 percent of their dry matter intake (DMI) requirement from pasture grazed over the course of the grazing season. To address one aspect of your article specifically concerning access to the outdoors, you are correct that continual total confinement of any animal indoors is prohibited. However, the regulations account for instances when temporary confinement or shelter may be necessary (e.g., animal’s stage of life, inclement weather). This specific portion of the regulations is available here.

If you have any further questions about the organic standards, please let me know. Meanwhile, if you’re able to print a corrected version of the article, we’d really appreciate it. Despite whether farmers choose to produce their livestock organically, we think it’s important that information reflecting the organic standards are correct.


Soo Kim

Department of Agriculture

Agricultural Marketing Service

Public Affairs Office


Again thank you very much Soo for the updated information and your professional willingness to correct my misinformation.  It is always my intent to correctly inform our readers with existing and new rules that govern their way of farming/ranching.

Certified Organic? Sure! I think?

Aug 13, 2011

Certified Organic?  Sure!  I think?

   Does anyone raise truly Organic Livestock?  Are you sure?  How do you know?  Are you certified through an Organic organization or the always trustworthy Government?  Do you think that the Government knows what Organic means to producers, what about the general public?  I’ve done research on this subject over the last decade, and every time I ask a question (or find information about becoming certified Organic), for either livestock or commodities, I wind up with more questions because everyone including the USDA has different requirements or rules that change as often as the price of corn or oil!

   There are so many producers out there that are claiming to be "Organic" or "Certified Organic" that when you see their operation you wonder, why would I want to be associated with that?!  Don’t get me wrong there are a few honestly certified producers that are doing everything in their power to be truly organic.  But after having spoken with our local PA Dept. of Agriculture health inspector, he stated that "there are so many producers out there claiming to be organic that the Dept. of Agriculture can’t regulate or check on all of them, so they don’t. "  So if you wanted to, you could claim to be organic or certified organic and no one can legally challenge your false claims.  I believe this is because the rules and regulations have so many loopholes and confusing propositions that are constantly being changed, that it’s hard to tell if someone is telling the truth.

   In a proposed "Certified Organic" rule the USDA defined a dry lot as ‘‘a confined area that may be covered with concrete, but that has no vegetative cover.’’  Two similar edited versions of the definition were also received.  One of the version received, which the USDA accepted, replaced the word ‘‘confined’’ with the word ‘‘fenced’’ That sounds nice doesn’t it?  They also modified "vegetative cover" as ‘‘little or no.’’ meaning NO GRASS/vegetation.   Responses asserted that ‘‘dry lot’’ is commonly used in certain regions to describe outdoor access areas.  Commenter’s that recommended revising the definition to include ‘‘little or no vegetative cover’’ were concerned that areas of sparse vegetation could qualify as pasture.  Otherwise known as a Feed-lot.

   Other commenter’s recommended revising the definition to clearly characterize dry lots as areas for continuous total confinement.  The prohibition on dry lots in the proposed rule has been stricken from this final rule due to comments received asserting that ‘‘dry lot’’ is a term which, in some regions of the U.S., describes a feature that can be compatible with organic livestock production. Accordingly, the definition of ‘‘dry lot’’ has been amended to clarify the characteristics by which a dry lot would be acceptable for organic ruminant livestock.  They may be fed organic feed stuff’s, but what is their quality of life?

   The USDA also accepted the commenter’s suggestion to modify "vegetation" with ‘‘little or no’’ in order to prevent the incorrect usage of dry lots that have some vegetation, as pasture.  The definition of ‘‘Dry lot’’ reads: ‘‘A fenced area that may be covered with concrete, but that has little or no vegetative cover.’’ 

So basically cattle can qualify under USDA criteria for Certified Organic when the majority of their lives are spent on concrete or as they put it "a dry lot".  Next week we’ll take a look at Certified Humane guidelines.  You thought Organic had allot of loop holes and wishy washy definitions, wait till you find out what we’ve experienced with regards to "Certified Humane" criteria!

"Access To Pasture"

   Under this provision the terms feedlot, yard, feeding pad are used interchangeably under the rule. Feedlot, yard and feeding pad are terms used to describe an area that functions as a space to provide feed rations, other than pasture, to livestock.  Beyond their functional similarity, these attributes do vary in how they are used (the amount of time that animals spend in feedlots) and designed (how much space do animals have in the feedlot). During the non-grazing season and when animals cannot be out on pasture, organic producers need an area to feed their livestock. Animals cannot be continuously confined in a feedlot, yard or feeding pad. When animals are in a feedlot, yard or feeding pad, they must have enough space to eat simultaneously and without competition for food.

Soooo, can Certified Organic Livestock be confined in a "Feed-lot" or not?  Re-read the last paragraph. In one sentence they state "Animals cannot be continuously confined in a feedlot".  Than in the same paragraph they state "When animals are in a feedlot,….."  Which is it?  I guess you really can have your concrete and eat it too!?

Understanding Confusion

Aug 06, 2011

Understanding confusion?

  You would think that when you hear of Cattle that are "Grass-fed" that would pretty much define what they are, based off of what they eat right?  Well….Not exactly.  Believe it or not the Government (being the USDA), has at "least" 3 definitions for the term "GRASS-FED"!  Wouldn’t it be nice if they would stop confusing consumers and stop making our lives as producers more difficult?

   According to the USDA, Grass and forage shall be the feed source consumed for the lifetime of the ruminant animal, with the exception of milk consumed prior to weaning. The diet shall be derived solely from forage consisting of grass (annual and perennial), forbs (e.g., legumes, Brassica), browse, or cereal grain crops in the vegetative (pre-grain) state. Animals cannot be fed grain or grain byproducts and must have continuous access to pasture during the growing season. Hay, haylage, baleage, silage, crop residue without grain, and other roughage sources may also be included as acceptable feed sources. Routine mineral and vitamin supplementation may also be included in the feeding regimen. If incidental supplementation occurs due to inadvertent exposure to non-forage feedstuffs or to ensure the animal’s well being at all times during adverse environmental or physical conditions, the producer must fully document (e.g., receipts, ingredients, and tear tags) the supplementation that occurs including the amount, the frequency, and the supplements provided.

Grass (Forage) Fed Marketing Claim Standard (October 16, 2007, Federal Register Notice (72 FR 58631)) - PDF

Than there are the discussion group’s notes taken from the meetings they had to come up with these standards.

Grass (Forage) Percentage

Comments: An overwhelming majority of the comments received expressed support that AMS (Agricultural Marketing Service, USDA). chose to develop and propose production standards for grass fed animals.  Further, the majority of comments supported

that the animal’s diet must be 99 percent or higher grass or forage-based. AMS also received a small number of comments suggesting a percentage other than the proposed 99 percent. A few commenter’s suggested the standard be 100 percent grass or forage-based.  One commenter in particular commented favorably on the increase from 80 percent to 99 percent but stated that "a 100 percent would be easier to verify."  YA THINK!?

There were also commenter’s who stated that the 99 percent grass or forage-based diet was too strict due to the diverse climate and rangeland throughout the United States.  One commenter stated that 99 percent of the diet coming from grass or forage is too high to have a balanced ration that provides good weight gains and also reduces nitrogen losses to the environment.

And the senseless babble of backroom confusion continued. 

Let’s just lay it all out and make it simple O.K.?

Cattle must be maintained on 100% GRASS/forage diets for their entire lives. 

NO GRAIN EVER!!  Simple to understand right?

   "Grass-finished" on the other hand means just that, they were "finished" on grass.  Nothing is covered or defined about what they were fed prior to being "finished".  The average finishing time for cattle is 6 weeks.  That’s approx. 6% of their entire lives, based on a finishing age for harvesting of 24 months.  Or an average of 200 pounds gained before harvest.

   "Grain-finished" could be the exact opposite of "grass-finished".  My question is why would you do that?  BIGGER faster isn’t necessarily better or healthier for you or the cattle.

   Compliance with all of a "Grass-fed" BEEF program should be monitored by on-farm/ranch visits and audits by the certifying agency that has certified the producer in question.  Just like "Certified Organic" producers right?  Not exactly.  In Pennsylvania there are no governing bodies that enforce statements or claims of being Certified Organic!  Unfortunately I’m not kidding.  I could market organic snails and folks that might eat those slimy little creatures would pay top dollar for them.  That is if my neighbor/competitor sold his snails as being marketed as Grain-fed or grass finished.  Now I’m kidding.

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