Organic dairy industry approaches life with “Harvey”

For U.S. dairy farmers, who are interested in certifying their operations as organic, June marks a deadline for implementing a notable rule change in the USDA’s national organic standards for milk production.

On June 8, the “Harvey rule” takes effect and will require dairy farmers, who are interested in converting their herds to organic milk production, to do more strategic planning and budgeting.

The “Harvey rule” was named after Arthur Harvey, an organic blueberry farmer and organic certifier, who filed a lawsuit in 2002 demanding that USDA’s National Organic Program (NOP) regulations conform to the language and intent of the legislation – the Organic Food Production Act (OFPA) of 1990. A span of 12 years had passed between the publishing of the OFPA legislation and full implementation of the regulations.

An avid advocate of organic food production and a stickler for detail, Harvey challenged many aspects of the regulations. One of those involved milk.

Life with Harvey
The USDA regulation allowed 20 percent of a converting dairy herd’s ration during the first nine months of the transition year to be non-organic feed. Harvey asserted that federal law regarding organic milk production required farmers to provide cows with only certified organic feed and pasture for one full year before the milk could be labeled organic. (It takes a full year of organic practices to transition a dairy herd to organic milk.)

The courts agreed with Harvey and the rest is history.

Under the new rule, any feed or forage purchased for a transitioning dairy herd must be certified organic. Dairy cattle also may consume feed and forage that is raised on the farm or graze on farm pastures as long as they are in the final year of transition to organic. (That means, those crops and pastures that have completed 24 months of the 36-month organic conversion may be used.)

Ultimately, “life with the Harvey rule” benefits the organic milk industry by adding value and meaning to the “certified organic milk” label.

Challenges for newcomers
The rule change has helped to spawn short-term challenges. The approaching deadline of the Harvey rule provided incentive for some dairy farmers to make the switch to organic milk production before the changes.

Organic milk supplies in 2007 increased by 40 percent over the previous year’s industry growth rate. Since demand continues to rise at 20 to 25 percent, industry analysts expect organic milk and dairy product demand to continue to experience robust growth. The industry could see organic milk production settle down and most likely “go short” again in 2008 and 2009. Any new milk entering the market after June of 2007 must meet the new regulations. So the “spike” could begin to decline after June 9, 2007, as farmers finish their transition under the old rule.

In the short-term, transitioning farmers will want to carefully evaluate their financial strategies and have a tested, reliable buyer of their milk. Rising farm and fuel input costs; a limited supply of competitively priced organic feed, forage and seed; and more farm acres being planted to corn for ethanol production are key factors that could significantly affect farm budgets – especially during the transition period when non-organic milk income must support organic production costs.

Despite these challenges, organic milk markets continue to offer dairy farmers a growing market that historically has carried long-term, economic advantages. Most organic milk processors, cooperatives and marketing organizations provide special education programs and financial assistance for transitioning dairy farmers. These types of programs will continue to play a vital role in the growth and development of a strong, certified organic milk supply.

USDA reviews grazing standards
Another regulatory change facing the organic milk industry is that the USDA will be providing more detailed regulations on grazing standards. The NOP has given notice that the regulation on pasture for organic ruminants will be revised.

The organic dairy industry, which has been working to secure clarification on organic milk production standards for years, is advocating for a minimum pasture intake standard to be added to the organic regulations. According to the National Organic Standards Board (NOSB) Livestock Committee guidance recommendation, organic dairy livestock over six months of age should graze on pasture during months when pasture can provide edible forage. The grazed feed should provide significant intake, at a minimum average of 30 percent of the dry matter intake (DMI) during the growing season for no less than 120 days per year.

While most in the organic dairy community believe that the 30 percent DMI is achievable (Horizon Organic, included), there is huge merit in also bringing the cow-to-grass relationship (which is critical to long-term plant and soil health and the sustainability of the land) into the discussion. Done properly, year-round grazing that is managed and timed carefully, ensures the health of the cows and the micro-environment of the soil’s surface. Done poorly, year-round grazing focused only on a DMI level, could deplete long-term soil, plant and pasture health and cattle nutrition.

The organic dairy industry should also advocate for holistic pasture management practices that prevent overgrazing and damage from trampling by cows and optimize the nutritional value and sustainable growth of grass and pastures. PD

—Submitted by Horizon Organic