Bulletin #1025, Risk Management for Organic Dairies: Organic Dairy Certification Requirements

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Developed by Mary Yurlina, Director, MOFGA Certification Services LLC

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The Maine Organic Farmers and Gardeners Association (MOFGA) has been certifying organic producers since 1972, and was the first state-level program in the country. MOFGA Certification Services (MCS), LLC, a wholly owned subsidiary of MOFGA, is a USDA-accredited organic certifying agent, operating principally in the state of Maine. MCS evaluates producers, processors, and handlers to determine whether they conform to an established set of operating guidelines called the national organic standards, administered by the U.S. Department of Agriculture’s National Organic Program. Those who conform are certified by MCS and allowed to use a logo, product statement, or certificate to document their product as certified organic. For more information, visit the certification section on the Maine Organic Farmers and Gardeners Association website (www.mofga.org) or call 207.568.4142.

Table of Contents

Land requirements

  1. Pasture. Farm systems must have pasture to serve as a significant portion of feed for ruminant dairy animals, and pasture must be managed to maintain or improve plant, soil, and water resources. Certifiers must verify that a significant portion of the herd’s intake of dry matter is from grazing on pasture. Certifiers in the Northeast expect all animals six months of age and older to be outside on pasture during the grazing season from May through October. Farm systems with a ratio of animal units to pasture acres in excess of two to one must be able to demonstrate that they graze their animals intensively and efficiently, without sacrificing natural resources. Many certifiers will look to see whether the herd’s annual dry matter intake from pasture is around 30 percent. If your farm system has too few pasture acres, you will need to reduce the size of your herd or expand pasture acreage.
  2. Growing forage and grain crops. Purchasing certified-organic hay, baleage, grains, and silage from off-farm sources is permissible under the standards of the National Organic Program (NOP). However, most organic farms in Maine grow their own hay crops on fields that are part of their organic farm plan,1 thereby satisfying the majority of their herd’s feed requirements with on-farm production. Anyone growing livestock feeds must keep the following in mind:
  1. You may own the land you grow crops on, or you may use leased land, provided that you can demonstrate that you have control over what happens to the land.
  2. In order for any crop to be eligible for certification, the land it grew on MUST NOT have had any prohibited materials applied to it for a period of 36 months prior to harvest. Prohibited materials include but are not limited to commercial synthetic fertilizers, herbicides, pesticides, and fungicides (including seeds treated with these materials); sewage sludge or composts made from sewage sludge; and certain paper limes and industrial ashes.
  3. If you use leased land, you must have the landowner sign a landowner affidavit stating that no prohibited materials have been applied to the land during the 36 months prior to harvest of the crop you intend to market or use as organic. From here on, you are expected to make management decisions for this land in accordance with NOP standards.
  4. If you buy seed, look for certified-organic seed. The NOP requires organic farmers to use certified-organic seed if they can find the type, quality, and quantity needed. If that cannot be done, you may use conventional seed instead; however, be sure to get documentation that the seed is not genetically modified (GMO), genetically engineered (GE), or treated. You may NOT use GMO, GE, or treated seed. Do not let anyone tell you otherwise.
    • GMO or GE seeds: if you are opting to use conventional corn, soy, or alfalfa seeds, make sure you secure documentation that the variety you purchase is NOT genetically engineered. In addition, any legume seed such as alfalfa must NOT be coated with a genetically engineered inoculant. Discuss your concerns carefully with your seed dealer and be sure to get documentation.
    • Treated seeds: these are usually dyed pink, and this should tell you NOT TO PLANT, as the pink dye indicates a fungicide treatment. The NOP considers sowing treated seeds the equivalent of applying fungicide to your land, in which case your crop cannot be certified, and that field cannot be used for organic production for 36 months from the date of sowing.
  5. Your fields should be adequately buffered from any nearby sources of contamination. If your field is near a roadside that is sprayed with an herbicide, secure a no-spray agreement and establish an appropriate buffer. If your neighbor grows conventionally, consider the threat of spray drift and runoff, and establish a buffer zone accordingly. If pollen drift from a genetically engineered crop is a possibility in your neighborhood and you grow the same crop plant organically, contact your certifier immediately to determine the threat of cross-pollination and the steps you need to take to prevent it.

Equipment and facilities

  1. Barn. Many types of structures are acceptable as a shelter for herds. The inspectors sent by certifiers will consider cleanliness and space for natural animal behaviors. Housing arrangements must be configured to allow animals to have daily outdoor access summer and winter, where they can have fresh air, sunshine, and space to move around. Tying or restraining animals is not a long-term permitted practice.
  2. Milk room. All commercial dairy operations in Maine must be licensed with the Maine Department of Agriculture. Facilities, including the barn, milking facilities, and milk room, must meet requirements and an inspection as established in the Maine Department of Agriculture, Food and Rural Resources Rule Governing Maine Milk and Milk Products (Word). (For more information contact the state Dairy Inspection Program at 207.287.7631.) This rule outlines the procedures and standards governing the inspection and examination, licensing, permitting, testing, labeling, and sanitation of milk and milk product production and distribution.
  3. Manure management. Although we understand that season and weather affect a farmer’s ability to deal with manure, we don’t like to see manure get the upper hand. You should have reliable ways of removing manure and storing it until you can apply it to fields or use it to make compost. You must manage manure in a way that does not contaminate land or water, which means that certifiers may question unprotected piles. Manure application on frozen ground is illegal in Maine. You are also expected to maintain or improve the fertility of your fields. Therefore, you should use manure on crops and pastures as opposed to exporting manure off the farm.
  4. Feed storage. Feeds need to be protected from degradation and spoilage. If a farm produces or buys conventional feeds, MCS requires foolproof systems for segregating and identifying feed types. Certain types of parallel or split production may necessitate separate facilities.


  1. Organic feeds. Certified dairy farms must give 100 percent certified-organic feeds to all animals in the herd (from calves to cows) all of the time.
  2. Milk replacers. To the best of our knowledge, there are NO CERTIFIED-ORGANIC MILK REPLACERS. If you think you have found one, please check with your certifier before using it.
  3. Feeds during transition. It takes 12 months to transition a herd to organic management. Transitioning dairies are required to provide organically produced feeds to all animals all of the time for the 12 months and beyond. Because the NOP allows crops from fields in the last year of transition to be fed to cows that are transitioning to organic, you can organically produce feeds on your transitioning farm on land that is eligible for certification or in the last year of transition. In other words, fields and cows can transition together on the same farm, provided these fields are in the third year of transition. You can also purchase feeds from certified-organic off-farm sources. NOTE: A herd or a cow may transition from conventional to organic management once and only once. Should your dairy return to conventional management after being certified organic, you will not be able to recertify that herd for organic production. Those animals can never transition to certified organic again.
  4. Supplements. Vitamin and mineral supplements are permitted, but their ingredients must meet NOP standards. Stay clear of products with artificial colors or preservatives. There are several companies that make nutritional supplements for organic livestock. For more information about materials permitted for livestock products, see the NOP “National List of Allowed and Prohibited Substances,” section 205.603. Also see Raising Organic Livestock in Maine (listed under “For more information” below).

Animals and animal management

Good herd health is achieved through quality forage, clean living conditions, and access to the outdoors. These are the guiding principles of organic livestock management.

  1. Antibiotics and other banned substances. Farms that rely on medications such as antibiotics to maintain herd health should think twice about becoming organic. Dairies that are transitioning to organic must use organic health-care products and practices during the 12 months prior to certification and thereafter. You are expected to use antibiotics or other banned substances to save the life of a cow or to prevent suffering, but you must understand that the treated animal can no longer be part of the herd and is typically expected to leave the organic farm. Some farmers make arrangements with neighboring conventional dairies to have them serve as outlets for treated animals. Animals treated with antibiotics either during the 12-month transition to organic or after certification cannot be used to produce organic milk or meat.
  2. Hormones. With the exception of oxytocin (with restrictions on use), hormones are not permitted as a management tool. This means that you may not use hormones to synchronize breeding cycles for artificial insemination.
  3. Parasiticides. You may use Ivermectin in dairy animals if other management techniques have failed to solve a parasite problem (failed techniques must be documented in your organic farm plan). You must not use Ivermectin during the last third of gestation if the unborn calf is intended for certification. Any certified organic dairy animal that has been given Ivermectin cannot produce organic beef. Milk or milk products from treated animals cannot be represented as organic for 90 days following treatment.
  4. Replacement animals. Once a herd is certified, all animals must be raised organically from the last third of gestation onward. Replacement animals from off-farm sources must be certified organic. Adding a conventional animal to your herd will extend the transition period for the herd by another 12 months from the time you begin organic management of the new animal. As a result, we recommend that dairies in transition purchase only certified-organic animals.


  1. Maps. You should keep detailed maps of your facilities and fields. You should submit copies with your organic farm plan to the certifier. Aerial photos, National Resources Conservation Service maps, and maps from local tax offices are fine so long as fields and buffers are labeled and roads and other landmarks are identified. Maps should facilitate easy orientation.
  2. Receipts. Whenever you purchase feed, seed, forage, or other products for crop or livestock production for your farm, you should keep the receipt. Generally, inspectors are interested in dates, amounts, and whether animals, feeds, or seeds are certified organic.
    1. Feed invoices: organize by date and include supplier, certification status, and amount.
    2. Replacement animal documents: transitioning and certified dairies must purchase certified-organic replacement animals. Documents should identify the animal, source, and certifier.
    3. Receipts for supplies: keep receipts and labels for purchases such as field inputs, livestock minerals, and other products used on land, crops, or animals.
  3. Field activity records. You are expected to keep records of activities such as manure spreading, liming, seeding, and harvesting. If questions ever arise about crop management practices, you will have records to refer to for verification. A simple notebook or calendar will do.
  4. Crop harvest records. You should keep written harvest records for fields. This can provide you with important data. It is also necessary for your inspector in order to audit feeds for your herd and do a mass balance based on your feed chart.
  5. Milk production records. The company buying your milk will provide milk production, SCC (somatic cell count), and PI (pre-incubation) records. These should be readily available for your inspector.
  6. Seed search. Farmers are expected to document their search for organic seeds. You may need to investigate more than one source. If you purchase conventional seeds, you must be able to prove that the seed is untreated and not genetically engineered.
  7. Leased or borrowed land. Using leased or borrowed land requires a letter from the landowner stating that no prohibited materials have been applied for at least 36 months prior to harvest.
  8. Animal records. The inspector should be able to choose any animal on your farm and easily access records concerning the animal’s origins and health care. A card system (with one record card per animal) works well for many farmers. When you sell cows, there should also be a record documenting how each one was marketed and where it was headed. You should use reliable methods of identification for your animals such as calf photos, tattoos, or ear tags with a unique numbering system.

For more information

MOFGA Certification Services LLC
Phone: 207.568.4142

Maine Department of Agriculture, Food and Rural Resources, 2006. Chapter 329: Rule Governing Maine Milk and Milk Products (Word) Augusta, Maine: Animal Health & Industry Statistics and Rules.

Maine Organic Farmers and Gardeners Association, 2006. Raising Organic Livestock in Maine: MOFGA Accepted Health Practices, Products, and Ingredients (PDF). Unity, Maine: MOFGA.

United States Department of Agriculture, National Organic Program. For a continuously updated version of National Organic Standards, go to the Electronic Code of Federal Regulations; choose Title 7 – Agriculture; then Part 205 – National Organic Program.

1An organic production and handling system plan for a farm business submitted as part of an application for organic certification.

Northeast Center for Risk Management Education USDA’s Cooperative State Research, Education and Extension Service Maine Organic Farmers & Growers Association logo
This publication is sponsored by the Northeast Center for Risk Management Education under USDA/CSREES award #2004-49200-02254.

Information in this publication is provided purely for educational purposes. No responsibility is assumed for any problems associated with the use of products or services mentioned. No endorsement of products or companies is intended, nor is criticism of unnamed products or companies implied.

© 2007

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