United States Department of Agriculture 1400 Independence Avenue SW. NOP 5006

Agricultural Marketing Service Room 2646-South Building Effective Date: July 22, 2011

National Organic Program Washington, DC 20250 Page 1 of 3

Original Issue Date: 10/05/10 Authorized Distribution: Public

File Name: NOP 5006 Processed Animal Manures Rev02 08 31 18

Guidance

Processed Animal Manures in Organic Crop Production

Links Update: August 31, 2018

1. Purpose 

This guidance explains the policy for the use of heat processed animal manures in crop production 

operations certified as organic under the National Organic Program (NOP). This policy does not 

supersede requirements of other Federal and State laws and regulations. However, written procedures 

and records prepared by producers to meet NOP requirements may be the same as those prepared to 

meet other regulatory requirements.

2. Scope

This guidance applies to all organic crop producers. This guidance does not apply to compost teas or 

other products that may contain raw or composted manure.

3. Background

The NOP regulations require that uncomposted animal manures be applied at least 90 days prior to 

harvest for crops whose edible portions do not come in contact with the soil and at least 120 days prior 

to harvest of crops whose edible portions do come in contact with the soil. However, while the 

regulations do not place the same restrictions on properly composted animal manures, the regulations do 

not address heat processed animal manure products and their proper use in organic production. In the 

past, the NOP had determined that processed manures, since they had not been composted according to 

the NOP regulations, would fall in the category of uncomposted manure products for the purpose of 

determining any restrictions which should be placed on their use in organic production.

At its September 2006 meeting, the National Organic Standards Board (NOSB) made a recommendation 

regarding the use of processed animal manures in organic farming operations. In its recommendation, 

the NOSB said that when animal manures are treated to a certain temperature over a given period of 

time and then subsequently dried to a very low moisture level, the resulting product should fulfill the 

pathogen reduction requirements imposed on compost in the NOP regulations. Therefore, the NOSB 

recommended that the NOP issue guidance to the effect that processed manure products that meet 

prescribed minimum time, temperature, and moisture requirements, or processed manure products that 

have the same level of pathogen reduction as the prescribed process, should be allowed for use without 

pre-harvest time restrictions.

In reviewing the NOSB’s recommendation, NOP officials met with manufacturers of processed manure 

products and reviewed facilities used to produce these products. We also met with representatives of the 

Organic Materials Review Institute (OMRI) to discuss current practices for the use of these products in 

organic agricultural production. In addition, we reviewed and considered the Compost Task Force 

Recommendation dated April 18, 2002.
United States Department of Agriculture 1400 Independence Avenue SW. NOP 5006

Agricultural Marketing Service Room 2646-South Building Effective Date: July 22, 2011

National Organic Program Washington, DC 20250 Page 2 of 3

Original Issue Date: 10/05/10 Authorized Distribution: Public

File Name: NOP 5006 Processed Animal Manures Rev02 08 31 18

Upon completion of our review of the recommendation, task force report, supporting documentation, 

site reviews, and industry consultations, the NOP finds that it concurs with and accepts the NOSB’s 

recommendation to remove the time restrictions previously imposed on processed manure products and 

allow the unrestricted use of processed manure products when prepared in accordance with the 

guidelines in this document. We noted, however, that the NOSB placed a more restrictive annotation on 

the use of the processed manure, requiring that post-planting applications be applied below the surface 

of the soil.

Our review of the task force report indicated that such restrictions may not be necessary, so we have not 

incorporated that additional restriction into this operational policy.

We also noted that the NOSB recommendation specified a minimum temperature for the product to be 

held for at least one hour without prescribing a minimum time for continuous flow processes. In 

consulting with OMRI, we learned that achieving at least 165 degrees Centigrade in a continuous flow 

process will achieve the necessary pathogen reduction, so we added that option to the criteria for an 

acceptable process.

Finally, we noted that the NOSB recommended that processed manure test negative for the presence of 

Salmonella and fecal coliform organisms. In considering this element of the recommendation, neither 

the product manufacturers nor OMRI found this to be a practical requirement but agreed that a very low 

level of pathogens could be reasonably accomplished with the prescribed process. Therefore, in 

developing the policy for processed manures, we used the very low microbial counts consistent with 

current industry practice, which could be used to indicate a sufficient level of pathogen reduction.

4. Policy

Processed manure may be used as a supplement to a soil building program without a specific interval 

between application and harvest. As always, producers are expected to comply with all applicable 

requirements of the NOP regulations with respect to soil quality, including ensuring the soil is enhanced 

and maintained through proper stewardship.

Processed manure products must be treated so that all portions of the product, without causing 

combustion, reach a minimum temperature of either 150o F (66o C) for at least one hour or 165o F

(74o C), and are dried to a maximum moisture level of 12%; or an equivalent heating and drying process 

could be used. In determining the acceptability of an equivalent process, processed manure products 

should not contain more than 1x103 (1,000) MPN (Most Probable Number) fecal coliform per gram of 

processed manure sampled and not contain more than 3 MPN Salmonella per 4 gram sample of 

processed manure.

5. References

NOP Regulations (as amended to date)

7 CFR § 205.203 Soil fertility and crop nutrient management practice standard.
United States Department of Agriculture 1400 Independence Avenue SW. NOP 5006

Agricultural Marketing Service Room 2646-South Building Effective Date: July 22, 2011

National Organic Program Washington, DC 20250 Page 3 of 3

Original Issue Date: 10/05/10 Authorized Distribution: Public

File Name: NOP 5006 Processed Animal Manures Rev02 08 31 18

NOSB Recommendations

April 2002, Crops Committee Compost Tea Task Force Final Report.

September 13, 2006. Crops Committee, Recommendation for Guidance for Use of Compost, 

Vermicompost, Processed Manure, and Compost teas.

Approved on July 22, 2011