National Organic Standards Board

Livestock Committee

Animal Welfare Discussion Document

Stocking Density

September 9, 2010

Introduction

Animal welfare is a basic principle of organic production. The Livestock Committee of the 

NOSB considers that a focus on animal welfare warrants appropriate and effective regulation. 

Good animal welfare requires that animals be able to perform species specific behaviors and 

enjoy as natural and normal a life as possible. 

From its conception, regulation in organic agriculture was intended to provide conditions that 

foster the natural behavior of livestock. Since research in organic animal production has 

increased considerably, it is now possible to obtain science-based evidence for justifying and 

supporting expanded regulation for improved animal management practices. 

With this proposal, which involves several terms defined and added language to §205.239

Livestock living conditions, the Livestock Committee intends to move closer to the goal 

of providing stricter definitions for animal welfare in certified organic operations.

Background

The need for specificity regarding animal welfare has been considered by the Livestock 

Committee for many years. Consumers have become increasingly concerned about the 

welfare of farm animals. Organic farmers have led the way in animal welfare, and continuous 

improvement and clarification of the Standards are a major part of that. Stocking density, 

outdoor access, pasture, and outcome based standards are important components. 

Livestock Committee members wish to provide specifics that will reduce confusion between 

producers, inspectors and certifiers. Further, the Livestock Committee determined that the 

imprecise language had created unintended production practices which could allow the welfare 

of some animals to be compromised. 

The following document is a continuation of the fall 2009 NOSB animal welfare 

recommendation; the intention of this document is to refine, not replace, topics related to 

animal stocking rates. The National Organic Standards Board is presenting a framework to 

include the topic of stocking rates in the regulation and to invite additional discussion. In 

presenting the current proposal for discussion, the Livestock Committee carefully reviewed 

studies presented on animal welfare, considered existing legislation from other countries, and 

weighed comment from the organic community. Some of the major documents reviewed were: 

American Humane

Animal Welfare Approved

Global Animal Partnership

Humane Farm Animal Care

Department for Environment, Food and 

Rural Affairs (UK)

Organic Production Systems, General Principles, and 

Management Standards (Canada)
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Relevant Areas in the Rule

Those areas of the Rule which impact animal welfare include §205.237 Livestock feed,

§205.238 Livestock health care practice standard and §205.239 Livestock living 

conditions. However, historical context relating to animal welfare and the intent of the Rule is 

best found in the testimony provided to the NOSB on November 28, 2007, by Kathleen 

Merrigan and William Lokeretz, both of Tufts University at that time. Dr. Merrigan reflected 

upon the time she had spent in helping write the Organic Foods Production Act as staff of the 

US Senate Committee on Agriculture, Nutrition and Forestry. The introduction to their 

presentation is reproduced here:

“The United States Congress foresaw the need to elaborate livestock standards in 

1990 when it passed the Organic Foods Production Act. The report accompanying the 

Senate bill included the following statements anticipating additional standards and 

directing the NOSB to recommend additional standards to the Secretary. 

More detailed standards are enumerated for crop production than for livestock 

production. This reflects the extent of knowledge and consensus on appropriate 

organic crop production methods and materials. With additional research and as 

more producers enter into organic livestock production, the Committee expects 

that USDA, with the assistance of the National Organic Standards Board will 

elaborate on livestock criteria. (Report, 292) 

There are not many organic livestock producers at this time, perhaps as few as 

one hundred. A major reason is that few producers are willing to invest in raising 

animals organically since USDA explicitly prohibits meat and poultry from being 

labeled as organically produced. There is also little consensus on appropriate 

livestock standards and thus State and private programs vary widely. (Report, 302) 

The Board shall recommend livestock standards, in addition to those specified in 

this bill, to the Secretary. (Report, 303)2

These passages do not explicitly discuss health and welfare, but the general 

consensus of the organic community is that animal health and welfare would be 

encompassed whenever such standards were developed. Also, records show the 

central role played by The Humane Society of the United States in advocating for 

passage of OFPA, and it was widely understood at the time that organic livestock 

production would eventually include specific standards requiring superior welfare for 

animals. 

Animal health and welfare standards were also anticipated by USDA when it 

promulgated the National Organic Program Final Rule. The Preamble accompanying 

the NOP Final Rule describes several animal health and welfare practices, most of 

which have yet to be fully articulated by the program. According to the Description of 

Regulations, an organic livestock producer must: 

• Select species and types of livestock with regard to suitability for site-specific 

conditions and resistance to prevalent diseases and parasites 
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• Provide a feed ration including vitamins, minerals, protein, and/or amino acids, 

energy sources, and, for ruminants, fiber. 

• Establish appropriate housing, pasture conditions and sanitation practices to 

minimize the occurrence and spread of diseases and parasites. 

• Maintain animals under conditions which provide for exercise, freedom of 

movement, and reduction of stress appropriate to the species. 

• Conduct all physical alterations to promote the animals’ welfare and in a 

manner that minimizes stress and pain. 

• Establish and maintain livestock living conditions which accommodate the 

health and natural behavior of the livestock. 

• Provide access to the outdoors, shade, shelter, exercise areas, fresh air, and 

direct sunlight suitable to the species, its stage of production, the climate, and 

the environment. 

• Provide shelter designed to allow for the natural maintenance, comfort level, 

and opportunity to exercise appropriate to the species. 

Furthermore, in sections relating to comments, the Preamble describes several issues 

that the Secretary understood would require elaboration in the short-term, but for 

which he had insufficient expertise to prescribe. In these cases, a central role for the

NOSB is established, with the Board soliciting public comment, building consensus, 

and providing expert recommendations to USDA on animal health and welfare 

standards. 

• (Confinement) species-specific guidelines would be developed in conjunction 

with future NOSB recommendations and public comment. 

• We will seek additional input from the NOSB and public comment before 

developing such standards (on a specific length of time that cattle or other 

species may be confined prior to slaughter). 

• We anticipate that additional NOSB recommendations and public comment will 

be necessary for the development of space requirements. 

• The NOP will work with the NOSB to develop additional guidance for managing 

ruminant production operations. 

• We will continue to explore with the NOSB specific conditions under which 

certain species could be temporarily confined to enhance their well-being.”

Discussion

The tables below list livestock by species and weight. The indoor bedded space allowance is 

to be considered a minimum for housed animals. Outdoor runs for cattle are to be considered 

a minimum during the non-grazing season when weather allows animals to leave the indoor 

bedded area. Cattle pastured during the non-grazing season may not require an indoor 

bedded area. Piglets and chicks must be protected from freezing weather, so outdoor runs 

would not be necessary. Calves, lambs, kids, and other young animals require protection from 

frostbite.
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Basic outcome standards for hygiene, locomotion, body condition, lesions and injury would be 

expected in addition to the minimum space requirements. No more than 5% of ruminant 

animals should have an extremely low body condition score, be obviously lame, or have 

lesions or injuries. No more than 2% of non-ruminant animals should have an extremely low 

body condition score, be obviously lame, or have lesions or injuries. No animals should have 

broken tails. There are many welfare groups writing standards with numbers and consumers 

are demanding animal welfare certification. Ultimately, the Livestock Committee will need to 

include numbers with the outcome based standards.

The less space provided per animal the more labor intensive it may be to keep them clean and 

in good health. Bedding keeps animals warm, clean, and dry and also protects animals from 

developing lesions due to abrasion on rough surfaces. Animals must be managed in a manner 

that lameness does not become a common and routine occurrence as a result of diet or 

housing. If routine hoof trimming due to lameness is required adjustments to diet or 

environment are indicated. Outdoor access allows exercise to enhance muscle tone and 

relieve boredom. 

Bison are not domesticated animals and therefore indoor bedded space would be an added 

stressor. 

Poultry houses and outdoor areas are to be managed in a manner that allows birds to perform 

natural behaviors which minimize stress and aggressive acts. Poultry mortality lessens when 

perches are provided because they encourage natural behaviors; strengthen bones via 

exercise, reduce aggression, and mortalities. Perches also allow for maximum use of vertical 

space within the house. Two square feet of outdoor space is required because paddocks need 

to be rotated to minimize parasite load for the birds and to protect the soil. 

Outcome based standards require that birds be in good body condition, have good feather 

cover for stage of life, no more than 2% with impaired gait, poor hygiene, lesions or other 

injuries. Like ruminants, poultry would not need to be scored unless a problem is obvious.

Mobile poultry units require the same amount of indoor space per bird but allow the house to 

be moved so birds always have access to fresh vegetation.

§ 205.239 Livestock living conditions. (Mammalian section)

(c) The producer of an organic livestock operation may provide temporary confinement for an 

animal for the following reasons. If only one animal requires treatment another animal of the 

same species should be within visual proximity as a lone animal experiences increased stress. 

Temporary confinement may last no longer than necessary to safely perform the procedure, or 

address the condition: 

(5)(iii) Ventilation in confined housing must be adequate to prevent buildup of ammonia. 

Ammonia level testing must be documented and ammonia levels must be at or below 25ppm.
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Livestock Indoor Bedded Space / 

Animal

Outdoor Runs and Pens

The space allowances listed below are to be considered minimums when animals cannot be 

provided pasture access. Young may be kept indoors when there is danger of frostbite. 

Bison weight (pounds) NA Square feet

Up to 220 NA 70.0 

220-440 NA 120.0

440-770 NA 190.0

Over 770 NA 400 .0

Beef cattle weight (pounds) Square feet Square feet

Up to 220 15.0 10.0 

220-440 25.0 20.0 

440-770 40.0 30.0 

770-1100 50.0 40.0 

over 1100 10.0 sq. ft per 220 pounds 8.0 sq. ft per 220 pounds 

live weight 

Dairy cattle weight (pounds) Square feet Square feet

Up to 220 15.0 10.0 

220-440 25.0 20.0 

440-770 40.0 30.0 

770-1100 50.0 40.0 

over 1100 10.0 sq. ft per 220 pounds 8.0 sq. ft per 220 pounds 

live weight 

Sheep and goats (pounds) Square feet Square feet

Adults up to 230 16.0 10.0

Doe with one kid 22.0 12.0

Kid: up to 75 4.0 2.0

Swine Square feet Square feet

Sows and piglets 48.0 40.0 

Sows 30.0 30.0 

Boars 64.0 85.0 

Growing pigs (pounds) Square feet Square feet

Up to 22 1.0 0.5

22--44 2.0 1.0

44--110 3.0 1.0 

110--154 4.0 2.0

154--220 5.0 2.5

220--265 6.0 3.0
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Rabbits Square feet Square feet

Adult rabbits 3.0 20.0

Pregnant does 5.0 20.0

Doe and litter 8.0 20.0

Young rabbits 5-12 weeks 1.0 N/A

Reserved for additional 

species

§ 205.239 Livestock living conditions. (Avian section)

(1)(iv) Outdoor access should be provided at the rate of 2 square feet per bird. This would 

allow for rotation of paddock, re-growth of any vegetation, and reduced parasite load.

(3) Ventilation must be adequate to prevent buildup of ammonia. Ammonia level testing must 

be documented and ammonia levels must be at or below 25ppm.

(h) Space Allowance

Poultry housing must be sufficiently spacious to allow all birds to move freely, stretch their 

wings and engage in natural behaviors. Perching areas and nest boxes may not be used in the 

calculation of floor space. Slatted/grated floors may be considered floor space. 

(i) Birds in mobile poultry units are subject to the same minimum space requirement as housed 

birds. 

Poultry Indoor Bedded Space / 

Animal

Outdoor Runs and Pens

Square feet Square feet

Laying hens 1.5 

1.2 / bird with 6 inches perch 

space / bird

2.0

Pullets 1.0 / bird with 4 inches perch 

space / bird

2.0

Breeders 1.5 / bird

1.2 / bird with 6 inches perch 

space / bird

2.0

Broilers 1 sq. ft. / 6 lbs. 1 sq. ft. / 3 lbs.

Turkeys and Geese—

breeding, laying, or meat birds 

(pounds)

1 sq, ft. / 7 lbs. 1 sq. ft. / 7 lbs.

Ducks-meat 1.0 3.0 

Ducks-laying hen 2.5 6.0 

Ducks—breeder 1.5 6.0 
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Mobile poultry units Square feet Maximum number of birds / 

acre

Laying hens 

Broilers 

Turkeys 

Geese 

1.5 / bird

1.0 / bird

7 pounds / square foot

7 pounds / square foot

Laying hens: 800/acre

Broilers:1000 /acre

Turkeys:540/acre

Geese:540/acre 

Reserved for additional 

species

(i) Access to Outdoors 

(1) Doors should be spaced uniformly over the length of the poultry house. There must be 

direct access to outdoor areas. These should be at least 14 inches high and spaced evenly 

about the building. The total door opening available must be 6 feet per 1,000 hens. 

Committee Vote

Motion: Jeff Moyer Second: Kevin Engelbert

Yes: 7 No: 0 Abstain: 0 Absent: 1