Livestock:OmnivoreDiets

National Organic Standards Board

Livestock Subcommittee 

Discussion Document:Omnivore Diets

August 21, 2012

I. Introduction

The National Organic Standards Board (NOSB) Livestock Subcommittee (LS) seeks the 

organic community’s discussion on the framework for natural omnivore diet materials, 

production, manufacturing, and commercial availability. Pigs, chickens, and turkeys are 

omnivores. These omnivores eat primarily both plants and non-plant (meat) materials. 

Cattle, sheep, rabbits, and bison are herbivores. As herbivores, they eat primarily plant 

materials. The LS views the natural behavior of chickens, turkeys, and pigs to be 

omnivorous. Therefore, the LS is considering the options of providing both plants and 

animal materials that are compatible with organic principles, production practices, and 

that allow omnivores their natural diet of plant and animal materials rather than feeding 

an unnatural herbivore diet. The LS is seeking stakeholder input on the issue of an 

omnivorous diet for organically raised omnivores. 

 

II. Background

Chickens, turkeys, and pigs are omnivores. Omnivores, by nature, eat plant and nonplant materials. Organic production practices require that poultry and pigs be reared 

outdoors and on the soil. Because of this requirement, poultry and pigs should already 

be consuming plant and animal materials. These materials may include (1) grass and 

other plants, (2) insects and other invertebrates, (3) carrion, (4) vegetables, (5) fish or 

meat materials naturally, (6) herbs, (7) fruits, and (8) berries, nuts, and whatever else 

they find to eat. By foraging, the animals are performing their natural behavior in 

consuming a diverse diet that includes non-plant life. 

Practical poultry and swine diets fed for normal growth, maintenance, production, and 

reproduction require essential amino acids, minerals, vitamins, and possibly fatty acid 

supplementation. As the organic community moves toward reducing or removing 

synthetic supplements in omnivore diets, a real need exists for organic omnivore 

producers to provide or be provided options for supplying the essential nutrients to 

these omnivores. Essential nutrients are needed in poultry and pig diets due to their 

inability to manufacture certain nutrients in adequate amounts for maintenance, growth, 

reproduction, and production. While some organic practices, including access to biodiverse healthy pastures may provide some of these nutrients, supplementation may 

still be required. A case in point is methionine, an essential amino acid for poultry and 

pigs. Methionine comes in natural and synthetic forms. Methionine is naturally present 

in all feedstuffs with protein; however, the amount of methionine present varies among 

the various feedstuffs. Natural sources of methionine are corn gluten meal, crab meal, 

fishmeal, blood meal, alfalfa meal, and sunflower meal according to the NOP, (2012), 

Methionine Task Force, 2011, and NOP Technical Review of Methionine, 2011. There 
Livestock:OmnivoreDiets

is at least one company that market sea kelp which is claimed to replace synthetic 

methionine There is an organic feed mill which manufactures a soy free feed mix using 

fishmeal for providing sufficient amino acids( methionine, lysine, etc.), mineral, vitamins 

( Favre, 2012). However, the mill manufactures medium to small formulations, primarily 

for small or hobby poultry producers. The cost and availability at a commercial level 

may be prohibitive. As it relates to fish meal, there seems to be an inadequate supply of 

fish meal with no synthetic preservatives added that would make fishmeal a possible 1:1 

replacement for synthetic methionine. There is interest in developing a natural source 

for methionine through extraction, fermentation or hydrolyzing protein, but at present, 

none of these processes currently provide a commercially viable alternative to synthetic 

methionine. (Fanatico, 2010). There is a potential herbal methionine on the market in 

India that might have applicability in the United States. Research results are promising 

and mixed. (Walker, 2012). Chattopadhyay, 2006 and Halder, G., and Roy, 2007 

reports a 1:1 replacement for synthetic methionine with herbal methionine in broiler 

rations. However, Salome, et.al. 2010 reported inferior results. The difference could be 

due to herbal ingredients in the natural methionine product. Salome, et. al. 2010 

suggested that the methionine requirement of broilers could be met by the 

supplementation of DL-Methionine and the use of animal protein sources. 

Synthetic methionine was first petitioned in 1995, with technical reviews in 1996, 1999, 

2001, and 2011. Currently, synthetic methionine is allowed in poultry diets at a 

maximum level of 4 pounds per ton of feed for layers, 5 pounds for broilers, and 6 

pounds for other poultry. From October 2, 2012 to October 1, 2017, the step-down rate 

will be 2 pounds for layers, 2 pounds for broilers, and 3 pounds for other poultry. 

Methionine will be up for a sunset review prior to 2017 and a new petition by the 

Methionine Working Group (MWG) has been submitted. Therefore, the LS is seeking to 

advise and assist in increasing the dialogue in the organic community on possible 

approaches to obtaining viable and commercially available natural methionine 

alternatives for poultry before the October 31, 2017 sunset date for synthetic 

methionine. 

Meat by-products and fish meals are good natural sources of essential minerals and 

vitamins. LS solicits our stakeholder input on possible ways to reduce synthetic 

nutrients (minerals, vitamins, and amino acids, etc.) in organic livestock rations by 

organic omnivore producers regardless to scale and type of operation. Significant work 

has been done on alternatives to synthetic methionine; yet more effort is still required. 

Time is of the essence. We believe that the current work into researching natural forms 

of methionine is encouraging. However, it needs to be accelerated. It could be that not 

one, but multiple organic practices may be required in order to provide a viable 

alternative to synthetic methionine. 
Livestock:OmnivoreDiets

III. Relevant Areas of the Rule

Relevant areas of the rules are briefly stated in this section. At Section 2110(3) of the 

Organic Foods Production act (OFPA) it reads, “.... no use of growth promoters and 

hormones on such livestock, whether implanted, ingested, or injected, including

antibiotics and synthetic trace elements used to stimulate growth or production of such 

livestock.” The National Organic Program regulatory text at 205.239 (a) states, “the 

producer of an organic livestock operation must establish and maintain livestock living 

conditions which accommodate the health and natural behavior of animals.” The rule

at §205.239(a) (1) further asserts that “access to the outdoors, shade, shelter, exercise 

areas, fresh air, and the environment are required.” At §205.238(a)(2), it reads, 

“provision of a feed ration sufficient to meet nutritional requirements, including vitamins, 

minerals, protein and/or amino acids, fatty acids, energy sources, and fiber (ruminants)” 

is required. 

At § 205.237 Livestock feed.

(a) The producer of an organic livestock operation must provide livestock with a total 

feed ration composed of agricultural products, including pasture and forage, that are

organically produced and, if applicable, organically handled: Except, That, non-synthetic 

substances and synthetic substances allowed under §205.603 may be used as feed 

additives and supplements, (b) the producer of an organic operation must not: (1) use

animal drugs, including hormones, to promote growth; (2) provide feed supplements or 

additives in amounts above those needed for adequate nutrition and health 

maintenance for the species at its specific stage of life; (3) feed plastic pellets for 

roughage; (4) Feed formulas containing urea or manure; 

(5) feed mammalian or poultry slaughter by-products to mammals or poultry; or (6) use 

feed, feed additives, and feed supplements in violation of the Federal Food, Drug, and 

Cosmetic Act.(OFPA, 2002). 

IV. Discussion

Prior to the 1950’s poultry and pigs were fed a plant and meat based diet without 

synthetic amino acids such as methionine. One former NOSB member stated, “we have 

seemingly made vegetarians out of poultry and pigs” in §205.237(5) (b). As the organic 

community moves toward reducing or removing synthetic nutrients in the diets of 

poultry, a heightened need exists for the organic community to rally around omnivore 

producers to marshal our collective efforts in finding viable alternatives to synthetic 

methionine, and to help find approaches for making them more commercially available. 

The approaches need to be compatible with (1) omnivore natural behavior and food 

sources, (2) organic principles, and (3) good organic omnivore management practices.
Livestock:OmnivoreDiets

To enhance our ability to consider and incorporate public comment into our decisionmaking process, the LS is seeking public input on this topic as a means of addressing 

this important concern. In particular, the LS seeks input regarding solutions to low 

supply of materials, commercial availability, approaches for providing a greater 

opportunity for the expression of an animal’s natural behavior and providing a path for 

nutritional management of omnivores as omnivores rather than feeding a natural 

omnivore as a vegetarian or herbivore. 

V. Discussion Questions Request from Stakeholders 

The LS is seeking the public’s perspective on the questions below. (Please indicate the 

question number in responses provided to these questions below.) 

1. Would you recommend the LS look at a possible annotation to allow 100% 

organic meat scraps or by-products to be used in omnivore diets (poultry and 

pigs), since it is natural for these omnivores to consume both plant and animals 

materials? Explain. 

2. Natural herbal methionine, potato meal, and corn gluten meal are showing 

promising results. Should this type of research effort increase? Explain. 

3. There is a natural herbal methionine manufacturer in India that touts their product 

as being a 1:1 replacement for synthetic methionine. How can this product be

brought to commercial availability/viability within the next three years in the 

United States?

4. How can the organic community spur more production and manufacturing of 

natural amino acids, including methionine and lysine, vitamins, and minerals 

products for livestock and aquaculture rations in the next three to five years? 

5. While the FDA regulates the safety of meat/slaughter by-products, what 

additional organic regulations or safeguards should be in place before organic 

livestock producers feed mammalian or avian slaughter by-products to their 

omnivore livestock? 

6. Would the organic brand be damaged if organic livestock producers were given 

the choice of feeding organic animal by-products and naturally or organically 

harvested fish by-products? Explain.

7. Would a rule change at §205.237(5) (b) to allow the feeding of organic meat offal 

or by-products to omnivores be appropriate to help fulfill the essential amino 

acids, vitamins, and minerals requirement? If yes, state the language you would 

use. If no, offer viable suggestions to dealing with the absence of synthetic amino 

acids in omnivore rations. 
Livestock:OmnivoreDiets

VII. References

Chattopadhyay, K., M.K. Mondal, and B. Roy. 2006. Comparative efficacy of GLMethionine and herbal methionine on performance of broiler chicken. International 

Journal of Poultry Science 5(11): 1034-1039. Retrieved August 14, 2012 from 

http://docsdrive.com/pdfs/ansinet/ijps/2006/1034-1039.pdf

Fanatico, A. 2010. Organic poultry production: Providing adequate methionine. A 

publication of ATTERA, National Sustainable Agriculture Information service. Retrieved 

July 8, 2011 from http://attra.ncat.org/attra-pub/methionine.html

Favre, T. 2012. Personal Communication with K. Fletcher, Countryside natural products 

Federal Register. 2012. National Organic Program; proposed amendment to the 

national list of allowed and prohibited substances (Livestock), federal register, Vol. 77, 

No. 24.

Halder, G., and Roy, B. 2007. Effect of herbal or synthetic methionine on performance, 

cost benefits ratio, meat and feather quality of broiler chicken. International Journal of 

Agricultural Research 2(12):987-996. Retrieved August 14, 2012 from 

http://scialert.net/fulltext/?doi=ijar.2007.987.996

Methionine Task Force, 2011. Methionine task force update. 2011. Paper presented at 

the National Organic Standard Board, November, 28, 2011, Savannah, Georgia.

Organic Food Production Act. 2002. Livestock feed. Retrieved August 14, 2012 from

http://law.justia.com/cfr/title07/7-3.1.1.9.31.3.34.11.html.

Salome, I., I.I. Dafwag, and G.S. Bawa. 2010. Evaluation of methiorep as a substitute 

for methionine in broiler diets. International Journal of Poultry Science 9(8): 809-812. 

Retrieved August 14, 2012 from http://www.pjbs.org/ijps/fin1776.pdf

Technical Evaluation Report, 2011. Methionine. ICF International for USDA National 

Organic Program 2011.

VIII. Summary

Poultry and pigs are omnivores and naturally eat plant, animal, and non-animal 

materials. Yet in organic livestock production, they are fed as vegetarians and 

herbivores. Maybe it is time to feed organic materials that are of both plant and animal 

origin. 

IX. Committee Vote:

Moved: Tracy Favre Second: Jean Richardson

Yes: 8 No: 0 Abstain: 0 Absent: 0 Recusals: 0