FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: __March 18, 2005_______

Subject: NOSB Recommendation for Rule Change – “Access to Pasture” 

Chair: _________________________ Jim Riddle ___________ 

 (sign) 

Recommendation

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: ___X_____ 

Guidance Statement: ________ 

Other: ________ 

Statement of the Recommendation (including Recount of Vote):

The NOSB recommends the following: 

1. Rule Change for §205.239(a)(2) 

The NOSB recommends that §205.239(a)(2) be amended to read: 

§205.239(a)(2) Access to pasture for ruminants Ruminant animals grazing pasture during the 

growing season. 

This includes all stages of life except:

 a) birthing; b) dairy animals up to 6 months of ageand c) beef animals during the final finishing 

stage, not to exceed 120 days. Note: Lactation of dairy animals is not a stage of life under which 

animals may be denied pasture for grazing.

March 2, 2005 Board vote: 13 – yes, 1 – no, 0 – abstain 

Rationale Supporting Recommendation (including consistency with OFPA and NOP):

Rationale for change explained in text below. 

Response by the NOP:

Updated 2/25/05 
NOSB Recommendation for Rule Change 

Pasture Requirements for the National Organic Program 

Adopted March 2, 2005 

Introduction 

The USDA National Organic Program (NOP) has requested NOSB provide guidance concerning 

the pasture requirements of the National Organic Program that the NOP can review and distribute 

to accredited certifying agents and post on the NOP website. 

The following recommendation is based on the NOSB’s June 2000 and October 2001 pasture 

recommendations and the standards currently required under the NOP regulations, attached in 

addenda to this document. The NOP Final Rule defines “pasture” as “land used for livestock 

grazing that is managed to provide feed value and maintain or improve soil, water, and vegetative 

resources.” 7 CFR 205.2. Pasturing is required under the Livestock Health Care Practice 

Standard (7 CFR 205.238) and under Livestock Living Conditions (7 CFR 239). The Final Rule 

provides that temporary confinement is allowed in certain circumstances. This recommendation 

will provide further guidance on the meaning of temporary confinement and stage of life. 

As stated in the October 2001 NOSB recommendation, requiring pasture for ruminants ensures 

an organic production system which provides living conditions that allow animals to satisfy their 

natural behavior patterns, provides preventative health care benefits and answers the consumer 

expectation of humane animal care. Organic pasture management reflects a synthesis of crop 

and livestock production principles that works from the soil up to promote an interdependent 

community of plants and ruminants. Organically managed pasture should produce the quantity 

and quality of edible plants suitable to the species, stage of life, and number of animals. Pasture 

assures a relationship between the animal and land that satisfies both organic principles and 

international standards for organic livestock. 

Recommendation

The NOSB recommends the following: 

1. Rule Change for §205.239(a)(2) 

The NOSB recommends that §205.239(a)(2) be amended to read: 

§205.239(a)(2) Access to pasture for ruminants Ruminant animals grazing pasture during the 

growing season. 

This includes all stages of life except:

 a) birthing; b) dairy animals up to 6 months of age1 and c) beef animals during 

the final finishing stage, not to exceed 120 days2. Note: Lactation of dairy 

animals is not a stage of life under which animals may be denied pasture for 

grazing.

Board vote: 

13 – yes, 1 – no, 0 - abstain 

 

1 The NOSB recommends 6 months for young animals to allow for weaning and prevention of parasites. (Footnote 

included as explanatory text – not to be included in rule change.)

2 The NOSB recommends 120 days for the finishing of bovines based on comments received from beef producers who 

indicated that 120 days is the amount of time needed to achieve “choice” grades of beef. (Footnote included as 

explanatory text – not to be included in rule change.)