FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: _August 17, 2005________

Subject: __Guidance on NOP Pasture Requirements________ 

Chair: ____Jim Riddle______________________________________ 

 (sign) 

Recommendation

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: ________ 

Guidance Statement: ____X____ 

Other: ________ 

Statement of the Recommendation (including Recount of Vote):

Guidance for interpretation of §205.239(a)(2) 

A. Organic System Plan 

Ruminant livestock should graze pasture during the months of the year when pasture can provide 

edible forage. The Organic System Plan should have the goal of providing a significant portion of 

the total feed requirements as grazed feed but not less than 30% dry matter intake on an average 

daily basis during the growing season but not less than 120 days per year. Growing season 

means the time of year of pasture growth from natural precipitation or irrigation. The Organic 

System Plan should include a timeline showing how the producer will satisfy the goal to optimize 

the pasture component of total feed used in the farm system. For livestock operations with 

ruminant animals, the operation’s Organic System Plan should describe: 1) the amount of pasture 

provided per animal; 2) the average amount of time that animals are grazed on a daily basis; 3) 

the portion of the total feed requirement that will be provided from pasture; 4) circumstances 

under which animals will be temporarily confined; and 5) the records that are maintained to 

demonstrate compliance with pasture requirements. 

B. Temporary Confinement 

Temporary confinement means the period of time when a ruminant is denied pasture. The length 

of temporary confinement will vary according to the conditions on which it is based (such as the 

duration of inclement weather) and instances of temporary confinement should be the minimum 

time necessary. In no case should temporary confinement be allowed as a continuous production 

system. All instances of temporary confinement should be documented in the Organic System 

Plan and in records maintained by the operation. 

Temporary confinement is allowed in the following situations: 

1) During periods of inclement weather such as severe weather occurring over a period 

of a few days during the grazing season; 
2) Conditions under which the health, safety, or well being of an individual animal could 

be jeopardized, including to restore the health of an individual animal or to prevent 

the spread of disease from an infected animal to other animals; or

3) To protect soil or water quality 

C. Appropriate Pasture Conditions 

As a tool for the farmer and the certifier, appropriate pasture conditions can be determined by 

referring to the regional Natural Resources Conservation Service Conservation Practice 

Standards for Prescribed Grazing (Code 528) for the number of animals in the Organic System 

Plan. 

Board vote – August 16, 2005 

13 yes, 0 no, 1 absent 

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

Rationale provided in text of recommendation below. 

Response by the NOP:

Updated 2/25/05 

NOSB Livestock Committee Recommendation for Guidance on 

Pasture Requirements for the National Organic Program 

Adopted by the National Organic Standards Board 

August 16, 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 NOSB reviewed the proposed guidance from the 

Livestock Committee at the March, 2005 meeting, and made several changes. 

The NOSB then requested additional public comments on the revised guidance. 

The NOSB Livestock Committee received and reviewed comments on the 

revised guidance. The Livestock Committee has revised the guidance to include 

several of the comments, including clarification of the meaning of growing 

season, clarification of the role of the NRCS standards, and certain grammatical 

issues. A minority opinion on the Livestock Committee sought the inclusion of 

the word “approximate” in relation to the percentage of DMI to reflect the 

annualized aspect of the Organic System Plan, however this opinion was not 

adopted by the Committee. The Livestock Committee will present this guidance 

to the NOSB at the August meeting and request that the NOSB recommend this 
guidance to the NOP. The Livestock Committee believes that the guidance, 

combined with the rule changes recommended at the March 2005 meeting with 

regard to stage of life and lactation are sufficient, and no further rule changes are 

recommended at this time. 

Guidance for interpretation of §205.239(a)(2) 

A. Organic System Plan 

Ruminant livestock should graze pasture during the months of the year when 

pasture can provide edible forage. The Organic System Plan should have the 

goal of providing a significant portion of the total feed requirements as grazed 

feed but not less than 30% dry matter intake on an average daily basis during the 

growing season but not less than 120 days per year. Growing season means the 

time of year of pasture growth from natural precipitation or irrigation. The 

Organic System Plan should include a timeline showing how the producer will 

satisfy the goal to optimize the pasture component of total feed used in the farm 

system. For livestock operations with ruminant animals, the operation’s Organic 

System Plan should describe: 1) the amount of pasture provided per animal; 2) 

the average amount of time that animals are grazed on a daily basis; 3) the 

portion of the total feed requirement that will be provided from pasture; 4) 

circumstances under which animals will be temporarily confined; and 5) the 

records that are maintained to demonstrate compliance with pasture 

requirements. 

B. Temporary Confinement 

Temporary confinement means the period of time when a ruminant is denied 

pasture. The length of temporary confinement will vary according to the 

conditions on which it is based (such as the duration of inclement weather) and 

instances of temporary confinement should be the minimum time necessary. In 

no case should temporary confinement be allowed as a continuous production 

system. All instances of temporary confinement should be documented in the 

Organic System Plan and in records maintained by the operation. 

Temporary confinement is allowed in the following situations: 

1) During periods of inclement weather such as severe weather occurring 

over a period of a few days during the grazing season; 

2) Conditions under which the health, safety, or well being of an individual 

animal could be jeopardized, including to restore the health of an 

individual animal or to prevent the spread of disease from an infected 

animal to other animals; or

3) To protect soil or water quality 
C. Appropriate Pasture Conditions 

As a tool for the farmer and the certifier, appropriate pasture conditions can 

be determined by referring to the regional Natural Resources Conservation 

Service Conservation Practice Standards for Prescribed Grazing (Code 528) 

for the number of animals in the Organic System Plan. 

Approved by the Livestock Committee July 12, 2005 

5 Yes 

0 No 

0 Abstain 

Amended and adopted by NOSB August 16, 2005 

13 Yes, 0 No, 1 Absent