FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: _March 18, 2005________

Subject: __NOSB Livestock Committee Recommendation for Guidance – Pasture 

Requirements for the National Organic Program__________________________________ 

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):

NOSB voted to post the Livestock Committee Recommendation for Guidance on NOP Pasture 

Requirements for public comment. 11 yes, 3 no, 0 abstain. 

NOSB chair recommends a 60-day comment period to commence as soon as possible. 

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

Rationale stated in text below. 

Response by the NOP:

Updated 2/25/05 
NOSB ITEM FOR PUBLIC COMMENT 

The National Organic Standards Board (NOSB) is seeking public comment on recommendations 

regarding its “Livestock Committee Recommendation for Guidance Pasture Requirements” until 

May 20, 2005. With respect to receipt of comments by the NOSB during the comment period, the 

following provisions have been established to ensure that your comment has the greatest 

probability of being received and reviewed by the Board: 

• Mail: Persons may submit comments on listed Board recommendations by mail to: The 

National Organic Standards Board; c/o Arthur Neal; Room 4008 - South Building; 1400 and 

Independence Avenue, SW; Washington, D.C. 20250-0001. 

• E-mail: Comments may be sent via internet to NOSB.Livestock@usda.gov. 

• Fax: Comments may be submitted by fax to (202) 205-7808. 

Clearly indicate if you are for or against the Board recommendation or some part of it and why. 

Include recommended wording changes as appropriate. Include a copy of articles or other 

references that support your comments. Only relevant material should be submitted. 

NOSB Livestock Committee Recommendation for Guidance

Pasture Requirements for the National Organic Program 

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 NOSB is seeking comments on organic system plan requirements; temporary confinement; 

and what constitutes “appropriate pasture conditions.” In particular, the NOSB seeks input on 

specific dry matter intake from pasture language; reference to regional NRCS prescribed grazing 

standards; and whether or not any of the text below should be recommended to the NOP for rule

change. 

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

A. Organic System Plan 

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

edible forage. The Organic System Plan shall have the goal of providing grazed feed greater than

30% dry matter intake on a daily basis during the growing season but not less than 120 days. The

Organic System Plan shall include a timeline showing how the producer will satisfy the goal to

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

with ruminant animals, the operation’s Organic System Plan shall 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 ruminant livestock are 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 shall be the 

minimum time necessary. In no case shall temporary confinement be allowed as a continuous 

production system. All instances of temporary confinement shall be documented in the Organic 

System Plan and in records maintained by the operation. 

Temporary confinement is allowed only 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; 

3) To protect soil or water quality 

C) Appropriate Pasture Conditions 

Appropriate pasture conditions shall be determined in accordance with the regional Natural 

Resources Conservation Service Conservation Practice Standards for Prescribed Grazing 

(Code 528) for the number of animals in the Organic Systems Plan. 

Board Vote to post for public comment: 

11 – yes, 3 – no, 0 - abstain