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Ed Maltby

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Organic Producer

Here, Executive Director of the Northeast Organic Dairy Producers Alliance Ed Maltby explains the history behind the final pasture rule, highlights its key provisions, and explains what these provisions mean for organic consumers.

Q: How long has the final pasture rule been in development?

A: The USDA National Organic Program (USDA NOP) has been working to clarify what is meant by “Access to Pasture “ for the last five years because there seemed to be confusion amongst farmers and certifiers, and finally the USDA lawyers, as to what was required to satisfy the farm’s organic status. It has always been required that organic dairy cows and livestock graze on pasture whenever it is available.


Q: Who was involved in developing it?

A: The language clarifying the regulations was very much a result of the whole organic community working with the USDA NOP to have criteria that was practical, met the expectations of the organic consumer and was acceptable to the USDA lawyers who have the job of enforcing the regulations. The Federation Of Organic Dairy Farmers (FOOD Farmers) worked with the National Organic Coalition, The Organic Trade Association, the milk companies, consumer advocates and many smaller non-profit organizations to build a consensus position that ensures dairy cows and calves would ‘eat grass’.

Q: What are some of the key provisions of the final pasture rule?

A: The key provisions are that dairy cows have to be on pasture for at the very least 4 months of the year and that the pasture needs to provide at least an average of 1/3 of the diet while on grass. All certified organic dairy farmers are required to provide their third party inspector with specific details on what they will be doing on the farm within an ‘Organic Systems Plan’ (OSP). The new rule specifies that they also need a plan on how they will use their pasture, also accounting for how their calves and young animals will be on pasture.

Q:How do these provisions differ from those that were in place before the final rule was passed?

A: The most significant difference is that the regulations now specify that farms need to meet specific goals and provide data to illustrate how they met those goals for their cows being on productive grassland. Before, there was only a loose requirement that cows must have access to the outside which was interpreted in many different ways. Now the farmer has to provide a written plan and data that shows how they met the legal requirements, no matter which part of the US or the world they are farming.

Q: Many have hailed the final pasture rule as a great achievement for the organic community. Would you agree?

A: Yes. It shows that the decision to work with the federal government to accredit organic certification works, since the regulation that went through the federal rule-making system can be seen as representative of the needs of the consumers while reflecting the practicalities of organic farming. The organic community rose to the occasion to reach consensus around a set of standards that they could recommend to the USDA, even though as consumer advocates, farmers, certifiers, trade organization and non-profits they all had a slightly different idea of what the ‘ideal’ rule would be. Rule making is like sausage making and we all united together to produce the best possible ‘sausage’, a shining example of bi-partisan work!

Q: What does the new rule mean for organic consumers?

A: The new rule provides consumers with a guarantee that organic dairy and livestock products come from cows that graze on rich and nutritious grass for a minimum of 1/3 of their lives no matter where the farm is located. USDA has shown that they will enforce the regulation to preserve the integrity of the organic seal and protect the future of family farms. The organic seal is all you have to look for if you want a guarantee that your dairy products come from cows on grass.

About Ed Maltby
Ed Maltby, Executive Director of the Northeast Organic Dairy Producers Alliance, is a producer with over 45 years experience managing conventional and organic dairy, beef, sheep and vegetable enterprises on a variety of different farms in Europe and the United States. For the past twenty years, Ed has worked with regional farms to cooperatively market their products into mainstream markets, ranging from direct marketing of lambs and organic produce, to establishing a cooperative of dairy farmers who direct market their own brand of milk in Western Massachusetts. Since 2005, Ed has worked as Executive Director of the Northeast Organic Dairy Producers Alliance (NODPA, www.nodpa.com), an organic family farm member organization dedicated to preserving organic integrity and a sustainable pay price for farmers. He also developed sister organizations in the Midwest and West, and a national umbrella organization, Federation of Organic Dairy Farmers (FOOD Farmers), to provide a national voice for organic dairy family farms. Since the start of his tenure, the organization has developed into a recognizable national voice on organic dairy policy.