A Proposed Clarification of "Origin of Livestock"
Comments of the Organic Trade Association to the National Organic Standards Board
October 19, 2002
205.236(a)(2)(iii) of the NOP Final Rule refers to raising young dairy stock on the farm from the
last third of gestation.
First, the Organic Trade Association (OTA) recommends treating dairy and fiber-bearing animals similarly, as “production livestock”. Secondly, this production livestock should be treated differently from slaughter stock.
Specifically, for therapeutic reasons, in case of illness or injury, production stock should be able to be treated with medications deemed necessary for the animal's health and survival 12 months prior to products being sold, labeled, or represented as organic. These medications should be considered as being outside the scope of the National List. Treatments should recorded in the organic farm system management plan and certifiers should be informed.
This interpretation would maintain the requirements of the Rule in regard to organic feed and organic living conditions.
Under 205.238(c)(1), the prohibition of marketing animals or edible livestock products clearly refers to livestock actively producing organic products, because the Rule does not specify an exception for converted herds nor for any animal brought in under the 12-month rule (205.236(a)(2)). There is no direct exception for converted herds or animals purchased in replacements. | 
