Food Animal Drug Regulations
Organic and alternative farming
The regulations and options for organic farming and the many related practices are NOT straightforward and are not as simplistic as many veterinarians believe. There are much better resources than this chapter; consider this just a start!
Regulatory overview
The USDA maintains a national list of allowed and prohibited substances under the National Organic Program (NOP). This list is evaluated twice yearly by the National Organic Standards Board (NOSB). States may have stricter regulations. In general, most natural products are permitted and most synthetic products are prohibited but there are exceptions in both categories.
The USDA also accredits agencies to certify farms as organic (or to remove organic certification). Trained individuals (organic inspectors) visit farms and report back to the organic certification agencies. It takes 3 years for a farm to be able to be classified as organic.
Other agencies will also “certify” farms or products (eg American Grassfed Association) or labels may include claims without certification (free-range).
Organic food must be produced without using conventional pesticides, certain fertilizers, herbicides, genetic engineering, antibiotics, growth hormones or irradiation. Animals must also meet animal health and welfare standards that include time outdoors, limited stocking density, and must be eating organically raised food.
Organic farming rationale
Organic farming has several benefits for animal welfare and land conservation. It generally improves environmental health through reduced use of nitrogen fertilizers, better pasture management, and choice of adapted crops. After five years, farms are generally economically competitive. Human health is improved by better food quality (fewer toxins and antibiotics). Animal health is improved via better housing (fewer lameness issues), increased grazing (less ketosis and acidosis), and better immune systems /stress levels (outdoor activity).
Organic livestock requirements
Animal health and natural behavior must be accommodated year-round, and livestock and milk products must be:
- Managed organically from the last third of gestation (ruminants and swine) or second day of life (poultry).
- this includes being on organic land and being fed 100% organic feed (trace minerals and vitamins are allowed)
- Allowed year-round access to the outdoors, direct sunlight, and shade, weather permitting
- Provided shelter, clean and dry bedding, and clean drinking water
- Managed without antibiotics, added growth hormones, mammalian or avian by-products, or other prohibited feed ingredients (e.g., urea, manure, or arsenic compounds)
- Only allowed substances used for management/therapy (see live list)
- Natural substances are allowed unless they are specifically prohibited
- Synthetic substances are not allowed unless they are specifically listed
- Some substances on the list may be used only in specific situations or up to a maximum amount
Veterinarian role
Disease prevention
Because of the treatment restrictions, disease/disorder prevention is crucial. Organic farms can use vaccines, need to monitor human traffic (nutritionists, feed delivery etc), and need to be very careful with the entry of new animals as well as controlling the environmental factors that increase the risk of animal injury and stress (movement of animals, nutrition). Veterinarians are often wary to intervene in organic farms and organic farmers tend to avoid veterinary advice. This leaves a potential gap in animal health and care.
Therapy of disorders and diseases
Organic animals can be treated. Organic animals MUST be treated if it is indicated for humane care. Many therapies are allowed on organic farms, including vaccines, electrolytes, vitamin and mineral supplements, certain disinfectants (alcohol, chlorhexidine, chlorine, iodine, hyrogen peroxide), calcium borogluconate, dextrose, xylazine, flunixin meglumine, butorphanol, oxytocin, fenbendazole, moxidectin, poloxalene, tolazoline and lidocaine. Certain topical agents are also permitted, including copper sulfate and zinc sulfate. Natural products may also be useful, eg butter for frothy bloat. Just as with standard animal care, a multiprong approach is often required to minimize gaps in therapeutics. Eg fly control with natural products will also require mitigation of moist areas and other mechanisms to make the environment less fly friendly.
Veterinarians are also useful on organic farms for assistance with record management, diagnostics, reproduction, nutrition, livestock handling, facilities design and modification, use of alternative therapies (homeopathy, acupuncture, chiropractic) and species-specific expertise. Culling decisions are still required as are following the regulations requiring farmers to “treat with all means necessary”.
Always ask the farmer for their OSP (organic system plan) that describes the expected farm practices and the materials list (approved products).
Animals that do require treatment with agents not on the approved list must be clearly identified and cannot be sold, labeled or represented as organic.
Be sure and provide an itemized invoices that list all products used for any sale or service!
Withdrawal times are still required and may be different (if different, it will be noted on the national list). Note all withholding times on your label, even if it is zero.
Communication is key. Trust is often lacking and veterinarians may shy away from organic farms. However, much of the animal needs an care is the same. This ebook includes prompts that help guide important conversations on genetics, nutrition, animal stress, exercise, vaccination, homeopathic remedies, parasite control, and other topics.
Notable
Terminology is important. Organic farmers do not appreciate being lumped in with large farms or conventional farms. The terms “farmer” and rancher” are more acceptable than the term “producer”. “Disease prevention actions” or “activities” is often taken more favorably than the term “biosecurity”.
Foreign animal disease management and natural disasters can impact organic farmers much more severely. Development of emergency plans can be very helpful to ensure continued access to feed and appropriate pastures.
Resources
USDA National Organic Program website
Permitted synthetic substances list. Note that strychnine is a natural product that is prohibited on organic farms.
Organic and alternative animal health course – free; the source of most of this information
- Organic and alternative animal health overview ebook
- Prevention and organic/ alternative animal health ebook
- Rules and regulations associated with organic and alternative livestock ebook
- Communication Considerations for Working with Organic and Alternative Livestock Clients ebook
- Practice Management Considerations for working with Organic and Alternative Livestock Clients ebook
- Treatments and modalities for organic and alternative livestock ebook
