The U.S. Department of Agriculture’s (USDA’s) Office of Inspector General
(OIG) has released a July 2013 audit report examining how the Agricultural
Marketing Service’s (AMS’s) National Organic Program (NOP) established
the “access to pasture” rule for organic dairy cattle. Although OIG generally
found that the new rules for organic milk production were “successfully
implemented,” it nevertheless recommended that AMS clarify guidance
for certifying agents “to ensure that all dairy producers are being treated
consistently.”

To this end, the audit noted that NOP (i) “had not clearly defined how producers should demarcate herds of organic milk-producing cattle, which meant that some certifying agents allowed producers to add cattle to organic herds,” and (ii) “needs to include organic feed brokers within the NOP-certification process to ensure that organic feed is not commingled or contaminated.” OIG also reported that certifying agents failed to take consistent enforcement actions “when their inspectors or reviewers identified possible noncompliance issues,” and that smaller operations “were often unaware of the recordkeeping requirements of the access to pasture rule regarding livestock confinement, grazing, or the cattle’s dry matter intake.” AMS has reportedly concurred with all of OIG’s recommendations.

 

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For decades, manufacturers, distributors and retailers at every link in the food chain have come to Shook, Hardy & Bacon to partner with a legal team that understands the issues they face in today's evolving food production industry. Shook attorneys work with some of the world's largest food, beverage and agribusiness companies to establish preventative measures, conduct internal audits, develop public relations strategies, and advance tort reform initiatives.

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