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Newsletter of Penn Dutch Cow Care August 2009

Hi Folks,

As the weather has been generally favorable for dairy cows this summer, there haven’t been many of the typical problems related to hazy, hot and humid weather. This is good and so be it. Even if the heat still occurs, we can’t change it anyway. Accepting things we cannot change is one of life’s lessons.

But some things can be changed. Of obvious relevance to the organic livestock sector is the ability to have materials available for good husbandry of your animals (short of antibiotics). As a member of the National Organic Standards Board, I would like to inform you of continuing developments geared towards our next meeting during the first week of November. Being Chairman of the NOSB Livestock Committee and having conference calls every Tuesday, I’d like to update you on recent committee activity. Being in the fifth and final year of my term on the NOSB, I have been bringing up items that I believe are of critical importance to you, my organic dairy clients, as well as organic livestock producers in general. These items have been triggered mainly by actions taken by some certifiers in official letters to farmers that clients have asked me to read and which are quite alarming. Of particular concern to animal health care are excipients and vaccines.

Excipients are those ingredients in formulations that are not the “active” materials but those ingredients to help keep the material in suspension, flowing, and not separating, etc. Since the Dec. 2007 release of the excipient rule, many certifiers have decided to re-review items in order to make sure they comply with the new rule. It is currently written:

205.603(f): Excipients, only for use in the manufacture of drugs used to treat organic livestock when the excipient is: Identified by the FDA as Generally Recognized As Safe; Approved by the FDA as a food additive; or Included in the FDA review and approval of a New Animal Drug Application or New Drug Application.

I have re-written it to propose:

205.603(f) Excipients, only for use in the manufacture of animal health care products used to treat organic livestock when the excipient is: Identified by the FDA as Generally Recognized As Safe; Approved by the FDA as a food additive; Included in the FDA review and approval of a New Animal Drug Application or New Drug Application; or approved by APHIS.

Notice I have also inserted excipients “approved by APHIS” - for vaccines and biologics (i.e. colostrum whey products, etc). If this proposed change is voted in by the entire Board in November, certifiers won’t be able to easily kill materials like peppermint based udder salves.

Vaccines are well known and while not everyone uses them, many farmers do use them for very valid reasons. Some certifiers have recently decided to not allow vaccines that they have allowed for the last 7 years since they have only now found out that some are manufactured by certain methods (genetic rearrangement). The fact of the matter is that there has been a great increase in the genetically altered vaccines and manufacturing by these methods is now the standard for many vaccines (foot and mouth disease, avian influenza, west nile virus, etc) The list is continuously growing. To have organic farmers hamstrung to a dwindling list of “conventionally” manufactured vaccines is potentially disastrous if a severe disease outbreak were to occur, since the new methods of manufacture would be used to quickly create a new vaccine. The Livestock Committee has taken action to allow vaccines of all manufacturing processes to be allowed. Remember that you yourself may not want to use vaccines but other organic farmers definitely do - and for very valid reasons specific to their own farm.

Chlorhexidine and Xylazine. I’ve also written technical corrections on the annotations of these two materials (already on the national list) to preempt certifiers from potentially punishing innocent farmers needing antiseptics and sedation to work on common problems.

As farmers are aware, chlorhexidine (active ingredient of Nolvasan®, etc) is used as an antiseptic and an alternate teat dip (the blue teat dip often used in winter). Right now, the chlorhexidine annotation says:

205.603(a)(6)Allowed for surgical procedures conducted by a veterinarian. Allowed for use as a teat dip when alternative germicidal agents and/or physical barriers have lost their effectiveness.

To reflect actual usage in the field, I have re-written the annotation to state:

205.603(a)(6)Allowed as a germicide for medical and surgical procedures. Allowed for use as a teat dip when alternative germicidal agents and/or physical barriers have lost their effectiveness.

As farmers are also aware, xylazine (Rompun®, Anased®) is used to sedate animals, such as for the unfortunate animals that have horns needing to be “chopped” or for surgery for a twisted stomach. The second annotation in the allowance for xylazine 205.603(a)(23) requires “The existence of an emergency”. I have re-written the annotation to delete this requirement in order to reflect actual usage, as dehorning and surgery for twisted stomachs aren’t usually emergencies.

The Livestock Committee has voted 6-0 in favor of each of these four changes to these materials at the committee level and they will be voted on by the full board in November. You may think that I am being too technical in these changes. There is good reason to be: minor wording changes can impact your daily lives as organic livestock farmers because of the way certifiers interpret and apply the words. Remember, these items came to my attention only due to seeing letters from certifiers to client farmers. Whether you’ve had any awareness of these issues or not, these proposed changes are simply to help ensure appropriate care of certified organic livestock.

One last item that the Livestock Committee is working on is the topic of animal welfare. At this point we are probably looking at simple statements such as “no tail docking of cattle and pigs”, density requirements for poultry and making sure poultry are actually outside pecking the earth (their natural behavior), for reasons similar to cattle out on pasture. We will likely look to the new Canadian organic regulations since the USDA officially recognizes them as equivalent. We also want to assure organic consumers that animals aren’t being neglected when they need treatment (i.e. that they get prompt, effective treatment) and that herds in general are clean, have good body condition and not lame. The Livestock Committee hasn’t finished its work on this topic yet. Please contact me with any constructive input and insight you would like to share.

NODPA FIELD DAYS: If there’s ever a time to know where your markets are, what your costs are and how you can be more efficient with a down market and dropping prices, make sure to be at the Roman Stoltzfoos farm on August 13th (12-9pm) and 14th (9-4pm). This is the biggest organic event of the year. Free registration for organic dairy farmers and their families. Come hear James Landis (Roman’s advisor), Jeff Mattocks, Ken Muckenfuss (nutrition), Kathy Soder (pasture) and others. Join in on the exchange of practical information as well as understanding how the national situation will affect your future. Don’t be left out! See enclosed flyer

NOTE: Amos S. Beiler, 323 Maple Shade Rd, Christiana, PA 17509 has 2 fresh Jersey-Holstein heifers and a springer for sale. Asking $1500 each.


For Bovinity Health, information on functional alternatives to antibiotics see:

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