SIGN THE PETITION: Tell the National Organic Program: Don’t let 'Big Organic' dairies cheat family farmers and consumers.

Got organic milk?

There are plenty of reasons to drink it.

And there are lots of organic dairies producing—with real integrity—authentic nutrient-dense organic milk, including raw milk.

Unfortunately for those organic dairies and for consumers, the U.S. Department of Agriculture’s National Organic Program (NOP) lets some very large dairies get—and keep—organic certification, even though they don’t play by the rules.

SIGN THE PETITION: Tell the National Organic Program: No more cow flipping! Finalize the Origin of Livestock Rule and close the loopholes that let Big Organic dairies cheat family farmers and consumers.

black and white dairy cows on a factory farm CAFO feed lot

You’ve heard of cow tipping and house flipping. But how about cow flipping? 

A big business in the factory farm “Big Organic” dairy industry is flipping cows—buying conventional cows, managing them according to organic regulations for a year, and selling them to “Big Organic” dairies at a profit. 

The Cornucopia Institute explains it this way:

To meet the demand from these factory farms for replacement animals, wholesale suppliers of organic heifers (young cows who have not yet calved for the first time) have arisen. These organic heifer farms generally purchase one-year-old conventionally raised yearlings. These animals were typically raised on “medicated” milk replacer (infant formula for bovines) that includes antibiotics and other materials banned in organics. After weaning, the young animals’ diet generally consists of conventional feed, treated with toxic agrochemicals, and almost undoubtedly all genetically engineered (practices prohibited in organics). The heifer ranches, who purchase the young stock, then manage the cows as organic from this point on in their lives until their eventual sale to the large [“organic”] factory farms. 

Cow flipping is profitable because the factory farm-style “Big Organic” dairies consider their cows disposable. So they’re in constant need of replacement heifers. According to the Cornucopia Institute, they push their cows to produce 25,000 pounds or more of milk per year. When this forced overproduction inevitably results in mastitis (udder infection) or other maladies, their management solution is to buy replacements for the sick and lower-producing animals. As Mark Kastel, who recently left Cornucopia Institute to co-found OrganicEye with partners from Beyond Pesticides, said:

“These dairies burn out their cattle and send them to the hamburger plant, sometimes just a year or two after they start milking them, and then replace them with conventional cows.”

Cow flipping should be illegal. That’s because in order to be certified organic, milk is supposed to come from cows that were raised from before birth under organic rules.

There’s one exception, though. In order to help conventional dairy farmers transition to organic, the Origin of Livestock Rule allows those farmers “to convert an existing herd of milk cows and their young offspring to organic status by providing them qualified organic feed, and shunning any of the prohibited pharmaceuticals, for one year before they officially sell their milk as certified organic.”

But here’s the issue. Some “Big Organic” dairies, and the business described above, are wrongly using the Origin of Livestock Rule to transition conventional cows to organic, over and over again.

That was never the intent of the rule. Yet the NOP has turned a blind eye to the abuse of what was supposed to be a one-time conversion. 

The widespread practice of cow flipping means that most of the store brand “organic” milk available in grocery stores comes from cows that were born and raised on conventional factory farms for a year before being transitioned to organic. 

During that important first year of life, these cows were raised on conventional milk or milk replacers which contain substances banned in organic. The banned substances include antibiotics and other prohibited pharmaceuticals, and also the blood plasma of other cows. 

From a consumer perspective, there are lots of problems with this. One of these is the ever-growing antibiotic resistance crisis, caused by the overuse of antibiotics on factory farms.

Another? The increased risk of Varient Creutzfeldt–Jakob disease (vCJD), a form of Mad Cow disease that is transmissible to humans and is transmitted among cows through cannibalism. In the U.S., the practice of feeding cows to cows was never completely banned. The U.S. Food and Drug Administration bans only “the brains and spinal cords from cattle 30 months of age and older.” Everything else is allowed. So calves on conventional farms are regularly fed “spray-dried bovine plasma—in other words, cow blood.

The continued cannibalisation of cows is probably why neither Mad Cow (bovine spongiform encephalopath or BSE) nor vCJD has been eradicated. A Tennessee man recently got vCJD (read his tragic story here).  And BSE has been found this year in Brazil and Poland.  

If the risk of increasing rates of antibiotic-resistant infections and cVJD isn’t enough to make you want to do something about the problem of conventional factory-farm-raised cows producing “organic” milk, consider how it impacts small-scale family farmers who are producing organic milk with only the animals born on their farms and raised organically from conception. 

As Civil Eats reports, there are a number of ways factory-farm “organic” producers undercut their all-organic family farm competitors:

  • Selling organic calves and buying conventional heifers: One cost-saving trick is to sell off all the organic calves born on the farm (they’d have to be raised organically for two years before they could produce milk) and buy cheaper conventional heifers to replace milking cows (it only takes one year to transition them to organic).
  • Raising organic-born calves conventionally: The Idaho State Department of Agriculture lets organic farms rear their organic-born cows conventionally and then transition them back to organic status for organic milk production.
  • Operating a “split operation” with both organic and conventional cows: Dairies can manage both conventional and organic herds, moving organic calves to the conventional herd until it’s time to transition them to organic a year before milk production.
  • Using conventional versus organic feed: At one organic farm, the cost of raising a heifer for its first 60 weeks was $3,628 or nearly triple the $1,274 cost of a conventional heifer.
  • Maximizing production and shortening cows’ lifespans: With cheap conventional replacement heifers available, there’s no incentive to maximize a cow’s life span by reducing its stress or treating it humanely. Factory-farm “organic” dairies can focus on maximizing production by feeding large amounts of grain, even though it shortens the cow’s life.

Cow flipping should be illegal. The rules say an organic cow is a cow that has been organic since the last third of gestation.

The problem lies in lax enforcement and certifiers’ “creative interpretations” of an exception to the rule that allows for the one-time transition of a dairy herd from conventional to organic.

The NOP has been talking about “clarifying” what’s known as “the origin of livestock” rule for more than a decade. It’s time to act.

The NOP has re-opened a public comment period on the subject through December 2, 2019. Please sign our petition today. Thank you!

Take Action by December 2 for Better Organic Dairy: Tell the National Organic Program to stop letting factory-farm “organic” dairies break the rule requiring livestock to be raised organically from before birth.

Sign the Petition

Comment on Proposed Rule on Origin of Livestock 

Docket Number AMS-NOP-11-0009-1572

Thank you for the opportunity to provide public input on the National Organic Program’s Proposed Rule on the Origin of Livestock. I fully support the effort to close the loopholes that have allowed the continued practice of bringing conventional livestock onto organic farms.

This loophole has been abused and has allowed factory farm livestock operations to manage their herds using practices that are not sustainable and do not promote the health of their livestock.

However, the proposed new rule appears to create a new loophole that I want to see closed to prevent the ongoing abuse of the intent and spirit of organic law.

Specifically, I support the following changes:

  • The National Organic Program should require all organic dairy farms selling organic animals to be a functioning “commercial dairy” that is inspected and permitted by the state in which it operates. Furthermore, this dairy farm must have a relationship with a licensed milk handler shipping to a licensed dairy plant. In addition, this operation should be fully established, shipping milk for no less than 180 days and any animal sold should be producing milk itself. This would mean that no young transitioned heifers, who had never been milked, could qualify for sale as “organic.”

  • The final rule should ban the sale to an organic operation of any livestock that had been transitioned from conventional production to organic production.

Thank you for considering my comments on this important matter.