For livestock operators

#Requirements

Your recordkeeping system demonstrates where promise and practice meet for compliance. The annual inspection reviews every aspect — from birth records to feed rations — of organic livestock production. Our ability to easily audit and trace all certified organic livestock products maintains integrity and enables quick action if issues occur.

Note

If you have a split operation — organic and non-organic — you will need a distinct set of records for your organic livestock to demonstrate that they meet organic standards. You’ll also need to demonstrate how organic and non-organic livestock do not commingle.

You need to maintain documentation — your Organic System Plan outlines recordkeeping strategies, management, and storage — that demonstrates all requirements are being met. Each operation’s recordkeeping systems will be different. However, a few core requirements must be minded:

Recordkeeping basic requirements:

  • Records are easily accessible on-site for inspection
  • Documentation must be adapted to reflect your operation
  • All records must be clear and auditable

Alert

Records must be kept for at least five years after the production date.

What records do I need to keep?
The records listed below are examples of records that can be used to demonstrate compliance with the recordkeeping requirements in the USDA National Organic Program regulations.

  • Animal origin
    Records cover the birth and/or hatch records of animals and verify purchase.
  • Animal health and welfare
    Health records include all treatments and vaccinations for your animals. Additionally, you must include records and labels for any product or veterinary purchases for health care. For operations with poultry, records of artificial light management and ammonia monitoring are required.
  • Feed and feed supplements
    You will need records for all purchased feed, including receipts and organic certificates. Additionally, harvest and storage records are required for any feed you grow on-site. Documentation for livestock grazing, pasture rotation, feed and feed supplements is necessary.
  • Production and sales
    All sales records such as orders, invoices and receipts must be maintained.
  • Handling, transport, and storage
    Records must demonstrate all handlers are certified — slaughter, cut/wrap, creamery, etc. — and include affidavits of exemption of certification for storage facilities handling pre-packaged products. If handling your own products, documentation of sanitation, processes, and ingredients are required. Animal welfare transport requirements must be recorded as well.

#Audit trail

Organic inspectors are required to conduct at least one complete audit trail exercise and a feed audit at each inspection. The audit trail evaluates your recordkeeping system as well as activities for traceability and compliance.

For livestock producers, a complete and thorough audit trail enables a product — e.g., a finished brick of cheese — to be traced back to the sourcing and handling processes of all of its ingredients. Your recordkeeping system should act as connected web. An inspector will be able to easily review the source farm of an ingredient —i.e. milk in the case of cheese, milk — the production inputs used, feed sources and pastures grazed.

The quality of a recordkeeping system is not about fancy technology. Depending on your operation and production needs, you might choose an online program or handwritten logs. Integrating recordkeeping into the daily routine and culture of your business is key for success. It should be clear that updating and tracking information on your farm is well-managed and easily done.

Alert

All records related to your organic product need to be stored for at least five years.

No matter what system you use, it is important to ensure that your recordkeeping:

  • Is easy to update regularly
  • Is well understood by all employees, even those not responsible for data entry
  • Is clear and well-organized for inspectors and certifiers
  • Documents a full, linked chain between activities, materials, and products without gaps
  • Demonstrates clear relationships that match on-the-ground realities — e.g., the number of animals in your operation — with reported activities — e.g., the amount of space and feed

Resource

You do not have to start your recordkeeping system from scratch, the USDA National Organic Program created template recordkeeping documents and OTCO created a recordkeeping webinar and Lessons Learned series to get you started.

#Materials

Documentation of materials is a critical part of your recordkeeping system. An inspection will review the materials used, how they are used, and determine the compliance of your certification.

What are materials?
For livestock, materials include feed supplements, vaccines, pest controls, dewormers, sanitizers, housing, and many more. Your Organic System Plan (OSP) should contain a list of your operation’s materials and be regularly updated prior to use.

Note

Always contact OTCO prior to purchasing and applying a non-OMRI or WSDA listed material to verify that it is approved for use.

Tracking materials
All materials listed in your OSP require thorough documentation to verify compliance as allowable substances per the USDA National Organic Program. Acceptable records include but are not limited to purchase receipts, labels for all materials (including brand name and ingredients), and veterinary records.

Sanitation equipment records
For all sanitation materials used in direct contact with livestock products — examples include, milk line sanitizers, carcass wash, etc. — you will need to keep an equipment cleaning log.

#Living conditions

The USDA National Organic Program (NOP) outlines requirements for outdoor access and grazing for ruminant and non-ruminant livestock. Records and documentation should verify the “Living Conditions” section of your Organic System Plan (OSP), which outlines your plans for housing, outdoor access, cleaning, and lengths of confinement for specific reasons.

Bedding
If you use roughages for bedding, you must document organic certificates and receipts. If, however, you use forestry products such as wood shavings for bedding, they are not required to be organic.

Avian
You will need to demonstrate a plan for proper ventilation to keep ammonia levels below 25 parts per million, and extra monitoring practices whenever levels exceed 10 parts per million. Documentation of ammonia levels testing should correspond with the monitoring type — e.g., test strips, electronic meters — and frequency as indicated in your OSP.

If using artificial light, you’re required to document the amount of time and type of artificial light used. For example, if there is six hours of daylight in winter months and you use artificial light to prolong daylight to 10 total hours, you will need records demonstrating the light’s total time of active and dimming ability.

Grazing and pasture access
All ruminants must be managed on pasture and with daily grazing throughout the grazing season(s), for a minimum of 30 percent of daily dry matter intake and 120 days. A livestock grazing record is a required part of your recordkeeping. Several methods are acceptable — a calendar system, notebook, or spreadsheet — but it must be in a form that the inspector can be easily audit.

On your sheet you’ll want to indicate the number of days in your grazing season, the days in which your livestock graze on pasture, as well as pasture rotation.

Confinement
Livestock producers may temporarily confine their livestock under certain conditions — e.g., inclement weather, safety issues, preventative health care practices — but must provide documentation with the date, animal or herd identifier, and the reason for confinement.

Resource

The USDA National Organic Program created sample livestock documentation forms for organic processors including grazing sheets, confinement forms and more.

#Animal health

Health records should support your health care plans for animals as outlined in your Organic System Plan.

One approach is to keep a record sheet for each individual animal. You can find example health record forms for individual animals — as well as entire flocks — from USDA ATTRA. Identifiers such as an ear tag or band match to individual records, allowing clear traceability of the animal through its life cycle.

After adapting to meet your unique needs, an individual animal record offers a simple, single location to document birth or hatching records, source history, vaccinations, health care treatments, physical alterations or culling/mortality information.

Note

Any time an animal receives health care, your records must include the animal, dose, reason, age, material, and date. You’ll need to support your records with documentation of the materials, typically receipts and labels. You can read more about this in our materials recordkeeping article.

#Feed

The USDA National Organic Program (NOP) requires that organic livestock feed consist of certified organic agricultural products. Feed rations may also include allowed feed additives and supplements.

You inspection will include an audit of at least one feed ration or a component of a ration fed to a specific group of animals during a specific timeframe — e.g., bred heifers during the non-grazing season — to ensure compliance. Your records must clearly demonstrate that the amount of feed consumed matches the amount that was available. The audit will examine harvest yield records for feed grown on-farm and/or receipts and weight tags for purchased feed.

Harvest and storage
Harvest and storage records offer verification that you produced enough food for your livestock. Always track harvest yields for all feed crops. Measurements may be in units that make sense for the crop — e.g., number of bins, bales or total weight — and records should clearly indicate how many acres (e.g., 100 bushels per acre) were harvested to achieve a total amount. Yields and the field of origin should be recorded in your calendar, harvest spreadsheet or directly on the storage container with the date. Be sure to organize and save weigh tags for review.

Purchase records
You are required to maintain purchase records for all feed and feed supplements to ensure compliance. Documentation can include receipts, invoices, organic certificates and feed labels (or accompanying documents) with all brand and ingredient information.

Calculating dry matter for ruminants

The USDA NOP requires that during the grazing season at least 30 percent of dry matter intake for ruminants comes from pasture grazing. Unless your animals receive 100 percent of their dry matter from pasture grazing, you’ll need to document your calculations — several worksheet templates are available — for meeting the dry matter intake rule. These records must be supported by documentation of days grazing on pasture, the length of your grazing season, and pasture rotation.

Alert

All ruminants must be managed on pasture and with daily grazing throughout the grazing season(s), for a minimum of 120 days.

Feed and supplement records
You are required to keep records of what and how much feed and feed supplements your livestock consume. For ruminants, differentiate between grazing and non-grazing season feed plans in your preferred recordkeeping system — e.g., a journal, preformatted spreadsheet or a calendar — and include what was fed to your livestock, feed date, and quantity.

Organization
Your feed records should reflect all activities supporting your livestock nutrition program, including harvesting feed, grazing livestock, purchases of concentrates, forages, feed additives/supplements, and your current ration. Organizing this information alongside your other production records maintains ease of access for inspection and verification.

#Livestock product processing

The livestock product processing — on farm or contracted — records required will depend on your product type(s).

Tip

Learn if your on-farm processing requires a handling certification. Still unsure? Call us for support.

Using contracted facilities
All off-site, contracted processing facilities — e.g., slaughter, creameries, labeling, cut and wrap — must be certified organic. Required records include current organic certificates, private label agreements (if using), invoices, and shipping documentation.

Using on-farm facilities

When performing on-farm processing, you will need to document sanitation, commingling and contamination prevention, materials, shipping and receiving.

Note

If you have a split operation — organic and non-organic — you will need a distinct set of records for your organic livestock to demonstrate that they meet organic standards. You’ll also need to demonstrate how organic and non-organic livestock do not commingle.

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