Medicine and health

#Preventative care for animal health

The use of preventative practices to promote animal health is central to organic production. Only after preventative practices and veterinary biologics are inadequate may synthetic medications be administered.

How do I make a preventative care plan for my livestock?

OTCO will review your Organic System Plan to ensure your preventative practices are adequate to promote good animal health. Start with the six preventative health care practices outlined in the USDA National Organic Program standards:

  • Choose species and types of livestock best suited for your region’s conditions, diseases and parasites
  • Provide a feed ration designed to meet your animals’ nutritional requirements
  • Establish appropriate housing, pasture conditions, and sanitation practices
  • Provide conditions for exercise, freedom of movement, and reduction of stress appropriate to the species
  • Perform physical alterations as needed to promote the animal’s welfare, minimizes pain and alleviates stress
  • Administer vaccines and other veterinary biologics as appropriate

What happens if, despite preventative care, my animals get sick?

If preventative practices prove inadequate, you will need to follow all restrictions for medications and antibiotics, as explained below.

#Restrictions and use of synthetic medications and excipients

Can I use synthetic medications?

Organic livestock operations can only use synthetic medications if they are allowed per the National List. Prior to using synthetic medications, you must demonstrate adequate use of preventative practices as a first measure.

What is an excipient?

Excipients are ingredients in a medication that do not provide any therapeutic or diagnostic effects. Typically, they assist or enhance the administration and delivery of the active ingredient to maximize its effectiveness. Commonly they are found as inactive ingredients such as emulsifiers or preservatives.

Which excipients are allowed?

The National List includes an allowance for synthetic excipients with the following restriction:

“Only for use in the manufacture of drugs used to treat organic livestock when the excipient is: Identified by the FDA [Food and Drug Administration] 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.”

Can I use a medication prior to approval from OTCO?

OTCO recommends you submit all medications for review and approval prior to use. Upon receipt of a medication request, we will review both the active ingredient(s) and the excipients to ensure they meet the requirements for organic production. You must provide a complete ingredient statement at the time of the request.


Often medications only list active ingredients on the label. We must review all of the ingredients, including the excipients. Even when the active ingredient in a medication is allowed in organic livestock production, the medication may not be approved unless all of the excipients are also compliant. You can request a complete ingredient list from the manufacturer.

How do I request approval of a synthetic medication?

To request approval of a synthetic medication, follow the steps for adding a material to your Organic System Plan.

For a synthetic medication, be sure to include a complete ingredient list — OTCO requires manufacturer-provided lists of active and inactive ingredients — with your submission.

What does a “medication is approved with restrictions” mean?

Be mindful of and track any usage restrictions associated with approved medications. Several materials, despite approval for use, will include restrictions for how they can be used. Any other use is prohibited. You can view restrictions on your approved inputs list in MyOTCO.

As an example, glycerin is only allowed when used as the active ingredient in a livestock teat dip. Additionally, it must be produced through the hydrolysis of fats or oils. It is not allowed as an active ingredient in any other medication, or if produced by other unapproved methods.

#Use of antibiotics

What happens if I use antibiotics on my organic livestock?

The use of antibiotics, including ionophores, is not allowed for use in organic animal production. The administration of antibiotics carries special requirements following use.

Organic livestock operations:

Any livestock treated with antibiotics (or any prohibited substances) must be immediately identified and cannot be sold, labeled, or represented as organic.

What do I do if my animal requires antibiotics?

Organic livestock operations are prohibited from withholding medical treatment from a sick animal in order to preserve the animal’s organic status.

Treat any animal with the appropriate medication, including antibiotics, to ensure the animal’s well-being.


Inspectors and certifiers will review your animal health care records to ensure that sick animals in need of antibiotics have been given appropriate treatment. They will also verify that any animals treated with antibiotics or other prohibited medications are clearly identified — segregated if necessary — and animals, offspring, or any products have not been sold or represented as organic.

#Teat dips

Teat dips are classified by the Food and Drug Administration as health care products used to prevent mastitis and other prevalent diseases in milking livestock.

How do I request approval for a teat dip?

Follow the steps for adding a material to your Organic System Plan. OTCO will need time to review and approve your teat dip — or equivalent material — prior to use.

Which teat dips are eligible for use with my livestock?

Chlorhexidine is only allowed as a teat dip when alternative germicidal agents and/or physical barriers have lost their effectiveness. If you are requesting the use of a chlorhexidine-based teat dip, first you must provide clear justification for its use per the restriction.

Give a detailed explanation of issues with alternative teat dips, including how you’ve addressed aftercare such as clean bedding or cows remain in standing position following milking. Only after acceptable justification will OTCO review the proposed chlorhexidine-based teat dip.

Glycerin is allowed as a teat dip as long as it is produced through the hydrolysis of fats and oils. You will need to provide manufacturer confirmation in accordance with the process-based manufacturing restriction. Glycerin is prohibited for use as an active ingredient in all other organic livestock animal products or applications.

Iodine-based teat dips are allowed as long as all ingredients used to keep the iodine in liquid form are compliant with organic standards. All excipients are also subject to review. To establish compliance, we will require detailed information from the iodine manufacturer to determine the specific purpose of each ingredient in the product.

#Emergency treatments for livestock

On rare occasions, federal or state authorities put into effect emergency pest or disease treatment programs that mandate the use of materials that are prohibited for use in organic production.

What happens to my certification if I’m required to use a prohibited material?

Livestock treated with a prohibited substance due to a federal or state emergency pest or disease treatment program, or any product derived from treated livestock, may not be sold, labeled, or represented as organic.

When can I sell milk or milk-based products as organic if dairy livestock were treated due to an emergency mandate?

Beginning 12 months after the last date that the dairy animal was treated with the prohibited substance, milk or milk products may be sold, labeled, or represented as organic.

Is offspring of mammalian livestock considered organic if treated due to an emergency mandate?

Provided the mammalian breeder stock was not in the last third of gestation when treated with the prohibited substance, offspring of may be considered organic.

What records are needed for a federal or state emergency treatment program?

We request as much information as possible prior to implementation of a federal or state emergency treatment program. Records may include:

  • Copy of the federal or state emergency program mandate
  • Info regarding the required material for application
  • Whether or not an alternative approved organic material or method is available
  • Explanation for why an alternative cannot be used
  • Locations and schedule for applications
  • Information such as animal life stage, etc.

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