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.