Inside Organics Blog

Say goodbye to ivermectin for organic livestock

By Harriet Behar, MOSES

By the time you read this, the National Organic Standards Board (NOSB) will have had its 2016 fall meeting in St. Louis. The agenda included a petition to remove the long-time allowed material for controlling parasites in livestock, ivermectin. As a member of the NOSB, I believe the vote will remove ivermectin, which will give organic farmers approximately 18-24 months to modify parasite management systems.

Ivermectin has been present on the National List since the National Organic Program rule was first printed in the Federal Register in December 2000. Before the regulation was implemented in October 2002, some certifiers allowed its use and some did not. It has been controversial since then, and at each five-year sunset review, both members of the NOSB and the public have urged removal. The recent petition for removal was submitted by a member of the NOSB, a somewhat unusual but allowed practice.

There are two main reasons for concern about the use of ivermectin: its scope and persistence in manure. It is a very broad-spectrum parasiticide and even has some antimicrobial activity, which means it could be considered to be an “antibiotic” as well. The law upon which our regulations are based prohibits the use of antibiotics in organic livestock.

Ivermectin remains toxic in excreted feces of a treated animals and can persist in the sediment of an aquatic environment for months. The manure of animals given ivermectin is especially toxic to the highly beneficial dung beetle, as well as being lethal or sub-lethal to many dung-breeding invertebrates that are beneficial to our ecosystem. Incorporating this manure into the soil can mitigate the negative effect of ivermectin, since it readily binds to soil which enables a more rapid breakdown of this substance and its toxic effect. However, for pastured animals, soil incorporation is not an option.

Routine use of parasiticides in organic livestock has never been allowed. Instead, organic standards give preference to the development of methods that lessen the exposure of their livestock to parasites.

While systems-based approaches can be effective in managing parasites, farmers still need tools to deal with parasite infestations in livestock when the situation is considered an “emergency.” Parasite management is an essential aspect of alleviating animal suffering and promoting animal health. It is also part of our regulation that a farmer cannot withhold necessary medical treatment in order to preserve the organic status of an animal. In these emergency situations, many producers favor ivermectin for its broad-spectrum effectiveness, its ready availability across the U.S., and its comparatively low cost.

The NOSB is working on a document which will further clarify what constitutes “emergency treatment” when referring to parasiticide use, and will hopefully have this ready for its spring 2017 meeting. This clarification will aid in a consistent review by organic certifiers of emergency treatment, as well as provide examples of what system approaches are expected before the remaining two parasiticides (fendendazole and moxidectin) on the National List can be used.

At its spring meeting, the NOSB voted to lessen the time between use of moxidectin or fenbendazole and the sale of a variety of organic livestock products. This spring’s vote also added the use of these parasiticides in fiber-bearing animals with a wait time of 90 days between use and harvest of organic fiber.

From previous NOSB meetings and public comments, it’s clear that most people believe fendendazole and moxidectin are sufficient tools for livestock producers to manage parasites in their organic livestock. It appears to be time for ivermectin to be removed from the National List.

It surprised me how few public comments were made on the proposed removal of ivermectin from the National List. This product has been used for a long time on organic farms. Hopefully, this lack of input from organic livestock producers means this removal will not negatively affect their farms, and they are in agreement that ivermectin should be no longer allowed.

I do have some concerns that there is only one meeting to discuss this issue, unlike at sunset when a material that might be removed is discussed at two NOSB meetings. If there had been concerns, producers could have made these known and there would have been an opportunity for a limiting annotation on ivermectin use, if a good case would have been made. Once the NOSB has voted at this meeting for removal, the process will begin and there will not be further opportunity for input.

Built into the organic system of production is the concept of continuous improvement. The sunset process of reviewing every material on the National List every five years, in order for it to remain allowed or prohibited, is a recognition that things change and a material’s necessity or prohibition may need to be modified. Have new methods been developed that make an allowed synthetic no longer needed? Have negative human or environmental effects come to light for materials currently allowed? Have new natural materials been identified that perform the same function as the approved synthetic? Does the prohibition on a natural product need to be revisited?

Organic operators know their annual organic inspection will include discussion of changes that could be made to their organic system of production in order to continually improve their compliance to the organic regulations. These changes mean less reliance on inputs, which positively affects the bottom line of the farmer.

An economic impact analysis must be done before the National Organic Program can make final changes to the organic regulation that removes a material, like ivermectin, which has been allowed for many years. With the allowance of other parasiticides in organic production, I do not see that this removal would have a significant negative economic impact.

Changes to allowed inputs can be stressful for an organic operator, since keeping track of what is allowed and what is not can seem to be a full-time task. Modifying what we do, where we buy inputs, and keeping track of how and when we can use a material, especially if they are changed over time, can be frustrating. However, the integrity of the organic label is the foundation of our marketplace, and continuous improvement that recognizes we can do better, keeps consumer trust in the organic label.

Harriet Behar is the Senior Organic Specialist for MOSES & a member of the National Organic Standards Board.

From the November | December 2016 Issue

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