We have recently received questions regarding whether the occasional, inadvertent application of manure to fields by draft animals is a violation of the NOP regulations.  In responding, we advise certifiers, their applicants, and certified operations to follow the existing NOP regulations regarding the application of raw manure to crops.  The regulations forbid the application of raw manure to a crop 120 days prior to harvest for crops that contact the soil and 90 days prior to harvest for crops that do not contact the soil.  This requirement applies to any raw manure application, whether deposited naturally by livestock or draft animals or manure spread as part of a nutrient management plan.  Producers and their certifiers are required to implement and verify any measures necessary to ensure raw manure is only applied in compliance with the NOP regulations.  Such controls must be clearly described in the producer’s organic systems plan and approved by their NOP accredited certifying agent.   For example, a producer’s OSP may state that dung bags will be worn by all draft animals when working in crop production areas within 120 days prior to harvest.