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"To redress the reputation of organic farming, to put animal welfare first on permanent pasture farms, I propose the creation of a new category of organic farmer that I will call Organic "B". ..."

Open letter to the Soil Association and the Organic Farmers and Growers

from Dr Ruth Watkins:


Proposal for a new organic status for hill farmers and conservation farmers- Organic “B”



Introduction and problems with the organic rules


                I am coming out of the organic farming scheme at the earliest opportunity.  I am a hill farmer and bought a small organic farm in its second year of conversion four years ago.  I am not alone among hill farmers in finding it impossible to continue. Rather than go quietly I would like to do something to improve animal welfare on upland organic farms.


 The two issues upon which organic rules fail my hill farm are the welfare of the farm animals and the conservation of ancient grassland.  I am a sheep and beef farmer with local native breeds on a permanent pasture farm at 600 feet situated in the westernmost end of the Brecon Beacons National Park.  In the summer my hefted flock of sheep grazes the common land of the Black mountain.  In this idyllic setting I never imagined that being organic could be so unsatisfactory. The organic rules have made it impossible for me to market healthy organic lambs, to prevent staggers caused by low magnesium in my cows with calves and to conserve my rare fen meadow. 


The organic rules as devised by Europe, and you, seem to be designed for mixed farms and not for permanent pasture farms.   On the mixed farm much or all of the farmland is improved and on drained lowland.  The improved land can be ploughed and be part of a crop rotation over a period of several years consisting of one or two cereal crops, root crops or legumes, and clover rich short-term grass leys.  This provides high quality animal fodder, clean pasture free of worm larvae for lambs, improvement of soil fertility through nitrogen fixation and control of perennial weeds such as creeping thistle.  Applications of calcified seaweed, manure, magnesium limestone, rock phosphate and trace elements can be made as necessary.  The welfare of the farm animals is satisfactory under this system. 


However this is in contrast to the permanent pasture farm, usually on acid soil that may be wet or very wet from a high rainfall and lack of drainage and often low in one or more essential minerals where the welfare of the animals is greatly improved by mineral supplementation and vaccines and treatments to prevent disease and death.  It may also be steep and rocky and not susceptible to ‘topping’ as a means of controlling weeds, let alone ploughing.  It is likely to have few if any fields suitable for cultivation and cropping.  The forage conserved annually will be of lower nutritional value than that from legumes, red clover or a new grass ley of rye grass and white clover.  As it is less favoured in terms of arable or dairy production there is likely to be unimproved pasture that has been left untouched since modern farming techniques, organic or non-organic were introduced. 


Conservation of unimproved pasture



Unimproved pastures should not be ploughed, limed, manured or spread with nitrogen, phosphorous or trace elements.  Improved pastures are those that have received chemical fertilizers or rock phosphate, slag and significant amounts of manure at some time in the past fifty years or so, and that have been drained and ploughed and sown with purchased seed.  The plant community on unimproved or ancient pasture, in comparison with an improved pasture, consists of a much richer diversity of plant species that are native to Britain. These are sensitive to the level of nitrogen and phosphorous and out-competed by agricultural grasses and weeds that thrive when these elements are applied in any form.  The native species of wild plants cannot be bought from seed merchants who supply seed mixed from monocultures that consist of hybrids, varieties or sub-species and may be derived from abroad, rather than our native plants many of which cannot be cultivated in monoculture.  Genetically these plants are different and a botanist can recognise these from amongst the native flora.  I found the merchant, from whom I bought extremely expensive seed suitable for woodland to cover a landslip, could not give me the genetic provenance of the seed he supplied.  Most of the plant species that emerged from the seed he sold me are recognisably different to the local native flora species though called by the same name.  I got his catalogue free with the “Organic Farming” magazine!  He was not interested in gathering seed from my wet meadows.  Improved fields are not easily or quickly changed back to the unimproved state, thus the importance of conserving the unimproved and ancient pasture that remains.


A permanent pasture farm is commonly on upland, often called marginal or less favoured land, and occurs down the whole of the western half of the British Isles along the Atlantic seaboard.  Upland pasture may be grassland, fen or moor, the latter usually common grazing.  The topsoil may be a mineral soil or peat and excepting chalk down, which is alkaline, it is usually acidic.  The underlying subsoil or rock may be permeable (well drained) or impermeable to water (wet), may contain a rich variety of different elements or very few elements available for plants as in the case of granite or old red sandstone.  The depth of topsoil and subsoil varies.  There is also less favoured lowland; undrained fens, marshes or levels, as well as brecks and heaths. Clearly less favoured land is not usually favourable for growing crops, except perhaps for lowland fens and levels.  Unimproved pasture is of high conservation value whether upland or lowland.  It is a complex spectrum of habitats supporting many insects, butterflies and moths, amphibians, birds and mammals as well as plants.  Many species of sedges, rushes, grasses, forbs or herbs, ferns and horsetails, mosses and liverworts make up these plant communities.  The unimproved pasture has evolved in some cases over thousands of years since the first Neolithic farmers and the Bronze age.  Light and timely grazing with our native breeds of farm animals maintain the unimproved grassland and moor plant communities, otherwise most would return to climax woodland with permanent loss of these special habitats.  This type of farmland is a jewel in the crown of British landscape biodiversity.  The ecology of the Western seaboard of Europe is greatly enriched by this diverse ancient pasture with a high rainfall and under the influence of the oceanic climate of the Atlantic.     


My fen meadow and the problem with alder


I have pastures that have never been ploughed, that are wet and marshy including a fen meadow. These pastures are ideally grazed by cattle, the best conservators as they graze unselectively and wrap their tongue round the forage to tear off a mouthful leaving the lower leaves of the plant intact.  Alder invading from the surrounding carr is threatening to overwhelm some of the last hectares of this fen meadow of the type m24c in South Wales (British Plant Communities vol. 2 edited by Rodwell).  Under the direction of the welsh countryside scheme Tir Gofal, so as not to disturb the plant community of the fen meadow, each individual alder tree (100s) must be carefully poisoned by hand with Round up.  This is an herbicide that reaches the roots of the plant it is applied to, is confined to that plant and is biodegraded in about 6 weeks.  Interestingly animals avoid grazing alder, perhaps it is too bitter, and this may be the reason why alder carr surrounds my fen and encroaches upon it.  I found that the cattle browsed seven of some 240 small alder trees I monitored whilst they heavily browsed every other type of young tree, some 140 birch, willow, oak and ash, and that these were on average one metre shorter than the alder.  The fen meadow must be grazed each year, 50% of the purple moor grass must be eaten off, so it does not become rank and overwhelm the other members of the plant community.  It will take several years to undo the neglect that has allowed young alders to become established; meanwhile I will not be allowed to graze it with my organic Welsh Black cattle under the organic rules. 


Health issues for sheep and cattle on hill farms and unimproved pasture



I see myself as a conservation farmer, a Flora and Fauna farmer.  My farm is too small to be commercially viable, and together with many small farmers in Europe I farm only part time.  Native breeds of farm animal are the most suitable for me and I must buy in any high quality food my animals need, and supply them with the essential trace elements lacking in my soil in a form I am sure they will consume.  Spreading trace elements and magnesium limestone is limited to my few improved pastures.  The cattle, my best conservationists, must graze the unimproved pasture, the wet and marshy grassland, heath and the fen meadow, for 4 months of the year. They require magnesium whilst they calve and lactate especially when the fodder is poor and the weather is bad- not just during the spring flush of grass growth.  Magnesium is bitter and the organic forms I am allowed to give they find unpalatable.  They would rather die than lick them.  I was lucky to save one cow from my small herd of seven but then lost another to low magnesium, ‘staggers’, two days after she calved. The liquid molasses with magnesium I need to give, on the vet’s recommendation, is not permitted under organic rules as it contains vitamins. However they will all consume sufficient of this to prevent death from staggers.  It is difficult to get what I need for supplementation of trace elements, cobalt, copper, selenium and zinc from organic suppliers and what I have had has been unpalatable and thus insufficient for the cattle.  These trace elements are all included in the molasses magnesium mixture I am not supposed to give them under organic rules.


Cattle and sheep


 Liver fluke is prevalent in this wet landscape and infects both cattle and sheep.  Parasitic worm larvae on the pastures thrive in wet conditions and are not eliminated by frost and snow. Infectious parasites such as scab mites, ticks, and lice are passed among the sheep grazing common land, as also is the virus infection, Orf.  Clostridia and other bacterial infections, especially of sheep’s feet, lurk in the wet pasture.  Vaccines and appropriate treatment with modern medicines to prevent these infections is needed as well as supplementary minerals to redress the deficiencies.


A consumer’s disappointment at the reality of organic farming


I had not expected to encounter such a number of welfare problems on an organic farm.  I had unreasonable expectations because once I was a fluffy bunny consumer imagining that organic farming was synonymous with healthy farming- healthy for the animals, the countryside and us.  I was an urban dweller, a resident of London, who knew nothing about farming.  I worked as a doctor, a clinical virologist, and when I had cancer and the treatment for it I became interested in nutrition.  I took mineral and vitamin supplements during that difficult time and bought organic food.  I did this to avoid pesticide and herbicide residues that may have had oestrogen-like or other harmful mutagenic effects.  I also imagined that the expensive organic meat I bought came from animals that were especially healthy, grazing on old-fashioned meadowland or mountains, compared to those raised non-organically.


I could not have been more wrong about organic animals from upland farms.  I never dreamt that they were refused mineral and vitamin supplements, modern vaccines or medicines, should they be needed to keep them healthy and prevent disease.  Treatment is allowed for organic animals once they are ill, but it is usually too late and they have died, cannot be saved or have been permanently harmed, their often short life blighted by ill health and their growth stunted.  Instead of the pastoral bliss I had foolishly imagined I found sickness that could have been prevented in my lambs, death from staggers in a cow that could also have been prevented, and my fen meadow threatened by rules that would not allow my organic welsh black cows to graze it were I to eliminate the invading alder scrub with round-up as recommended by Tir Gofal the countryside scheme for Wales. 


Sick Lambs

The first year my lambs were really sick was in 2002, my first fully organic crop of lambs in contrast to 2001 my last crop of non-organic lambs.  In 2002 after weaning the lamb’s growth was stunted and they were thin; they had staring friable wool of poor quality and permanent diarrhoea with filthy rears.  Some died.  I had the vet and it was mineral deficiency of cobalt, selenium and zinc, together with parasitic gastroenteritis caused by worms.  I was horrified to find that following the organic rules had produced this preventable disease.  Despite oral treatment with mineral drenches and anti-wormer they never fully recovered.  My organic farming neighbours have suffered similar problems with their organic lambs and feel the same revulsion and sorrow at the needless suffering, quite apart from the financial loss. 


Parasite infection in lambs


The lambs need anti-wormer two or three times in their short lives when they cannot have truly clean pasture to graze.  They are too young when killed to have developed the natural immunity to worms that occurs around one year of age.  The lambs pick up worms on the mountain as well as in my fields.  The grassland here is never baked bone dry for weeks on end, so the worm larvae are not eliminated by natural means (ploughing or not grazing for more than one year are other ways of cleaning a pasture of worm larvae).  Ideally the lambs should also be treated for fluke as well when they are brought down from the mountain, as upon slaughter a number are found to have gross lesions in their liver. 


Essential minerals, trace elements for lambs


The lambs also need trace elements. The trace elements are in the lowest part of the grass in the stem near the soil, as are the worm larvae, so infrequent grazing of sheep pastures when the grass reaches more than 4 inches high is not ideal from a nutritional point of view.   Cutting a pasture for hay does remove some worm larvae and provides relatively clean pasture on the new growth called the aftermath.  The lambs graze on the aftermath of my improved hay fields from September onwards when they are weaned.  I have tried seaweed meal to provide the minerals they need, mixed with whole oats to tempt them to eat it. This can only be started when they are down from the mountain in September, they need time to acquire the taste for eating it and they won’t touch it when it is wetted by rain.  Not all lambs will eat it anyway. Whilst it was dry in 2003 and the oats and seaweed meal helped, in 2004 it was so wet that they would not take it. In wet weather when they most need it they won’t eat it. In 2004 the lambs were sick again with mineral deficiency and diarrhoea. I checked for worms but they were clear and they responded well to a mineral drench, Liquithrive for sheep.  The very wet weather had either washed away the trace elements I have spread on the improved fields, or the grass cannot take them up when the ground is saturated.   Trace element boluses are too big for small lambs, and may be brought up and I find them on the pasture.  Lambs won’t lick any block no matter how palatable.  The best way to give trace elements to lambs is to give an oral dose to all the lambs before they develop a clinical deficiency.  The drenches I can purchase for this are not allowed by the organic rules because a few elements are chelated and vitamins A, D and E are normally included, as in Agri-Lloyd’s organically chelated ‘Liquithrive’ preparation for sheep.  I need to be able to use the products available to me down at the farmer’s shop.  The alternative, of persuading Rumenco, who make non-organic palatable licks suitable for ewes or cows, to make such licks for me within the organic rules, is too expensive, as they must stop all production, clean the factory and then will make no less than a ton at a time!  I have not been able to finish an organic lamb since September 2003.  Those in 2002 were not finished but sold as stores when they had made their limited recovery as they were in 2004.


Scab and fluke in sheep


 I also need to treat the lambs for scab, the sheep scab mite causes mange.  It is picked up on the common grazing. I don’t wish to give this up as this is part of our cultural and environmental heritage and hefted flocks of sheep once lost are difficult to recreate.  I any case my sheep also pick this up from my neighbour’s untreated sheep, either through a gate or when they escape from a field and come close to my sheep.  I cannot dip my sheep to treat or prevent scab because I have no safe way to dispose of the environmental poison one is permitted to use on organic farms (the pyrethroids permitted are highly toxic to freshwater organisms in streams and take some time to biodegrade), so I must use injection.  I am allowed to give an injection of Dectomax for example but I am obliged to double the manufacturer’s withholding time before the lamb can be slaughtered.  For Dectomax 56 days turns into 112 days and I cannot keep the lambs until after Christmas as my grass is too poor in the winter for their continued growth, and the organic premium has finished for the season by then.  When an organic farm gets scab in the lamb flock it loses commercial viability and this alone occurring year upon year is reason enough to leave the organic movement.  The same long withholding period applies to the use of an anti-fluke.  There is no scientific reason for doubling the recommended withholding time of medicines- it tempts organic farmers not to treat scab or fluke properly and thoroughly.


Treating other infections in sheep


Problems with Orf, clostridial infections, lameness from foot rot and flystrike must all be addressed to produce live marketable lambs whether for slaughter or breeding.  Orf is brought back from the mountain by a few lambs and spread amongst the flock by the thistles present in the pasture.  It sets back their growth for weeks, and can be prevented by vaccination.  Both ewes and lambs may need to be vaccinated against clostridial and pneumonic infections.  An organic neighbour lost 17% of their lamb crop during the summer to these infections in 2004 because this was the first year they were fully organic and they were not allowed in consequence to vaccinate the lambs as they had hitherto. The lethal pneumonia caused by pasteurella bacteria that occurs in young animals killing them within hours, can be prevented by vaccination.   Modern vaccines against the seven or more clostridial diseases that can affect sheep (including tetanus) are based on the same principles as the vaccine to prevent tetanus in humans, caused by infection with the bacterium Clostridium tetani.  When vaccination with a toxoid vaccine is given prior to infection, protection is conferred by the immunity that has been raised against lethal toxins that are secreted by the bacteria. Clostridial bacteria are free living in the soil so the risk of infection may be ever present. 


Essential trace elements for lambs, basic facts


Denied supplementary cobalt whilst grazing pasture deficient in it, the lamb will become sick.   My old red sandstone soil is deficient in cobalt at the surface and none is detectable in the subsoil.  Plants cannot take up and accumulate cobalt if it is not there.  Similarly zinc.  The lamb becomes deficient in vitamin B12 after weaning because the bacteria in the rumen have insufficient cobalt in the plant matter to synthesize vitamin B12 that will be absorbed by the lamb further down the gut.  An important source of B12 in the diet for humans is consumption of meat such as lamb.  It is not good for the lamb to be deficient in B12, neither is it so for us.  Zinc is just as important to growth and health both in lambs and humans.  Sufficient zinc should be consumed every day for optimal health and function of the immune system.  A normal level of zinc in the lamb contributes to healthy feet and the prevention of infections. 


The Organic “B” scheme- the solution for organic farming


Organic farming is anti-science


There is much good modern science on healthy nutrition and prevention of infection in farm animals.  The attitude taken by the organic rules to mineral and vitamin supplements and the use of vaccines and anti-parasitic preparations is without scientific foundation.  There is no scientific reason why farm animals should not receive these products to supplement their diet and prevent infection.  Homeopathy should not be imposed upon organic farmers especially where there is no proof that it is efficacious, in treating parasitic and other infections for example.  The organic inspectors ensure that each organic farm must experiment by following the organic rules to the letter and reinvent the wheel in order to use supplements and vaccines they know they need on their farm for which they must obtain proof.  Inevitably on a hill farm this leads to disaster, suffering and death for the animals, loss of commercial viability with an unmarketable product and expensive bills for the vet and numerous tests to produce the proof they need for the organic certification bodies.  I wonder that organic bodies are prepared to offer registration to upland farms without a crop rotation or an annual reseeding of new grass leys.  Organic farming has a poor reputation for animal welfare on upland farms that is justified by my and my neighbour’s experiences.


The organic “B” farming scheme proposed


To redress the reputation of organic farming, to put animal welfare first on permanent pasture farms, I propose the creation of a new category of organic farmer that I will call Organic “B”.  The organic farmers that are able to follow all the organic rules as conceived at present I will call Organic “A” farmers.  The Organic “B” farmers would be permitted to use modern vaccines and medicines as necessary for the welfare of their animals, abiding by the manufacturer’s withholding times without prolonging these.  Organic “B” farmers would also be allowed to use the nutritional supplements in the form of blocks or drenches purchased from the farm shop, as they were needed.  Whilst avoiding GMO foods in the feedstuffs purchased, a small and insignificant amount in some of the licks and blocks available would have to be accepted.  Even if the Organic “B” farmers received lower prices for their products than the Organic “A” farmers, at least they would have a healthy product to sell and may be able to remain commercially viable.


Also the present organic rules are not made with regard to conservation of permanent pasture.  The use of herbicides that are biodegradable and best of all specific, for example hand-wiping alder with Round up or spraying bracken with the specific herbicide Asulox, should also be permitted under Organic “B” rules.  Tall weeds such as bracken and thistle harbour flies and ticks, a menace to sheep.  To cut annually, perhaps more than once every year and by hand, bracken and weeds on permanent pasture is soul destroying and obviously not as useful and satisfying as hand-howing vegetables! The lazy dog method is not useful against rhizomatous weeds like bracken and creeping thistle, and their tools break on stony and rushy ground.  In the 21st century there is not the cheap abundant labour to control weeds by hand as there was in the 19th century.  We must take what help we can from modern methods.  In fact compared with improved pasture there isn’t a problem on unimproved pasture with agricultural weeds except bracken, brambles and trees invading from the field edges.  Any use of herbicide on unimproved and ancient pasture is done only at the instigation of a conservation scheme such as Tir Gofal.


The conflict of the present organic rules with conservation


Surely it is the conservation of the soil and its fertility that is important in the organic movement. Whilst this precludes the application of chemical fertiliser, soluble nitrogen phosphorous and potassium, this surely does include conservation of our native plants and the special habitats a long established community of such plants creates on our various soils. Flame weeding is allowed under the organic rules yet this is detrimental to the soil killing all the organisms near the surface of the soil- entomologists think this is more harmful than round up!  It also kills the seed bank of native plant species. But perhaps there is none in intensively cropped organic soils. Conversely under the organic rules at present I would do better to drain, plough, lime, fertilise and cover with trace elements and magnesium the ancient fen meadow, the Erica tetralix acid heath, and the never ploughed wet and marshy fields to improve the health of my farm animals. Of course I would not do so.  It would be outrageous in the name of organic farming to do this.




I believe organic farming is missing something that is really important.


The informed organic consumer would love to purchase meat from animals that had grazed these unimproved and ancient grasslands, whether enclosed in fields or on the common land of our hills, moors and mountains.  The rearing of animals on permanent pasture is more extensive and less intensive than that on mixed farms.  Also the informed organic consumer would be reassured to know that these animals had enjoyed healthy lives with optimal nutrition, treatment of worms, fluke and other parasites as necessary, and vaccination against diseases they would unavoidably meet whilst they lived their lives in the most natural way possible. Urban consumers would like to play a role in conserving our countryside, our soil and native plant communities and habitats.  An Organic “B” farming movement would enable them to do so.  It would enable the official organic management of far more farmland than at present and add a new dimension to the meaning of animal welfare within the organic movement and its commitment to conservation. 

Dr Watkins would welcome feedback on her ideas from any interested reader.