Using cover crops for feed or grazing
The use of cover crops as a means to improve soil health and reduce erosion and to some degree for weed control is increasing in the area. Some producers see this crop as an additional source for forage. Agencies have lifted some restrictions on the use of cover crops. For example, there has been recent assistance put in place by USDA NRCS to help establish cover crops including the allowance for grazing and harvesting in some situations. Additionally, the USDA has changed crop insurance rules for 2013 only to allow the production of cover crops and emergency forage crops while allowing insurance coverage for crops planted in the spring of 2013.
However, it is important to know, that these changes do not override the legal implications and responsibilities to safely use pesticides in accordance with pesticide labels. The question is "can a cover crop be used as forage if the species was seeded following a soybean/corn herbicide program?" The answer is that it depends on the previous herbicide that were applied to the field and the specific rotation restrictions listed on the herbicide label. The restrictions on the label are put in place to ensure we continue to produce a safe meat and milk supply.
When it comes to the issue grazing or feeding their cover crop, the issue is that once a herbicide is used in the previous corn or soybean crop, the grazing and feeding restrictions on those herbicide labels must be followed for that crop and the subsequent cover crop until the restrictions on those labels have been met. If the specific cover crop species you have planted and is not listed on the herbicide label, this does not mean that the species you have planted can legally be fed or grazed. Most of the species being used for cover crops are not specifically mentioned on current herbicide labels. In those cases, growers must fall back to the default listing on the label, which usually states something to the effect of "all other crops" or "all others" to find the grazing and/or feeding restrictions that they must follow, according to Kevin Bradley, University of Missouri weed specialist. Most often, the average rotation restriction for cover crop species that fall into this "all other crops" category is between 12 and 18 months after treatment.
The best thing to do if you are considering using cover crops for feed or grazing is to check your herbicide labels.
1. If the crop is to be planted as a cover crop only, then plant back restrictions on a label can be ignored but the grower assumes all risk of succeeding crop damage or failure.
2. If a plant species in whole or in parts is harvested for food or feed purposes, it is considered a crop and must be considered a crop on all pesticide labels.
3. It is a legal obligation of the grower to follow all plant back restrictions before harvesting a crop that will enter the food or feed chain.
4. If a plant species is not specifically listed on the label, it should be considered as an "other" crop and maximum rotation restrictions should be followed.
5. Most herbicides, particularly residual herbicides, have plant back restrictions that are longer than one year (most often 18 to 24 months) for crops not specifically listed on the label.