Letter to USDA about grass fed claim

 AGA submits comments on five specific areas:
1) The 99 Percent Standard
2) Pasture Raised as an Essential Part of the Grassfed Definition
3) Definition of Forage
4)  Grassfed Claim for Dairies and Animal Fiber Producers
5) Standardized Spelling for “Grassfed.”
1) The 99 Percent Standard
As stated above, we strongly support the proposed regulation provisions requiring any meat labeled under this program to be sourced from animals that receive 99 percent of their lifetime energy supply from grass and forage. 
2) Pasture Raised as an Essential Part of the Grassfed Definition
To consumers the term Grassfed means ruminants humanely raised in grass pastures from birth to harvest, the way nature intended.  We are concerned that if this proposed claim passes into regulation you would have the potential for feedlot confined ruminants fed harvested forages, antibiotics, hormones and legally be labeled “Grassfed”.

AGA supports the proposed standard that allows the feeding of harvested grass and forage. However, we feel that the consumer recognition of the term “grassfed” is synonymous with animals having free access to pasture and/or range.  We would like to propose the following language be added to the USDA standard:

It is the intent of this standard to prevent the finishing of ruminants for slaughter in confinement such as a feedlot environment, as defined by EPA’s definition of a CAFO, where non grain forage products are substituted for grain concentrates. 

Grassfed ruminants must graze pasture during the entire growing season and preferably beyond (aside from the exceptions granted in this definition) where they will receive most if not all of their nutrition and be allowed to fulfill their natural behaviors and basic instincts of grazing at all times.

AGA believes exceptions to this provision should be limited to emergencies that may threaten the safety and well-being of the animals or soil and management practices such as roundups, sorting, shipping and weaning.  This provision should not be interpreted as to exclude a MIG or other high intensity rotational grazing systems.

3) Definition of Forage

AGA supports for the most part the definitions of forage as set forth in the standard.  However, we feel that further clarification of the definition might strengthen the standard and make it less subject to abuse.  Specifically, we refer to corn silage and grain in the “immature” state as being acceptable forage in the standard.  We feel this opens the door to a sliding scale of interpretation that has the potential to be extremely subjective.  Perhaps the inclusion of language to the effect that grain species of forage must be in the vegetative state when harvested or grazed would help to clarify. 

At any rate, we feel that further review of the inclusion of this type of forage needs to be addressed in order to strengthen the precise meaning of what is acceptable.  AGA as producers, researchers and end-use consumer advocates would appreciate the opportunity to work with the USDA in choosing verbiage that will not easily allow for misuse of these grain producing forages.

4)  Grassfed Claim for Dairies and Animal Fiber Producers

The AGA is an association that represents grassfed producers of numerous livestock species.   We propose that the grassfed claim be applied to all ruminant animal products including meat, meat products, milk, milk products, animal fiber, and animal fiber products.  We want to ensure that our current and future members as well as all other non-member grassfed producers can benefit from the grassfed ruminant claim.

5) Standard Spelling for “Grass Fed”

There exist at least three spellings of “grass fed” that are currently in use for grassfed ruminant livestock production in the US.  These spellings are “grass fed”, “grassfed”, and “grass-fed”.  The AGA suggests that a standardized spelling of grassfed be determined to minimize confusion among producers, marketers, consumers, and industry organizations.  We of course prefer “grassfed”, since this spelling is reflected in our organization’s name which has been in use since 2003.

Again the American Grassfed Association membership appreciates the development of these proposed standards for voluntary labeling of grassfed meat, and look forward to working with your divisions on this issue in the future.

Sincerely,

Patricia Whisnant, DVM
President
American Grassfed Association
(573) 996-5333
pwhisnant@americangrassfedbeef.com