What's At Stake?

Ensure the USDA has a Strong Grass-fed Meat Standard

UCS submitted the following comments to the USDA on the proposed grass-fed meat standard.

Martin E. O'Connor, Chief
Standardization Branch
Livestock and Seed Program
Agricultural Marketing Service
United States Department of Agriculture
Room 2607-S
1400 Independence Avenue, SW
Washington, DC 20250-0254

RE: Docket No. LS-05-09.

Dear Mr. O'Connor:

On behalf of the Union of Concerned Scientists' 200,000 members and supporters, we write to offer the following comments in support of the Agricultural Marketing Service’s proposed standard for the Grass (Forage) Fed Claim.

The Union of Concerned Scientists (UCS) is a nonprofit partnership of scientists and citizens combining rigorous scientific analysis, innovative policy development, and effective citizen advocacy to achieve practical environmental solutions. UCS's Food and Environment Program seeks to ensure that food is produced in a safe and sustainable manner.

UCS strongly supports well-managed grass-fed and grass-finished cattle production systems in the United States. In March 2006, UCS published a report, Greener Pastures: How grass-fed beef and milk contribute to healthy eating, that examines the potential nutrition benefits of grass-fed and grass-finished beef and dairy products. We hope AMS finds this report to be a helpful resource. It is available online here.

We would like to thank the AMS team that worked with UCS and other stakeholders in developing this proposed standard. UCS participated in a diverse coalition of sustainable agriculture, consumer, environmental, and other organizations led by the Sustainable Agriculture Coalition in developing and submitting to AMS recommendations for this standard. We found the AMS team, headed by Associate Deputy Administrator Bill Sessions, to be informed and genuinely open to input throughout our work with them over the last two years. We believe the team's hard work and thoughtful approach has resulted in an appropriate standard that with one major change should be adopted.

UCS strongly prefers this 99 percent standard over a standard that AMS proposed in 2003 that simply said that "grass, green or range pasture, or forage, shall be 80% or more of the primary energy source throughout the animal’s life cycle." Many stakeholders, notably grass-fed producers, objected to this proposed standard. Those voicing opposition were concerned that the 80 percent requirement would allow for a considerable amount of grain feeding, which would undercut those producers who were already feeding 100 percent forage over the animals' lifetimes (except for milk up to weaning) as well as those consumers who would have expected a higher standard for "grass-fed" products.

UCS Supports AMS's 99 Percent Grass-fed Standard

UCS supports AMS's proposed Grass (Forage) Fed Claim requiring a grass or forage-based diet that is 99 percent or higher, although as we discuss later the proposed definition needs to be changed to eliminate the possibility of feeding more than 1% grain. We believe this meaningful standard will reinforce a growing agricultural sector that offers many benefits over conventionally raised cattle products.

Conventional corn- and confinement-based beef and dairy operations raise a host of concerns, including water, air, and soil pollution; greenhouse gas emissions; inefficient use of energy; odors; inhumane treatment of animals; reliance on drugs; and the promotion of antibiotic resistance in bacteria. There is general agreement among scientists that grass-feeding cattle on well-managed pastures provides significant environmental and other benefits.

Environmental Benefits
The environmental benefits of well-managed grass-fed systems stem largely from not feeding the animals grains and from not having the animals and their waste densely confined in small areas.

The production of feed grains accounts for a significant part of the negative environmental impact of conventional corn- and confinement-based beef and dairy operations. Most of the grain produced in the United States, including more than 70 percent of all corn, is fed to farm animals. Growing grains, including corn, for animal feed has negative environmental effects. Corn production demands inordinately high levels of fertilizer (i.e., biologically usable nitrogen), and corn grown for cattle feed accounts for more than 40 percent of all the commercial fertilizer and herbicides applied to U.S. crops. Fertilizer runoff from fields contributes to the problems of high nitrate levels and the depletion of oxygen that produces "dead zones" in the Gulf of Mexico. The same movement of nitrates from fertilizer into groundwater carries toxic pollutants including atrazine, an herbicide used on corn. And because almost half of all corn acres are irrigated, and most of these acres are in the rain-deficient states of Kansas, Nebraska, and Texas, this practice has contributed to the depletion of the Ogallala aquifer. Corn production is subsidized by taxpayers in the form of government payments to producers.

Significant negative environmental impacts are also associated with the concentrated animal feeding operations (CAFOs) themselves. These operations concentrate large quantities of manure in a small area. Because manure is heavy and expensive to haul far enough to use productively as fertilizer, CAFOs often apply manure to nearby land in amounts that plants and soil cannot absorb. The result is runoff of nutrients such as nitrogen and phosphorus that pollute surface waterways and underground water tables. CAFOs also pollute the air, emitting hazardous substances such as nitrogen gases, fine particulates, and pesticides, and dust particles that can carry pathogenic organisms. This air pollution poses health hazards for workers, cattle, and nearby communities. The greenhouse gases methane and ammonia are also released by CAFOs. Manure-related odors are another serious environmental problem associated with CAFOs that can have negative effects on human and animal health.

The environmental benefits of carefully managed grass-fed systems that do not confine animals or concentrate large quantities of manure, by contrast, can include:
o reduced emissions of heat-trapping or greenhouse gases,
o increased carbon sequestration,
o decreased energy use,
o reduced water pollution,
o decreased soil erosion,
o reduced sediment in waterways,
o reduced soil nutrient loss,
o decreased fertilizer and herbicide use and runoff,
o decreased air pollution, and
o increased opportunities for wildlife habitat.

Benefits to Animal and Human Health
Conventional corn-based diets can sicken cattle. Cattle are ruminant animals that naturally eat grass and forage. Because corn is low in fiber and high in starch, a corn-based diet allows fermentation acids to accumulate in cows' stomachs. This acid buildup can cause ulcers, through which infectious bacteria can enter the digestive tract and eventually produce abscesses in the liver. Grain-based diets can also promote virulent strains of E. coli in the digestive tract.

In addition, the crowded, unsanitary, and stressful conditions at conventional feedlots and dairy CAFOs can be dangerous to the health of cattle. For example, feedlot cattle suffer both morbidity and mortality from diseases including dust-related respiratory conditions, metabolic diseases, and other ailments that can be directly attributed to their confined conditions. Some feeds have been linked to bovine spongiform encephalopathy (BSE), or "mad cow" disease.

Conventional feedlots attempt to counteract the prevalence of health problems with heavy use of drugs, including antibiotics. This use of antibiotics speeds the development of antibiotic-resistant bacteria, which can infect people who consume meat as well as those working at, living near, or living downstream of CAFOs. Antibiotic-resistant bacteria can be more virulent and are linked to illnesses in people that are difficult to treat. This pressing public health problem increases human suffering and costs the U.S. economy billions of dollars each year.

By contrast, there is little need to rely on drugs at well-managed grass-fed operations that do not confine animals or concentrate large quantities of manure. These systems are better for the health of the animals, the agricultural producers, the neighboring communities, and consumers.

Nutrition Benefits
There may also be nutrition benefits from the products that meet the proposed standard AMS has set out. In the analysis done for the Greener Pastures report, we confirmed that grass-fed beef has lower total fat and tends to have higher amounts of some of the so-called beneficial fatty acids than grain fed beef. The amounts are relatively small but further research may show that they do lower the risk of disease. As grain is fed over a period of time, this difference disappears.

Benefits to Producers and the Market for Grass-fed Products
UCS believes that adoption of a 99 percent standard that precludes grain feeding for the Grass (Forage) Fed Claim will benefit producers economically and will help to expand the market for grass-fed beef products.

The standard is consistent with and legitimates the practices already implemented by producers. It will reward producers of true grass-fed and grass-finished beef products for learning about soil biology and fertility, experimenting with the right mix of forages for their particular geographic area, finding better breeds of cattle to produce tender good-tasting meat, switching to new schedules that place cattle on the best pastures before slaughter, and finding the other pieces of the value chain from abattoirs to small restaurant chains. Permanent adoption of the proposed standard will provide these producers with a valuable marketing tool.

UCS also believes the standard will help to increase the growing market for grass-fed beef by giving impetus to producers to move from partial to full grass feeding and by increasing demand for these products.

A growing number of small and mid-sized producers are drawn to this mode of production because of the economic benefits: lower capital costs accompanied by higher premiums. Grass-fed systems generate more profit per animal than conventional operations. Because overall animal health is significantly better than at CAFOs, veterinary and medicine costs are consistently lower for grass-fed systems. Producers can often get premium prices for meat produced without antibiotics and growth hormones and in a way that protects water and other natural resources.

Benefits to Consumers
Finally, UCS believes that adoption of this standard, amended as discussed below, will benefit consumers. This meaningful standard will create, as AMS pointed out in 2003, "a common language for buyers and sellers," and assure buyers that meat labeled as grass-fed comes from fully grass-fed and grass-finished animals.

Ensuring Compliance with the Spirit of the Claim and Standard
Like AMS, UCS would like to ensure that all producers participating in the Process Verified Program for this claim comply with the intent and spirit of the Grass (Forage) Fed Claim and Standard. To this end, we recommend that the rule be clarified to not allow the feeding of significant amounts of grain which could be possible under the ambiguous language now in the proposed rule and background section of the notice.

Specifically, the language of both the proposed rule and background information should more explicitly define the term "immature grain," with the goal of eliminating any possibility that feed harvesting or stockpiling methods that might include significant amounts of grain could potentially be approved under the standard.

UCS Encourages AMS to Promulgate Other Meat and Dairy Standards

UCS applauds AMS for publishing its 99 percent grass or forage-based diet standard for comment in the Federal Register. We ask that this 99 percent standard, with our proposed change that clarifies the definition of forage, be adopted at the earliest possible time following completion of the public comment period.

We understand that this standard applies only to beef—not to dairy. Grass-fed dairy products are also in great demand and grass-fed claims are being applied to dairy labels now. We strongly encourage AMS to develop an appropriate grass-fed standard for dairy products. Without this standard, we believe there is significant danger of consumer confusion, first because there is a standard for grass-fed beef but not for grass-fed dairy and second because meat products from dairy cattle may be labeled grass-fed under AMS's standard while the dairy products from those cattle may not.

We are aware that AMS is currently developing a pasture raised (free range, free roaming, and pasture raised) standard. We strongly support promulgation of this standard as soon as possible. Simultaneously with the grass-fed standard would be optimal. It will be important for AMS to ensure, in the development of this standard, that consumers understand that grass-fed cattle are pasture-raised but that pasture raised cattle are not necessarily grass-fed.

If it's not possible to develop an appropriate grass-fed standard for dairy products, there should be a separate pasture raised standard for dairy systems that sets a minimum percent of the energy source that must be forage. This minimum percent should be developed in consultation with a range of dairy producers and researchers.

We also believe it is necessary to have free range and pasture raised standards for poultry and swine. The pasture raised standard will of course be different for dairy (ruminants) and pork and poultry (non-ruminants) because of the different ability of the different classes to handle forage.

We understand that the AMS team working on the grass-fed standards is also empowered to develop other standards for cattle, sheep, and swine, but not for poultry. In the case of the free range, free roaming, and pasture raised standards, we encourage this team to work cooperatively with the AMS team empowered to develop standards for poultry, as free range, free roaming, and pasture raised standards that do not apply to poultry will likely be confusing to consumers.

The standards currently under consideration by AMS for antibiotic use and hormones use standards are complementary to the Grass (Forage) Fed Claim and Standard and are important for producers and consumers. UCS encourages AMS to finalize these standards as soon as possible.

Thank you for your thoughtful consideration of these comments.

Sincerely,

Kate Clancy, Ph.D.
Senior Scientist

Susan Prolman, J.D.
Washington Representative

The Union of Concerned Scientists
Food and Environment Program

Click here to send your own letter to the USDA urging them to clarify the proposed standard so that consumers will know that grass-fed really means grass-fed!

Go Back


	What's At Stake? Ensure the USDA has a Strong Grass-fed Meat Standard UCS submitted the following comments to the USDA on the proposed grass-fed meat standard. Martin E. O'Connor, Chief Standardization Branch Livestock and Seed Program Agricultural Marketing Service United States Department of Agriculture Room 2607-S 1400 Independence Avenue, SW Washington, DC 20250-0254 RE: Docket No. LS-05-09. Dear Mr. O'Connor: On behalf of the Union of Concerned Scientists' 200,000 members and supporters, we write to offer the following comments in support of the Agricultural Marketing Service’s proposed standard for the Grass (Forage) Fed Claim. The Union of Concerned Scientists (UCS) is a nonprofit partnership of scientists and citizens combining rigorous scientific analysis, innovative policy development, and effective citizen advocacy to achieve practical environmental solutions. UCS's Food and Environment Program seeks to ensure that food is produced in a safe and sustainable manner. UCS strongly supports well-managed grass-fed and grass-finished cattle production systems in the United States. In March 2006, UCS published a report, Greener Pastures: How grass-fed beef and milk contribute to healthy eating, that examines the potential nutrition benefits of grass-fed and grass-finished beef and dairy products. We hope AMS finds this report to be a helpful resource. It is available online here. We would like to thank the AMS team that worked with UCS and other stakeholders in developing this proposed standard. UCS participated in a diverse coalition of sustainable agriculture, consumer, environmental, and other organizations led by the Sustainable Agriculture Coalition in developing and submitting to AMS recommendations for this standard. We found the AMS team, headed by Associate Deputy Administrator Bill Sessions, to be informed and genuinely open to input throughout our work with them over the last two years. We believe the team's hard work and thoughtful approach has resulted in an appropriate standard that with one major change should be adopted. UCS strongly prefers this 99 percent standard over a standard that AMS proposed in 2003 that simply said that "grass, green or range pasture, or forage, shall be 80% or more of the primary energy source throughout the animal’s life cycle." Many stakeholders, notably grass-fed producers, objected to this proposed standard. Those voicing opposition were concerned that the 80 percent requirement would allow for a considerable amount of grain feeding, which would undercut those producers who were already feeding 100 percent forage over the animals' lifetimes (except for milk up to weaning) as well as those consumers who would have expected a higher standard for "grass-fed" products. UCS Supports AMS's 99 Percent Grass-fed Standard UCS supports AMS's proposed Grass (Forage) Fed Claim requiring a grass or forage-based diet that is 99 percent or higher, although as we discuss later the proposed definition needs to be changed to eliminate the possibility of feeding more than 1% grain. We believe this meaningful standard will reinforce a growing agricultural sector that offers many benefits over conventionally raised cattle products. Conventional corn- and confinement-based beef and dairy operations raise a host of concerns, including water, air, and soil pollution; greenhouse gas emissions; inefficient use of energy; odors; inhumane treatment of animals; reliance on drugs; and the promotion of antibiotic resistance in bacteria. There is general agreement among scientists that grass-feeding cattle on well-managed pastures provides significant environmental and other benefits. Environmental Benefits The environmental benefits of well-managed grass-fed systems stem largely from not feeding the animals grains and from not having the animals and their waste densely confined in small areas. The production of feed grains accounts for a significant part of the negative environmental impact of conventional corn- and confinement-based beef and dairy operations. Most of the grain produced in the United States, including more than 70 percent of all corn, is fed to farm animals. Growing grains, including corn, for animal feed has negative environmental effects. Corn production demands inordinately high levels of fertilizer (i.e., biologically usable nitrogen), and corn grown for cattle feed accounts for more than 40 percent of all the commercial fertilizer and herbicides applied to U.S. crops. Fertilizer runoff from fields contributes to the problems of high nitrate levels and the depletion of oxygen that produces "dead zones" in the Gulf of Mexico. The same movement of nitrates from fertilizer into groundwater carries toxic pollutants including atrazine, an herbicide used on corn. And because almost half of all corn acres are irrigated, and most of these acres are in the rain-deficient states of Kansas, Nebraska, and Texas, this practice has contributed to the depletion of the Ogallala aquifer. Corn production is subsidized by taxpayers in the form of government payments to producers. Significant negative environmental impacts are also associated with the concentrated animal feeding operations (CAFOs) themselves. These operations concentrate large quantities of manure in a small area. Because manure is heavy and expensive to haul far enough to use productively as fertilizer, CAFOs often apply manure to nearby land in amounts that plants and soil cannot absorb. The result is runoff of nutrients such as nitrogen and phosphorus that pollute surface waterways and underground water tables. CAFOs also pollute the air, emitting hazardous substances such as nitrogen gases, fine particulates, and pesticides, and dust particles that can carry pathogenic organisms. This air pollution poses health hazards for workers, cattle, and nearby communities. The greenhouse gases methane and ammonia are also released by CAFOs. Manure-related odors are another serious environmental problem associated with CAFOs that can have negative effects on human and animal health. The environmental benefits of carefully managed grass-fed systems that do not confine animals or concentrate large quantities of manure, by contrast, can include: o reduced emissions of heat-trapping or greenhouse gases, o increased carbon sequestration, o decreased energy use, o reduced water pollution, o decreased soil erosion, o reduced sediment in waterways, o reduced soil nutrient loss, o decreased fertilizer and herbicide use and runoff, o decreased air pollution, and o increased opportunities for wildlife habitat. Benefits to Animal and Human Health Conventional corn-based diets can sicken cattle. Cattle are ruminant animals that naturally eat grass and forage. Because corn is low in fiber and high in starch, a corn-based diet allows fermentation acids to accumulate in cows' stomachs. This acid buildup can cause ulcers, through which infectious bacteria can enter the digestive tract and eventually produce abscesses in the liver. Grain-based diets can also promote virulent strains of E. coli in the digestive tract. In addition, the crowded, unsanitary, and stressful conditions at conventional feedlots and dairy CAFOs can be dangerous to the health of cattle. For example, feedlot cattle suffer both morbidity and mortality from diseases including dust-related respiratory conditions, metabolic diseases, and other ailments that can be directly attributed to their confined conditions. Some feeds have been linked to bovine spongiform encephalopathy (BSE), or "mad cow" disease. Conventional feedlots attempt to counteract the prevalence of health problems with heavy use of drugs, including antibiotics. This use of antibiotics speeds the development of antibiotic-resistant bacteria, which can infect people who consume meat as well as those working at, living near, or living downstream of CAFOs. Antibiotic-resistant bacteria can be more virulent and are linked to illnesses in people that are difficult to treat. This pressing public health problem increases human suffering and costs the U.S. economy billions of dollars each year. By contrast, there is little need to rely on drugs at well-managed grass-fed operations that do not confine animals or concentrate large quantities of manure. These systems are better for the health of the animals, the agricultural producers, the neighboring communities, and consumers. Nutrition Benefits There may also be nutrition benefits from the products that meet the proposed standard AMS has set out. In the analysis done for the Greener Pastures report, we confirmed that grass-fed beef has lower total fat and tends to have higher amounts of some of the so-called beneficial fatty acids than grain fed beef. The amounts are relatively small but further research may show that they do lower the risk of disease. As grain is fed over a period of time, this difference disappears. Benefits to Producers and the Market for Grass-fed Products UCS believes that adoption of a 99 percent standard that precludes grain feeding for the Grass (Forage) Fed Claim will benefit producers economically and will help to expand the market for grass-fed beef products. The standard is consistent with and legitimates the practices already implemented by producers. It will reward producers of true grass-fed and grass-finished beef products for learning about soil biology and fertility, experimenting with the right mix of forages for their particular geographic area, finding better breeds of cattle to produce tender good-tasting meat, switching to new schedules that place cattle on the best pastures before slaughter, and finding the other pieces of the value chain from abattoirs to small restaurant chains. Permanent adoption of the proposed standard will provide these producers with a valuable marketing tool. UCS also believes the standard will help to increase the growing market for grass-fed beef by giving impetus to producers to move from partial to full grass feeding and by increasing demand for these products. A growing number of small and mid-sized producers are drawn to this mode of production because of the economic benefits: lower capital costs accompanied by higher premiums. Grass-fed systems generate more profit per animal than conventional operations. Because overall animal health is significantly better than at CAFOs, veterinary and medicine costs are consistently lower for grass-fed systems. Producers can often get premium prices for meat produced without antibiotics and growth hormones and in a way that protects water and other natural resources. Benefits to Consumers Finally, UCS believes that adoption of this standard, amended as discussed below, will benefit consumers. This meaningful standard will create, as AMS pointed out in 2003, "a common language for buyers and sellers," and assure buyers that meat labeled as grass-fed comes from fully grass-fed and grass-finished animals. Ensuring Compliance with the Spirit of the Claim and Standard Like AMS, UCS would like to ensure that all producers participating in the Process Verified Program for this claim comply with the intent and spirit of the Grass (Forage) Fed Claim and Standard. To this end, we recommend that the rule be clarified to not allow the feeding of significant amounts of grain which could be possible under the ambiguous language now in the proposed rule and background section of the notice. Specifically, the language of both the proposed rule and background information should more explicitly define the term "immature grain," with the goal of eliminating any possibility that feed harvesting or stockpiling methods that might include significant amounts of grain could potentially be approved under the standard. UCS Encourages AMS to Promulgate Other Meat and Dairy Standards UCS applauds AMS for publishing its 99 percent grass or forage-based diet standard for comment in the Federal Register. We ask that this 99 percent standard, with our proposed change that clarifies the definition of forage, be adopted at the earliest possible time following completion of the public comment period. We understand that this standard applies only to beef—not to dairy. Grass-fed dairy products are also in great demand and grass-fed claims are being applied to dairy labels now. We strongly encourage AMS to develop an appropriate grass-fed standard for dairy products. Without this standard, we believe there is significant danger of consumer confusion, first because there is a standard for grass-fed beef but not for grass-fed dairy and second because meat products from dairy cattle may be labeled grass-fed under AMS's standard while the dairy products from those cattle may not. We are aware that AMS is currently developing a pasture raised (free range, free roaming, and pasture raised) standard. We strongly support promulgation of this standard as soon as possible. Simultaneously with the grass-fed standard would be optimal. It will be important for AMS to ensure, in the development of this standard, that consumers understand that grass-fed cattle are pasture-raised but that pasture raised cattle are not necessarily grass-fed. If it's not possible to develop an appropriate grass-fed standard for dairy products, there should be a separate pasture raised standard for dairy systems that sets a minimum percent of the energy source that must be forage. This minimum percent should be developed in consultation with a range of dairy producers and researchers. We also believe it is necessary to have free range and pasture raised standards for poultry and swine. The pasture raised standard will of course be different for dairy (ruminants) and pork and poultry (non-ruminants) because of the different ability of the different classes to handle forage. We understand that the AMS team working on the grass-fed standards is also empowered to develop other standards for cattle, sheep, and swine, but not for poultry. In the case of the free range, free roaming, and pasture raised standards, we encourage this team to work cooperatively with the AMS team empowered to develop standards for poultry, as free range, free roaming, and pasture raised standards that do not apply to poultry will likely be confusing to consumers. The standards currently under consideration by AMS for antibiotic use and hormones use standards are complementary to the Grass (Forage) Fed Claim and Standard and are important for producers and consumers. UCS encourages AMS to finalize these standards as soon as possible. Thank you for your thoughtful consideration of these comments. Sincerely, Kate Clancy, Ph.D. Senior Scientist Susan Prolman, J.D. Washington Representative The Union of Concerned Scientists Food and Environment Program Click here to send your own letter to the USDA urging them to clarify the proposed standard so that consumers will know that grass-fed really means grass-fed! Go Back