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USDA’s Grass-fed Meat Standard will Confuse rather than Clarify
by: Montana Organic Producers Co-op and Organic Grassfed Beef Coalition

"Grass and forage shall be the feed source consumed for the lifetime of the ruminant animal, with the exception of milk consumed prior to weaning. The diet shall be derived solely from forage consisting of grass (annual and perennial), forbs (e.g.: legumes, Brassica), browse, or cereal grain crops in the vegetative (pre-grain) state. Animals cannot be fed grain or grain by-products and must have continuous access to pasture during the growing season. Hay, haylage, baleage, silage, crop residue without grain, and other roughage sources may also be included in the feeding regimen. Routine mineral and vitamin supplementation may also be included in the feeding regimen. If incidental supplementation occurs due to inadvertent exposure to non-forage feedstuffs or to ensure the animal’s well-being at all times during adverse environmental or physical conditions, the producer must fully document (e.g., receipts, ingredients, and tear tags) the supplementation that occurs including the amount, the frequency, and the supplements provided."

On October 16, 2007 after five years of work, the USDA Agricultural Marketing Service released the above definition of grass-fed meat standards for ruminant meat animals. The Center for Rural Affairs and others heralded it as “...a victory for family farms”. If, by that, one means that virtually any producer of ruminant livestock can cash in on this definition and sell his livestock as “grass-fed”, then that statement is certainly true. If, however, one hopes that this USDA definition will help clear up misunderstanding and false claims in labeling to the consumer in the marketplace, then this definition is little more than government’s usual attempt at “one size fits all” rules, regulations, and legislation whereby the big guy usually wins and the little guy usually gets lost in the shuffle.
Let’s first remember why people were wanting a standardized definition of grass-fed in the first place......consumers! It was consumers seeking the health benefits of truly grass-finished meats (see www.eatwild.com), and the species-appropriate growing protocols that would be necessary to finish ruminant animals on grass (green pastures, low density grazing systems). Taking the recently released USDA definition and giving it a litmus test of consumer expectations reveals something other than a “victory for family farms”.

HEALTH BENEFITS
Q. Does the standard promote a protocol that imparts the health benefits consumers are seeking (i.e. lower saturated fat content, higher omega-3 fatty acids, more antioxidants such as vitamin E, and more conjugated Linoleic acid)?
A. No. While the standard specifically lists grasses and other growing forages, it allows for hay, haylage, baleage, silage, and other formerly growing sources of feed. This is a problem because once the growing grass is cut and processed into one of these “shelf stable” feeds, it no longer creates the desirable health benefits in the tissues of the animal that the customer is looking for. While most producers need to rely on dried and processed grasses to feed animals over the winter months, a true grass-fed animal will be FINISHED on green, growing grasses during the summer and fall, making it a seasonal product which is not available on demand at any time of the year.

Q. Does the standard assure consumers of “clean” meat, free of antibiotics, hormones, steroids, paraciticides, genetically engineered feeds, and grasses or hays used as feeds grown without chemical or synthetic fertilizers, herbicides, or other toxic substances?
A. No. In its “one size fits all” definition, any of these substances may be present in meats touting compliance with the USDA Grass-fed Standard. The definition attempts to cover any growing protocol, including conventional, natural, or organic production. Only certified organic grass-fed meats offer the consumer any assurance that these toxic substances are NOT present in the meat they buy.

PASTURE RAISING & FINISHING
Q. Does the standard’s “continuous access to pasture during the growing season” language assure consumers of species-appropriate growing protocols (i.e.: no feedlots)?
A. No. Many abuses have already been documented with the “access to pasture” language in the USDA’s organic standards which are verified by third party audits. Most assuredly, abuses will occur with this voluntary, non-audited claim.
Animals naturally seek food, water, and shelter. If food and water is easily accessible in a feedlot, even with a gate open to a green pasture (access to pasture), animals will tend to stay within the feedlot rather than leave a known source of food and expend energy grazing and seeking food on their own. This is especially true during winter months when it is NOT the growing season and “continuous access to pasture” is not even required. Under this definition, animals may be confined to feedlots and fed processed feeds and still be called “grass-fed”.

Q. Does the standard assure only grass-fed (no grains) meats which are labeled as such will enter the food system?
A. No. While the language states “Animals cannot be fed grain or grain by-products...”, it also states, “If supplementation occurs due to inadvertent exposure to non-forage feedstuffs or to ensure the animals well-being at all times during adverse environmental or physical conditions, the producer must fully document (e.g., receipts, ingredients and tear tags) the supplementation that occurs, including the amount, the frequency and the supplements provided." But there is no provision for how much grain would be allowable to retain a “grass-fed” classification, nor for removing such animals from the program. “Inadvertent exposure” and the rest of this language is hardly a loophole, but rather an open door to abuse which will allow feedlot, grain finished animals to be marketed as grass-fed.
Furthermore, a daily ration of small grains, particularly during the winter months is not the bad thing some folks are trying to make it out to be. In nature, ruminant animals need the seed heads of grasses to maintain them over the winter months after leafy forages have dried up and lost most of their nutritional value. For truly grass-fed ruminant animals the question is not “to grain, or not to grain”, but rather to implement limited graining at certain times of the year and finishing on green-growing grasses consumed while grazing on pastures.

ACCOUNTABILITY
Q. Surely a standard developed by the USDA will be audited, checked, and verified to assure consumers of farmer compliance with the standard?
A. No, not at present. The USDA definition of grass-fed is just that...a definition, to be used on a voluntary basis by those who wish to exercise this claim. At this writing, no third-party verification of claims or other monitoring or regulating procedure has been put into place. AMS states that verification of USDA Grass-fed claims will be accomplished upon request.

Despite the time and effort put into this definition by well-meaning advocates of grass-fed systems, this USDA “Standard” opens the door for abuse by opportunistic meat purveyors, and muddies the water for consumers seeking a particular type of product. Once again, the independent family grassfarmer who has for years been developing excellent grass-finished meats through selective breeding, intensive pasture rotation techniques, and often also adding the authenticity of organic certification, is left in the difficult position of having to debrief and reeducate consumers all over again as to the merit and value of truly grass-finished meats, as differentiated from something falling under the USDA’s broad, all-inclusive definition.

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Montana Organic Producers Co-op (MOPC) is a collaborative marketing cooperative for qualifying organic producers of agricultural products and particularly grassfed beef. MOPC is affiliated with a network of other organic farmer marketing cooperatives and OFARM (Organic Farmers' Agency for Relationship Marketing) to develop marketing opportunities for member producers. A key component of MOPC’s purpose is to speak for organic farmers' interests in legislative matters and with the NOP, and in other instances as warranted.
www.mopcoop.org

Organic Grassfed Beef Coalition (OGBC) is a team of producers, researchers, educators, and organic beef livestock specialists that bring together resources used in the production and marketing of organic grassfed cattle in the Northern Plains. The group collaborates with organic producers to promote on-farm research and education of grassfed beef livestock systems including the economic, human health, and environmental benefits.
www.organicgrassfedbeef.org