Farmer and Consumer Feedback to USDA Needed by August 10

Consumers and family-scale farmers and ranchers could be big winners if a proposed new USDA standard for grass-fed livestock wins approval. But for this to occur, the USDA must hear from consumers that they want simple changes made to the draft that clarifies the grass-fed definition. Without these changes, the rule is open to misinterpretation and could be used by some to confine their cattle in feedlot conditions while claiming a grass-fed approach.

Feedback from farmers and consumers is needed by August 10. The Cornucopia Institute can help you with your response.

Specifically, the proposed rule would permit the feeding of “immature grain” that might be attached to silage or other forage–this does not conform to what most agricultural experts consider “grass.” Possible differences in the interpretation of this broad term could result in the misapplication of an otherwise strong standard. Before moving forward with approval of this rule, USDA should revise the rule to prohibit the use of any mature corn or other traditional feed grains in feedstock used by producers seeking to market products under the grass fed label.

Consumers should also tell the USDA to immediately initiate a rulemaking, with public comment, for another new label, a free range or pasture-raised livestock label, with the aim of finalizing a standard by the end of the year. Because pasture-based grazing is a fundamental aspect of grass-fed meat production, it is crucial that use of both of these labels be made available to producers and consumers simultaneously. Some experts have interpreted the grass-fed labeling draft as potentially allowing the maintenance of animals in feedlot conditions.

The grass-fed proposal is specific, defining grass as “grass (annual and perennial), forbs (legumes, brassicas), browse, forage, or stockpiled forages, and post-harvest crop residue without separated grain.” The potential loophole comes from the stockpiled forages, which could include attached corn – this is what consumers need to let the USDA know is unacceptable. The proposal makes an allowance for mother’s milk fed to young animals prior to weaning. And minerals and vitamins are OK as part of the feeding regimen.

The new grass-fed label would apply to all ruminants, including cattle, goats, and sheep. The draft, with the above noted clarification of feed, would allow for usage of the label for animals receiving 99% of their energy from grass and forage.

Many organic consumers and others seek grass-fed meat because of its distinct health advantages. According to a recent report from the Union of Concerned Scientists, meat from animals raised entirely on pasture is not only leaner but contains higher levels of beneficial substances that may fight cancer and strengthen the immune system. “When you eat grass-fed meat, you’re getting beef with benefits,” notes Dr. Kate Clancy, a nutritionist and senior scientist at the Union of Concerned Scientists and author of Greener Pastures.

In particular, grass-fed meats contain higher levels of omega-3 fatty acids (also found in salmon and some other fish, as well as in flax and a few other seeds) and CLAs (conjugated linoleic acid). a beneficial class of omega-6 fatty acids. In animal studies, CLAs like those in grass-fed meat have been shown to protect against cancer.

The grass-fed approach has other pluses, as well. The animals live in conditions allowing them to exhibit their natural behavior, a circumstance that stands in marked contrast to the misery associated with penning thousands of animals into giant feedlots. Fed grains and standing in their own manure, the stressed feedlot animals are routinely administered antibiotics to fend off or treat diseases. Pastured animals can also improve soil quality. Their manure is spread about in amounts small enough to actually fertilize and not overwhelm the soil while protecting ground and surface waters.

“The USDA’s grass-fed initiative, with the suggested language changes, would represent a dramatic improvement over their previous proposal,” says Mark Kastel, Senior Farm Policy Analyst for The Cornucopia Institute, a farmer advocacy and agricultural watchdog group. In 2002, the agency proposed that ruminants receiving 80% of their energy from grass and forage could qualify for the grass-fed label. That draft was strongly condemned in public comments the USDA received from consumers, producer groups, nonprofit organizations, and academics.

Adds Kastel: “It’s important for the public to contact the USDA and let the agency know that grass-fed means grass-fed. The USDA needs to hear that consumers want livestock raised in conditions that promote the animal’s health, protect the environment, and produce meat products that contain the healthiest nutrients.”

Consumers may also want to let USDA know that when the grass-fed and free range/pasture-raised labels are finalized, they should then begin developing additional labels. For example, the grass-fed label will not necessarily mean that antibiotics and/or hormones were not used in the animal’s rearing. Consumers should let USDA know that rules need to be developed for no anti-biotics and no hormones, as well.

Public comments will be accepted by the USDA on or before August 10. You can find a sample letter by clicking here. Copy and paste the text into your own message and modify it as you need to reflect your personal remarks.

They can be emailed to [email protected]. Comments should refer to Docket No. LS-05-09. Written comments can be submitted to Martin E. O’Connor, Chief, Standardization Branch, Livestock and Seed Program, AMS, USDA, Room 2607-S, 1400 Independence Avenue, SW., Washington, DC 20250-0254. Or a FAX can be sent to (202) 720-1112. Background on the proposed grass-fed label regulations can be viewed at

Although heartened by the potential USDA turnaround on the grass-fed issue, Kastel remains puzzled and disappointed at the agency’s reluctance to apply a similar approach to the role of pasture in organic dairying. “Many of the same nutritional, environmental, and animal husbandry benefits are captured by pasturing organic dairy animals,” explains Kastel. But the USDA has let factory farms that primarily confine their milking herds in feedlots or small sheds gain a significant and growing slice of the organic dairy market. “Cooperatives and their consumer members need to continue pressuring the USDA for a strong (organic) pasture rule that will protect family farmers and produce dairy products that match consumer values and expectations,” Kastel said.

To help consumers and dairy product buyers identify the dairy products produced with the highest organic integrity, The Cornucopia Institute has released a scorecard and report that rates the nation’s organic dairy products. It can also be viewed on our Web page at

– Will Fantle

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