[Announce] Call for opposition to proposed USDA rule

[Robert Waldrop]

Below is a call for opposition to a proposed USDA rule that I am circulating to my food security groups.  It should also be of interest to those concerned about Catholic social justice, as it is "one more attack" on the viability of sustainable, local food systems.  Please take some time to make comments as indicated below, and also to pray to Saints Joseph, Isidore, and Maria to intercede for the defeat or substantial amendment of the proposal.

Bob Waldrop, Romero House, Oklahoma City

CALL FOR COMMENTS ON PROPOSED USDA RULE

Below is a proposed USDA rule that would set voluntary standards for the use of the "natural" market claim by livestock producers.  

Comments are being accepted, but the deadline is JANUARY 28th (not far from now, so do not procrastinate). 

Comments should be submitted through the government's comment Web site at http://www.regulations.gov. Or, you may mail written comments to: Naturally Raised Marketing Claim, Room 2607-S, AMS, USDA, 1400 Independence Avenue SW., Washington, DC 20250-0254, or fax to (202) 720-1112. 

All comments should reference the docket number, which is Docket No. AMS-LS-07-0131; LS-07-16. 

Comments received will be  posted on the Web site at http://www.regulations.gov and will be made  available for public inspection at the above physical address during  regular business hours.

Unfortunately, this rule only addresses use of routine antibiotics, growth hormones/supplements in feeds, and animal or poultry byproducts in feeds.  It says nothing about a requirement for free ranging flocks and herds. 

At the Oklahoma Food Cooperative, our definition of "natural" also includes the requirement that the flocks and herds be free-ranging.  No confined animal feeding operation meat or poultry can be sold through the coop.  But under the USDA's proposed "voluntary rule", CAFO products COULD legally carry the "natural" label.  

The most charitable thing that I can think of to say about this rule is, "ABOMINATION!"  It makes me want to put on my John the Baptist hat, wear sack cloth and ashes, munch a few locusts smeared with honey and go cry repentance at the USDA.  Talk about the dreaded "Grumpy Bob Syndrome".

More rationally, the proposed rule:

+ Will be confusing to the buying public.

+ It will certainly dilute if not outright destroy the value of our "all natural" product description as used at the Oklahoma Food Coop and many other similar food distribution systems nationwide.

+ The rule is deceptive because it implies that a meat or poultry product raised in a confined animal feeding operation, which is a totally UNnatural method of livestock/poultry production, is somehow "natural".

Thus, I strongly encourage everyone -- producers and consumers -- to send in comments opposing this proposal.  There will probably be a resolution on the agenda of our annual meeting to officially express our opposition.

Please pass this news on to others who pay be interested.  Once more into the breech, Oklahoma Food Cooperators, in defense of our common natural right to grow, distribute, purchase, and consume food produced in accordance with natural and sustainable practices!

Bob Waldrop, president and general manager
Oklahoma Food Cooperative

http://edocket.access.gpo.gov/2007/E7-23103.htm

[Federal Register: November 28, 2007 (Volume 72, Number 228)]
[Notices]               
[Page 67266-67268]
>From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr28no07-20]                         

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DEPARTMENT OF AGRICULTURE

Agricultural Marketing Service

[Docket No. AMS-LS-07-0131; LS-07-16]

 
United States Standards for Livestock and Meat Marketing Claims, 
Naturally Raised Claim for Livestock and the Meat and Meat Products 
Derived From Such Livestock

AGENCY: Agricultural Marketing Service, USDA.

ACTION: Notice and Request for Comments.

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SUMMARY: The Agricultural Marketing Service (AMS) is seeking comments 
on a proposed voluntary standard for a naturally raised marketing 
claim. A number of livestock producers make claims associated with 
production practices in order to distinguish their products in the 
marketplace. There are a growing number of entities that wish to 
capture value added opportunities via alternative production methods to 
meet the demands of consumers seeking meat and meat products from 
naturally raised livestock. The livestock and meat supply chain along 
with consumers could benefit from a uniform standard for the marketing 
of this type of product. The standard for a naturally raised marketing 
claim, if adopted, will be part of the voluntary U.S. Standards for 
Livestock and Meat Marketing Claims. If this voluntary standard is 
established, livestock producers participating in this program would 
have their naturally raised claim verified through the Department of 
Agriculture (USDA). Verification of any claim would be accomplished 
through an audit of the production process in accordance with 
procedures that are contained in Part 62 of Title 7 of the Code of 
Federal Regulations (7 CFR part 62). Meat and meat products sold from 
approved programs can carry a claim verified by USDA.

DATES: Comments must be received on or before January 28, 2008 to be 
assured of consideration.

ADDRESSES: Interested persons are invited to submit written comments 
concerning this proposal. Comments should be submitted through the Web 
site at http://www.regulations.gov. Send written comments to: Naturally 
Raised Marketing Claim, Room 2607-S, AMS, USDA, 1400 Independence 
Avenue,

[[Page 67267]]

SW., Washington, DC 20250-0254, or by facsimile to (202) 720-1112. All 
comments should reference the docket number. Comments received will be 
posted on the Web site at http://www.regulations.gov and will be made 
available for public inspection at the above physical address during 
regular business hours.

FOR FURTHER INFORMATION CONTACT: Martin E. O'Connor, Chief, Standards, 
Analysis, and Technology Branch, Livestock and Seed Program, AMS, USDA, 
Room 2607-S, 1400 Independence Avenue, SW., Washington, DC 20250-0254; 
facsimile: (202) 720-1112; telephone: (202) 720-4486; or e-mail: 
Martin.OConnor at usda.gov. Additional information can also be found by 
accessing the Web site at http://www.ams.usda.gov/lsg/stand/
naturalclaim.htm.

SUPPLEMENTARY INFORMATION: Section 203(c) of the Agricultural Marketing 
Act of 1946, as amended (7 U.S.C. 1622), directs and authorizes the 
Secretary of Agriculture ``to develop and improve standards of quality, 
condition, quantity, grade, and packaging, and recommend and 
demonstrate such standards in order to encourage uniformity and 
consistency in commercial practices.'' USDA is committed to carrying 
out this authority in a manner that facilitates the marketing of 
agricultural products. One way of achieving this objective is through 
the development and maintenance of voluntary standards by AMS.
    AMS is seeking comments on a proposed voluntary U.S. Standard for 
Livestock and Meat Marketing Claims, Naturally Raised Claim for 
Livestock and the Meat and Meat Products Derived from such Livestock, 
in accordance with procedures that are contained in Part 36 of Title 7 
of the Code of Federal Regulations (7 CFR part 36).

Paperwork Reduction Act

    In accordance with the Paperwork Reduction Act of 1995 (PRA; 44 
U.S.C. 3501, et seq.), the information collection and recordkeeping 
requirements for the services associated with a proposed naturally 
raised marketing claim is approved under Office of Management and 
Budget Control No. 0581-0124.

Background

    Individuals and companies often highlight production and marketing 
practices in advertisements and promotions to distinguish their 
products in the marketplace. Since the late 1970s, livestock and meat 
producers (individuals and companies) have requested the voluntary 
services of AMS to verify or certify specific practices to increase the 
value of their products. The Livestock and Seed (LS) Program of AMS has 
provided certification through direct product examination for a number 
of production claims related to livestock and carcass characteristics. 
The validity of such claims is enhanced since the product is labeled as 
``USDA Certified.'' The LS Program also offers verification services 
through Quality System Verification Programs (QSVP; http://
www.ams.usda.gov/lsg/arc/audit.htm) to substantiate claims that cannot 
be determined by direct examination of livestock, their carcasses, 
component parts, or the finished product. The QSVP provides suppliers 
of agricultural products or services the opportunity to distinguish 
specific activities involved in the production and processing of their 
agricultural products and to assure customers of their ability to 
provide consistent quality products or services. This is accomplished 
by documenting the quality management system and having the 
manufacturing or service delivery processes verified through 
independent, third-party audits. One specific QSVP is the USDA Process 
Verified Program, which allows suppliers to make marketing claims--such 
as feeding practices or other raising and processing claims--and label 
and market their products as ``USDA Process Verified.''
    As multiple marketers of specialized claims have begun to seek USDA 
certification or verification for the same or similar production 
practices, AMS has determined it would be beneficial to establish 
standards for common production and marketing claims that would 
collectively be a part of the voluntary U.S. Standards for Livestock 
and Meat Marketing Claims, which may be used in conjunction with a 
certified or verified program recognized by AMS. The livestock and meat 
marketing claim standards are instrumental in facilitating 
communication, establishing a common trade language, and enhancing 
understanding among producers, processors, and consumers. Past 
experience indicates that standards sort a highly diverse population 
into more homogeneous groups, and when standards are uniformly applied, 
they provide a valuable marketing tool. AMS develops and proposes 
standards for marketing and production claims based on experience with 
USDA Certified Programs and USDA QSVP, research into standard practices 
and procedures, and requests from the livestock and meat industries.
    Naturally raised is an animal production method known in the 
industry. AMS is proposing that animals that have been naturally raised 
have been raised without growth promotants and antibiotics and have 
never been fed mammalian or avian by-products. Accordingly, AMS is 
seeking comments on a proposed voluntary naturally raised marketing 
claim standard. AMS has obtained input from a number of individual 
experts in government, industry, and academia while drafting the 
proposed standard and has conducted public listening sessions.
    If adopted, product labels that include the voluntary naturally 
raised marketing claim must be submitted to the USDA's Food Safety and 
Inspection Service (FSIS), Labeling Program and Delivery Division 
(LPDD), for evaluation prior to use. FSIS, LPDD, under the authority of 
the Federal Meat Inspection Act (FMIA; 21 U.S.C. 601, 607) and the 
Poultry Products Inspection Act (PPIA; 21 U.S.C. 451, 457), regulates 
domestic and imported meat, poultry, and egg product labeling, 
standards, and ingredients. AMS has worked closely with FSIS, LPDD to 
develop and propose the voluntary naturally raised marketing claim 
standard. All products using the naturally raised marketing claim 
standard would have to be accompanied by a brief statement explaining 
the claim and attributes. The proposed standard for a naturally raised 
marketing claim, if adopted, would be part of the voluntary U.S. 
Standards for Livestock and Meat Marketing Claims which may be used in 
conjunction with a USDA QSVP, and naturally raised marketing claims may 
be verified, as provided in 7 CFR Part 62. However, since this would be 
a voluntary marketing claim, if adopted, FSIS would not establish a new 
provision limiting the use of the term naturally raised to labels in 
which participants meet this standard with a USDA QSVP. Any specific 
labeling issues or questions not related to AMS services would be 
directed to the FSIS, LPDD.
    According to FreshLook Marketing Group retail data, the demand for 
natural and organic products has surged to double-digit growth in 
recent years (for more information on the National Organic Program 
visit http://www.ams.usda.gov/nop/indexIE.htm). To meet the growing 
consumer demand, U.S. meat and poultry companies have developed and 
marketed ``natural'' meat and meat products. An AMS naturally raised 
marketing claim standard, if adopted, would remain independent of the 
FSIS use of the term ``natural'' and

[[Page 67268]]

would separate claims about livestock production practices on product 
labeling.
    The majority of claims currently citing naturally raised animal 
production methods are defined by the individual company selling the 
product. Depending upon the branded program making the claims, the 
production activities and associated requirements can vary since there 
is currently no standard to specify which attributes must be addressed 
and to what level, other than to be truthful and not misleading. This 
has led to confusion in the industry and the marketplace as to what 
requirements must be met in order to have a uniform, explicit claim 
that can be easily understood. This confusion has caused AMS to develop 
and propose a standard with explicit attributes that could easily be 
understood by the public as the basis for a naturally raised marketing 
claim as it relates to live animal production practices. AMS seeks 
comment from the public concerning its development and requirements.

Proposed Standard

    To develop and propose a marketing claim standard for naturally 
raised, AMS conducted three listening sessions in December 2006 and 
January 2007 in Washington, DC, Denver, CO, and Seattle, WA, to seek 
oral and written comments regarding the use of a naturally raised 
marketing claim standard. Public input and comments related to a 
naturally raised marketing claim are posted on the Web site at http://
www.ams.usda.gov/lsg/stand/naturalclaim.htm. AMS evaluated the public 
input and comments and is seeking further comments on a proposed 
naturally raised marketing claim standard.
    AMS also reviewed consumer research along with the comments and 
identified, based upon this information, that production practices such 
as the prohibited use of antibiotics, growth promotants, and certain 
animal by-products are the main attributes consumers want for meat and 
meat products derived from livestock that are naturally raised. These 
are the attributes that AMS' proposed naturally raised standard 
contains. Again, the naturally raised labeling claim proposed in this 
notice remains independent of the FSIS policy on the use of the term 
``natural'' on product labeling and will only pertain to live animal 
production practices.
    Accordingly, AMS seeks comments on the following proposed voluntary 
U.S. Standard for Livestock and Meat Marketing Claims, in this notice.

Proposed U.S. Standards for Livestock and Meat Marketing Claims, 
Naturally Raised Claim for Livestock and the Meat and Meat Products 
Derived From Such Livestock

    Background: This proposed claim applies to livestock used for meat 
and meat products that were raised entirely without growth promotants, 
antibiotics, and mammalian or avian by-products.
    The administration of growth hormones, including natural hormones, 
synthetic hormones, estrus suppressants, beta agonists, or other 
synthetic growth promotants is prohibited from birth to slaughter. 
Collectively, they are referred to in the naturally raised marketing 
claim standard as growth promotants.
    No antibiotics can be administered, whether through feed or water, 
or by injection, from birth to slaughter. This includes low-level (sub-
therapeutic) or therapeutic level doses, sulfonamides, ionophores, 
coccidiostats, or any other synthetic antimicrobial. If an animal is in 
need of medical attention, proper treatment should, of course, be 
administered in an attempt to improve the health of the animal. In the 
case where antibiotics or the stated prohibited substances are 
administered, the treated animal must be identified and excluded from 
the program. Health products that can be used for disease prevention in 
a naturally raised program are vaccines, parasite control products, 
antibody preparations, and bloat prevention and treatment products 
(e.g., feed grade microbials and buffers that help facilitate the 
animals digestive process).
    The feeding of mammalian or avian by-products is prohibited. 
Livestock cannot be fed rations that include components that are 
mammalian or avian derived.
    Vitamin and mineral supplementation is permissible.
    Verification of the proposed claim will be accomplished through an 
audit of the production process. The producer must be able to verify 
for AMS that the naturally raised marketing claim standard requirements 
are being met through a detailed documented quality management system.

Claim and Standard

    Naturally Raised--Livestock used for the production of meat and 
meat products have been raised entirely without growth promotants, 
antibiotics, and have never been fed mammalian or avian by-products. 
This information shall be contained on any label claim that an animal 
has been naturally raised.

    Authority: 7 U.S.C. 1621-1627.

    Dated: November 21, 2007.
Lloyd C. Day,
Administrator, Agricultural Marketing Service.
[FR Doc. E7-23103 Filed 11-27-07; 8:45 am]

BILLING CODE 3410-02-P
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