Photos are of Clark Summit Farm in Tomales, CA; see note at end.
Exciting announcement for Ethicurean readers: After almost five years of deliberation and two rounds of public comments, the USDA’s Agricultural Marketing Service (AMS) has finally issued standards for "grass (forage) fed" marketing claims — ones that actually mean what most consumers think they should mean, and aren’t chock full of industry-pandering loopholes as we feared they would be.
The short version of the standards state that:
grass and/or 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 and animals cannot be fed grain or grain by-products and must have continuous access to pasture during the growing season.
Bye-bye, so-called "grass-fed" beef from animals that spend the last three (or more) months of their lives in a feedlot being stuffed with corn, barley, and other grains so they can have the kind of Omega-6-heavy, intramuscular fat that most Americans are used to. That means well-known grain-finishing producers like Niman Ranch and Panorama Grassfed Meats (the brand sold by Whole Foods as "grass fed"; see my interview with CEO) will have to revise their practices if they want to continue calling their beef "grass fed." (Update: Mack Graves, CEO of Panorama, has left a comment clarifying that Panorama does indeed follow the new definition to the letter. I have asked a couple of follow-up questions.) By the way, I’m not bashing either of these producers, who can be commended for eschewing growth hormones and supplemental antibiotics, and practicing humane husbandry and pretty sustainable agriculture: I’m just saying that calling their beef "grass fed" has long been misleading for consumers.
Kudos to the USDA for making it easier, not harder, for Ethicureans to chew the right thing.
All cattle eat grass – for some of their lives, anyway
Short(ish) background for those who don’t know anything about raising cows — a group that, up until a few years ago, would have included me: All bovines (the blanket term that includes bulls, cows, heifers, etc) grow up eating grass. That’s the foodstuff that their stomachs were designed to handle, thanks to a miracle compartment called the rumen, which produces enzymes that can break down cellulose — something no other mammals can live on. After World War II, when grain production in this country took off, it was found that feeding corn and soy to ruminants made them gain weight a whole lot faster — "about three pounds a day versus a pound a day on grass," according to Niman Ranch founder Bill Niman, writing in "The Niman Ranch Cookbook." Basically, it’s about stuffing them full of carbohydrates instead of their natural diet of fiber. Meanwhile, sticking thousands of them in a small feedlot is a whole lot easier for humans than herding and rotating them among acres of pasture, and confining them means they don’t burn calories, so they gain weight even faster.
Such grain feeding is great for the ranchers’ economics — and the basis for fast food and other cheap meat in this country — but detrimental to the cattle, the environment (lakes’ worth of antibiotic-laced manure), and the people who eat such beef. Diets high in corn and soy give cows severe indigestion, and can in fact kill them. Which is why you can’t just take a calf and start feeding it grain, you have to wait until its stomach has somewhat matured and its digestive tract has hardened — and combine it with regular does of antibiotics, which not only help with acidosis but help the cattle’s immune systems tolerate feedlot conditions. Too bad they also breed antibiotic-resistant strains of E. coli.
Conventional — or more accurately, "industrial" or "factory" — beef producers can take a calf at about six months of age and through a combination of growth hormones, grain, and antibiotics, turn out a 1,200-pound steer in 12 months. (For more details, read Michael Pollan’s "Power Steer" feature for the New York Times.) Grain-finishers like Niman Ranch wait until the cattle are at least a year old and feed them a less-grain-heavy ration for a few months. By contrast, 100% grass-fed animals can take two years or more to reach market weight, which means a lot less turnover (and profit) for producers. They’re also much more labor-intensive, as producers can’t just turn them out in to a big field and ignore them, they have to make sure that what their foraging is nourishing enough to make them gain weight, which means planting a variety of grasses and legumes and rotating the cattle to fresh pasture regularly. So think about that next time you wonder why grass-fed meat is more expensive. You’re paying for someone to do things the old-fashioned, hard way.
The origins of the grass-fed label standards
The following is a summary, with my comments, of the 13-page PDF the AMS sent out to interested copies. (The Center for Rural Affairs was kind enough to forward their copy; I’ve posted it here.) The AMS is the arm of the USDA that works with industry representatives and others to establish U.S. standards for agricultural products, in order to provide "a common language for trade and a means of measuring value" in their marketing. It’s basically so that niche producers can distinguish their meat and, for example, justify charging a premium.
In December 2002, the AMS proposed a grass (forage) fed standard saying that "grass, green or range pasture shall be 80 percent [emphasis mine] or more of the primary energy source throughout the animal’s life cycle." there was an uproar, because as previously explained, that mean that just about any beef could be labeled grass-fed if the animal were slaughtered young enough (ie, at 15 months after three months in a grain feedlot). As a result of the public comments received, AMS determined significant modification was needed and re-proposed the standard in May 2006. The new, stricter standard up for discussion was whether "grass (annual and perennial), forbs (legumes, Brassica), browse, forage, or stockpiled forages, ad post-harvest crop residue without separated grain shall be at least 99 percent of the energy source for the lifetime of the ruminant specie, with the exception of milk consumed prior to weaning."
The AMS reports that in response to the proposed standard, it received a staggering 19,811 comments — from consumers like us, academia, trade and professional associations, nonprofits, national organic associations, consumer advocacy groups, retail and meat product companies, and livestock producers. Of those thousands of statements, the AMS says, the majority supported that the animal’s diet must be 99 percent or higher grass or forage-based." It appears that beef producers were the ones arguing for a less-stringent percentage on the basis that "75 percent of beef producers in the United States work with environments with periods of zero plant growth, and only the highest quality stored forages will result in weight gains approaching 1.0 kg/day." To their credit, these producers were asking only for a 90-97.5 percent level, not the meaningless 80 percent level.
Quite a few commenters were also apparently concerned about whether the phrase "energy source" could allow for loopholes like feeding cattle supplemented material "such as urea-treated hay." They wanted the standard to say "energy/feed source," to cover anything that the animals are fed. The AMS has agreed, and says that the "standard is based solely on the consumption of a grass(forage)-based diet. Removing the ‘energy source’ terminology will further clarify that supplemental energy and protein sources are not permitted."
There is one statement about emergency feed sources that could be perceived as a loophole, should anyone be dumb enough to exploit it and risk consumer backlash (hello, Aurora Organic Dairy?). It is this: "AMS realizes that incidental supplementation may occur 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." I can imagine cases where this would occur, when, say, pastures have burned and purchase sileage has not yet arrived, or cows are found to have wandered into a neighbor’s grain pile and stood there snacking for several days. The AMS goes on to state that if such "incidental supplementation" occurs, the producer has to document — with "receipts, ingredients, and tear tags" — exactly what was fed to the animal, including how much and how often.
The Center for Rural Affairs, for one, isn’t concerned about the emergency loophole. "It might be helpful if they would provide greater definition, and we will see if we can get that out of anyone there," Traci Bruckner, Assistant Director of the Rural Policy Program at the Center for Rural Affairs, told me in an email. The standard is "so much better than what we had, and we do believe this is there to provide for those extreme situations."
Some other noteworthy points the AMS mentions in the PDF:
On grain-finishing: The AMS language is very clear on this one. "AMS did not intend for the standard to permit meat from grain-fed animals to be labeled as grass (forage) fed." Cows labeled "grass fed" may graze crops normally harvested for grain only if they do so in the "vegetative state (pre-grain).
On sileage (stored forage, which can include fermented vegetative products such as some grains on the stalks): The AMS said it got lots of comments about prohibiting the feeding of any sort of stored grass, such as is commonly done in the winters in inclement states and in the dry summers in California, for example. These people said that "grass fed" animals should be raised solely on living green grass, and harvested hay and almond hulls etc shouldn’t cut it. In response, the agency has ruled that "Due to the diverse range and climate conditions across the United States, it is not practical to limit consumption to grass (forage) consumed by the animal only while pasturing and to restrict the use of harvested, stockpiled or stored forage.Accordingly, harvested forage without grain is allowed." It goes on to state that it recognizes that fermented sileage is not as "green," but that is outside the scope of the standard.
Pasture versus feedlot: Many commenters wanted the standards explicitly to include a pasture component, to distinguish such meat from conventional feeding practices, ie, you can’t just start take a crowded feedlot of 1,000 animals and start throwing grass clippings in their troughs. Others stated that the label should specifically exclude the use of supplemental hormones and nontherapeutic antibiotics. The AMS disagreed on this one, saying additional claims such as "pasture raised" or "free range" and "hormone and antibiotic-free" can be made separately from the grass-fed label.
Penalties for using the label without USDA verification, protocol transition periods, and foreign producers: The AMS pointed out that the truthfulness and accuracy of food label claims is handled by the USDA’s Food Safety and Inspection Service (FSIS) arm. It’s FSIS, not the AMS, who will have to sort out who’s allowed to continue using the term "grass fed" while they transition their cattle to the new protocols, and whether or not a company can just stick "Grass Fed" as part of their brand name rather than as the USDA-certified label claim to get around the new rules. Companies are already prohibited by U.S. law from using USDA process-verified language on labels without actually getting the process verified. And in answer to the Argentinean grass-fed beef producer who complained its products were being discriminated against, the AMS said that a voluntary program to substantiate label claims could be developed.
Health claims (Omega-3 fats, etc): Some commenters wanted to be able to make associated health claims about the benefits of meat from grass-fed animals versus grain-fed. The AMS said "it is up to the individual consumer to determine their reason for eating meat from animals fed grass forage)."
We couldn’t agree more, and we’re grateful to the USDA for making it easier for us to seek out truly grass-fed meat more easily, so we can support practices that are better for the animals, our bodies, and the environment as a whole.
Regarding images: Clark Summit Farm raises grass-fed beef (including Scottish Highland cattle), pastured pork, and free-range chickens. Please do not reproduce images unless referencing (and linking to) this post.