I'm a product of the post-Watergate era, which I guess is to say pragmatic verging on cynical. Maybe that's why I believe the U.S. government serves its citizenry best by making and enforcing laws, not morals. There are people who prefer it handle both, but I'd rather not have to eat dinner with them.
So, given that the USDA's new standards for the label "grass-fed" seem laudably straightforward and sensible to me — just an informed eater, not a farmer and certainly no expert — I was surprised to find that small farmers I admire, along with the American Grassfed Association, think they are a travesty. Why? Because they aren't far-reaching or restrictive enough to prevent Big (Bad) Beef from exploiting the label's implied seal of approval by changing only its diet, not its animal-husbandry practices. The other line of criticism: that the certification process will be too onerous and expensive and thus will end up forcing small farmers — the ones who really do things right — out of this newish-yet-wildly-popular niche that they "steaked out" first.
Essentially, both arguments converge on the idea that it's organic all over again.
As most Ethicurean readers know, the set of practices we now label "organic" was once a loose philosophy of holistic agroecology. Some would say that the USDA's Certified Organic label has reduced this philosophy to just a lucrative marketing strategy for corporate mega-farms, who may be adhering to the letter of the National Organic Standards but certainly aren't following their spirit, at least as practiced by the movement's original farmers. When Certified Organic can refer to vast swathes of monocultural crops grown with no thought to the soil's diminishing fertility, or to cattle fed an unnatural diet of (certified organic) corn, is that really organic? Well, no. But is it better than conventional agriculture, with its floods of toxic chemicals and untested modified genes, or synthetic hormones and routine use of antibiotics to promote growth and help animals tolerate unsanitary, overcrowded conditions? The answer seems obvious.
To me, truly sustainable food is grown in a manner that not only doesn't harm but actually nourishes the soil, animals, workers, and community that produce it. I see it as a spectrum, a personal value system for food, from red (rather go hungry) to green (willing to pay a premium in cost and inconvenience to support). It might be shaded differently from person to person.
And don't get me wrong: I may live in Berkeley, and run this preachy blog, but I can't and don't always make the ideal choice. I would just like to see more Americans actually exercise decision-making power other than "Valu-Meal #2" versus "Valu-Meal #3" (with milkshake). But I digress.
Certified Organic, as you can see, occupies the colorless neutral ground on my spectrum. That's because I don't think it tells you much unless you get to know the farms behind the label. They could be just filing all the forms properly, yet not paying their workers a living wage (the organic label has animal-welfare standards, but not human ones), confining their dairy cows, or abusing the natural pesticides that are allowed. I see certified "grass fed" beef similarly.
And really, that's probably the best that government can do for us in this situation: Codify the middle territory between the devils and the saints. Most people just want the shortcut to chewing the right thing: "Five Tips For Buying Organic on a Budget!" (I lost those people at my second long paragraph.) Government labels provide that. Laws can never cover all the angles, and they certainly leave many loopholes for devious minds to exploit — look at our corporate tax law. That doesn't mean they're not useful.
The USDA's language is remarkably specific, I thought. It is clear that the intent is for the label to be applied to ruminants who eat grass they forage for themselves on pasture:
Grass (Forage) Fed--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 byproducts 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 as acceptable feed sources. 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.
I urge you to read the full text of the USDA's Agricultural Marketing Service (AMS) document online, in which the agency thoroughly reviews all the areas on which commenters focused, and why it decided to incorporate their criticisms (or not). It's a lot less boring than you might think.
• The grass fed label claim can continue to be used by anyone in the marketplace since participation in this AMS verification process is voluntary. If I read the AMS langauage correctly, this is not so, although it has yet to be determined how that will work. The AMS only sets the standards; now it is up to the USDA's Food Safety and Inspection Service, which handles actual food labeling, to sort out how it will limit and/or enforce it.
• The unrestricted supplementation of energy is allowed, as long as the feedings are recorded. This standard does not set any restriction on amount, frequency or type of non-forage feedstuffs. Seems pretty clear to me that this is a clause for emergencies, so that say, in the case of drought, hungry animals can be fed with what is available until a supply of grass (forage) can be found. Maybe I'm naive, but anyone who treats this as a loophole would likely get spanked.
• Long-term confinement practices are allowed under this standard since "access" to pasture and frost dates are easily manipulated. Notice that the USDA language above says "continuous" access to pasture, which is different from the vague "access to the outdoors" in the organic standards. Again, could Big Bad Beef cheat on its frost dates? Sure. It could also confine thousands of cows year-round in a huge barn with one door open to the pasture as long as they can withstand a simple electric shock going through it. Now that should make for good-tasting "grass-fed" beef.
• The use of artificial hormones is allowed under this standard. The use of therapeutic and sub-therapeutic antibiotics is allowed under this standard. This is a biggie. They argue that consumers expect "grass fed" meat producers to eschew these industrial methods. While I would be very surprised to learn that any current grass-fed producers were relying on steroids and routine antibiotics, I don't think the label should specifically forbid them. (I do wish that meat labeled "natural" actually meant raised according to nature, which it doesn't at all, something that even consumers and chefs who should know better, don't). As the AMS points out, "Additional labeling claims can be made in conjunction with the grass (forage) fed claim (e.g., free-range, no antibiotics or hormones administered) to highlight other production practices." There's nothing to stop producers from filing the paperwork to have that claim verified, too.
• Artificial milk replacers are allowed under this standard, including milk replacers made from bovine blood meal. The standard's language actually just says "milk"; it's the background section that explains the standard refers to animals "whose diet, throughout their lifespan, with the exception of milk (or milk replacer) consumed prior to weaning, is solely derived from forage." Again, seems to me that that parenthetical was inserted as an emergency measure, not as an equally acceptable alternative designed to let Big Bad Beef routinely separate calves from cows and raise them on crap until they can eat grass from the trough in their feedlot.
To me, the most powerful argument against the label is actually about having a label at all. It comes from
Massachusetts Vermont hog farmer Walter Jeffries, a frequent commenter on this blog and sometime subject. I hope I'm not going to lose him with this post. On Walter's other blog, NoNais.org (about stopping the National Animal Identification System), he writes:
Voluntary will become mandatory. Soon you will not be able to use the term grass fed unless you signup with the USDA and pay them their bribe price. The fees will be set high enough to exclude the vast majority of small farmers who are already practicing pastured grass fed raising of livestock.
It's true that the FSIS will likely decide to restrict the use of the term "grass-fed" on labels to those farmers who have submitted the "Process Verified" paperwork. It's true that it is going to be a headache for farmers to document their pasture time and feed makeups, and that having to pay fees to get a label saying you did the same right thing you've been doing all along seems grossly unfair. But just as small farmers who sell directly to consumers — via farmers markets or CSAs or whole-animal shares — are increasingly opting out of the Certified Organic labeling program, citing the expense and the hassle, I suspect small beef and bison producers will forego the eventual "Certified Grass Fed" label. They don't need it: their customers know and trust them. When someone like Walter (who doesn't raise cattle) says "Our cows are on pasture except for November through January, when we feed them stored, fermented grasses called sileage," he or she will be believed.
I stand by my initial assessment that the new grass-fed label is a positive step forward, toward re-mainstreaming age-old practices that somehow got so sidelined they have to be resurrected with linguistic makeover. Just remember, it's only a label — not a halo.