NoNAIS.org

This morning the USDA published the new Naturally Raised regulations, something we’ve discussed here before. Turns out they did listen to comments in some regards. In the original regulations it had banned feeding “animal by-products” but not made clear what that meant?

My guess was the concern was regarding the feeding of cows to cows, slaughter wastes, that is believed to have produced Mad Cow Disease a.k.a. BSE. The problem was that the way it was worded could ban the feeding of dairy and eggs to pigs which is a good practice and perfectly natural - pigs are omnivores. In fact, pigs and chickens both will eat meat in the wild making just about anything fair game for them.

If the definition of animal by-products had been made so limited it would have conflicted with the pre-existing Certified Naturally Grown program which is parallel to the USDA Certified Organic standards.

In the federal registry this morning I found the final ruling on Naturally Raised marketing claims by the United States Department of Agriculture (USDA). You can read the full text in the Federal Registry. The part relevant to the above discussion is quoted here:

The only diet requirement addressed in the proposed standard was that livestock have never been fed mammalian or avian by-products. Many commenters expressed support for this requirement; however, numerous commenters asked that the definition of animal by-products be clarified. Some commenters asserted that pigs were omnivores and that eggs and milk were commonly used in pigs’ diet and requested that the requirement of no mammalian and avian derived products be clarified to prohibit slaughter by- products but not food items such as eggs and milk in the porcine diet. Some commenters also suggested aquatic by- products be prohibited.

Agency Response: As stated previously, the only diet requirement addressed in the proposed standard was that livestock have never been fed mammalian or avian by-products. After reviewing the comments received suggesting the clarification of the definition of mammalian and avian by- products, AMS has determined to revise the standard to clarify the definition of animal by-product to specifically state what is prohibited. For the purpose of the Naturally Raised Marketing Claim standard, AMS will prohibit animal (mammalian, avian, and aquatic) by- products derived from the slaughter/ harvest processes including meat and fat, animal waste materials (e.g., manure and litter), and aquatic by-products (e.g., fishmeal and fish oil). This prohibition includes meat by-products as defined by FSIS in 9 CFR 301.2. Mammalian and avian products (e.g., milk and eggs) that are not derived from the slaughter/ harvest processes are allowed.
-Naturally Raised in Federal Registry

This is good news. Thank you AMS. I appreciate that the government regulators took our concerns into account and have made meaningful and reasonable changes and clarifications to the regulations they had proposed in late 2007.

Unfortunately the news is not all good. Big Ag with its Confinement Animal Feeding Operations (CAFOs) can get away with calling their production “Naturally Raised” if they simply make minor feed and medication changes:

All products labeled with a naturally raised marketing claim must incorporate information explicitly stating that animals have been raised in a manner that meets the following conditions:

• (1) No growth promotants were administered to the animals;
• (2) no antibiotics (other than ionophores used to prevent parasitism) were administered to the animal; and
• (3) no animal by-products were fed to the animals. If ionophores used only to prevent parasitism were administered to the animals, they may be labeled with the naturally raised marketing claims if that fact is explicitly noted.

-Naturally Raised in Federal Registry

A great many people, including myself, had left comment asking that management, humane handling and access to grazing should be included as part of the standard. An animal raised in confinement in a small pen or even “free-ranged” in a factory farm barn is certainly not naturally raised and should not get to use the term competing with animals that were truly raised naturally on pasture.

Unfortunately the USDA chose not to do this. Instead their rule will allow Tyson and other Big Ag factory farm producers to simply make small adjustments in their feeding to qualify for using the label “Naturally Raised” in their marketing. When a consumer thinks “Naturally Raised” they envision pastures, not steel bars, pens and confinement stalls.

Once again, just like with Organic, the big boys are stealing, dilluting and destroying the good that small producers have been using to differentiate themselves from the factory farm production model of agriculture.

AMS determined that it was not appropriate to expand the scope of this standard to incorporate the diverse range of suggested practices or attributes into the naturally raised standard. Furthermore, attempting to broaden the list of practices or attributes incorporated in a standard to be applied on a nationwide basis would be inherently difficult as practices vary from region to region and by producer. Due to the geographic diversity of the United States, livestock production practices vary considerably due to soils, climate, and availability of the production inputs and other necessities such as shelter, feedstuffs, and labor. AMS concluded that many of the production activities identified through the comment process would be more appropriately addressed as standards themselves or incorporated into other more encompassing standards or marketing programs that they would be more appropriately associated with.
-Naturally Raised in Federal Registry

One step back, one step forward, tango we must as we dance with the USDA regulators and Big Ag.