Executive Summary

Report

Feedlot Dust
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Koch
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Pilgrims Pride
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Smith Farms
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Sustainable Livestock
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Antibiotic Resistance
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Vertical Integration
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Natural Meat
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Organic Meat
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Recommendations  

Consumers today cannot readily discern from the label if fresh cuts of beef, chicken or pork come from a farm that uses sustainable growing methods. Although the FDA recently began to allow meat producers to seek certification as "organic" from a number of certifying agencies, Consumers Union SWRO found that "organic"-labeled meat is rarely available on the grocery store shelves (See sidebar). Instead, many producers who have rejected or moved away from industrial meat practices label their meat "natural," a term that has little or no real meaning. In order to create and support a viable market for meat produced in a sustainable manner, Texas needs significant labeling reforms, as well as the expansion of alternative markets where producers can sell directly to consumers.

With concerns about the environment and the sustainability of our food system, more consumers are demanding organically produced vegetables and meat. Over the past 2 decades, total retail organic food sales have risen from $178 million in 1980 to $6 billion in 1999. (1) In 1990, Congress passed the Organic Foods Production Act (OFPA), which established a National Organic Standards Board to address issues related to crop and livestock standards, labeling and packaging, certifier accreditation and international issues. After lengthy consideration, the Board made recommendations to the USDA in 1996. When the USDA published a substantially weaker national organic standards rule in December 1997, over 275,000 comments, largely critical, were submitted and USDA postponed finalizing the rule. (2) USDA did not act again until March 2000 when it announced its revised proposal for national organic standards. (3) Unlike the 1997 version, the new proposal more closely follows the recommendations of the National Organic Standards Board, including prohibiting antibiotic use, requiring 100% organic feed, and providing for more spacious and sustainable rearing conditions (i.e. no continual confinement). (4) However, until the federal organic rule is formally adopted, meat production continues to be regulated, if at all, by state law or voluntarily through organic certification agencies.

Currently, 33 private and 11 state certifying entities, including Texas' Department of Agriculture (TDA), provide organic certification for grain and produce. (5) Texas law requires that organic producers obtain certification through the state or a private certifying entity. (6) Currently, two private organic certifiers are accredited in Texas (7) and they may certify Texas organic producers as long as their certification standards meet, at a minimum, the TDA standards. (8) Therefore Texas consumers can be reasonably assured that when they buy "organic"-labeled grain and produce, they are getting a "certified organic" product.

However, the certification and marketing of organic animal products (meat, poultry, eggs, dairy, etc.) is not as well-defined. Without any state or federal organic livestock rules in place, animal products have not been allowed to use the word "organic" in their label. This has impeded the marketing of alternatively-produced meat and dairy products to conscientious consumers, many of whom are willing to pay a price premium for "organic"-labeled food.

In the face of this restriction, a complicated and confusing alternative-the "natural" meat label-has come into use. Unfortunately for consumers, the term "natural" is so loosely defined by USDA that virtually all fresh cuts of meat and poultry qualify as "natural." Specifically, the Food Safety and Inspection Service (FSIS) of the USDA defines a "natural" meat product as one that "contains no artificial ingredients" and is "not more than minimally processed." (9) This would apply to most fresh meat and eggs, whether they have been produced conventionally, organically, or through sustainable practices. In fact, "natural" meat producers may regularly use antibiotics and hormones for all aspects of production yet still legally market their meat as "natural" under this definition. As a result, producers who adhere to a variety of alternative production practices have come up with even more label claims to distinguish their products from conventionally produced meat. For example, claims such as "raised without added hormones," "no antibiotics used in raising," and "no subtherapeutic antibiotics used in feeds" are commonly used by producers to describe the "naturalness" of their products. (10)

Such varied claims make it difficult for consumers to make informed decisions at the supermarket. Further complicating the matter, the US Food and Drug Administration (FDA) sets residue limits which must be met by all producers, regardless of production methods. Strictly speaking, producers can meet the FDA standard for allowable residue limits whether they raise their animals conventionally (regular antibiotic use), organically (no antibiotic use), or with limited antibiotic use.

What matters to many consumers is whether the meat they buy is produced sustainably in a way that minimizes drug and hormone additives. Consumers who wish to support sustainable food production practices may find themselves mislead into buying products that do little to address these sustainability issues. For example, a "natural" cut of meat labeled, "No antibiotics administered 120 days prior to finishing," means that the producer could still administer antibiotics to the animal on a routine basis from birth until the last 120 days of the animal's life. While this may assure the consumer that the meat carries no detectable antibiotic residue at slaughter, the growing practices still allow antibiotic use for much of the production cycle. Therefore, "natural" label claims do not necessarily provide consumers with sufficient details to make informed decisions at the supermarket.

In January 1999, the Secretary of Agriculture and the FSIS announced that until a national standard for organic meat and poultry production is established, it will allow certified organic meat producers to market and label their products as "certified organic by (a certifying entity)." (11) This is a first step in providing consumers more choices in the meat products they buy, although "organic"-labeled meat has yet to appear in the supermarket.

In October 1999, the Organic Trade Association (OTA)-a 1000-member business association of organic growers, processors, certifiers, and others-adopted the American Organic Standards, a model to provide guidance to the industry. USDA then used OTA's standards as one of its references in developing its new proposed organic rules. (12) In December 1999, the Texas Department of Agriculture also proposed standards for organic livestock production in the state. (13) The Texas proposal adheres to many of the same guidelines as the national proposed standards, including the requirement for 100% organic feed and prohibition of sub-therapeutic antibiotic use. And under the proposed national organic rules, a state's standards cannot be less restrictive than the federal standards. (14) Therefore, the state's standards will have to comply with the federal regulations once those are in place. Texans will then be assured that the organic animal products they buy are certified to the highest standard.

The adoption of a unifying national standard for organic production would demonstrate a commitment on behalf of government and the organic industry to expand and promote sustainable livestock production practices. A strong, standardized "certified organic" meat label would boost consumer confidence in alternative meat products and allow for more informed purchasing. Without such a standard, conscientious consumers will continue to secondguess the meaning of the labels on the meat products they buy.

NOTES:

1 Vandeman, Ann M. and Beth Hayden, "New Law Paves Way for Expanding Organic Market," Food Review (May-August 1997), p. 28; United States Department of Agriculture, "Glickman Announces New Proposal for National Organic Standards," USDA Press Release No. 0074.00, March 7, 2000.

2 USDA, Agricultural Marketing Service, "National Organic Standards Board to Meet June 8-10," AMS News Release No. AMS-127-99, May 21, 1999.

3 United States Department of Agriculture, "Glickman Announces New Proposal for National Organic Standards," USDA Press Release No. 0074.00, March 7, 2000.

4 USDA, Agricultural Marketing Service, National Organic Program Proposed Rule, 7 CFR 205.236-205.239, March 7, 2000.

5 USDA, Food Safety and Inspection Service (FSIS), "Organic Labeling Claim Allowed on Meat and Poultry Products," FSIS Press Release, January 14, 1999.

6 4 T.A.C. 18.2

7 According to the TDA, Quality Assurance International and International Certification Services, Inc. are currently accredited in Texas (Texas Department of Agriculture, "Private Organic Certification Companies Registered in Texas," January 31, 2000).

8 4 T.A.C. 18.4

9 USDA, Food Safety and Inspection Service, "Natural Claims," Policy Memo 055, November 22, 1982; Letter to Producers from Robert C. Post, Labeling and Additives Policy Division, USDA, March 8, 1999.

10, USDA, Food Standards and Labeling Policy Book (August 1996). Note: The USDA refers to these types of claims as "negative labeling" and considers them distinct from the "natural" label (USDA, "Negative Ingredient Labeling," Policy Memo 019B, August 18, 1994.)

11 USDA, Food Safety and Inspection Service, "Organic Labeling Claim Allowed on Meat and Poultry Products," Press Release No. 0015.99, January 14, 1999; Federal Register, "'Certified Organic By' Labeling on Meat and Poultry Products," Vol. 64, No. 69 (April 12, 1999).

12 Organic Trade Association, "Organic Trade Association Adopts American Organic Standards," Press Release, October 20, 1999; Organic Trade Association, "OTA Cautiously Optimistic About Proposed Organic Regulations," Press Release, March 7, 2000.

13Texas Register, "Chapter 18. Organic Standards and Certification," Volume 26, No. 49 (December 3, 1999) pp. 10638-10653.

14USDA, "National Organic Program Revised Proposed Rule: State Organic Certification Programs." Internet source: http://www.ams.usda.gov/nop/facts/statenew.htm, printed 4/10/2000.