From: jxc555@gmail.com
Sent: Friday, May 19, 2006 4:52 PM
To: MarketingClaim
Subject: Docket LS-05-09


Relative to the comments being accepted concerning a grass-fed beef claim, I
wish to make some statements.

First, this step is a very necessary and useful one to the collective beef
industry.  The grass-fed enterprise suffers from a lack of continuity in the
description of it's products, and this has caused confusion to both producers
and to customers for grass-fed beef.

The definition of 1% non-grass or forage fed post-weaning may be too confining
for the production of an acceptable product for the customer and for profit
potential to the producer.  In the general case, this would imply only 45 lbs.
of non-grass or forage feed dry matter would be allowed (600 lbs. of animal
weight added at 7.5 lbs. of feed dry matter per pound of weight gain.)  This
amount is insufficient to allow adequate animal weight gains during non-grazing
periods.  Extensive research in Argentina (Pordomingo et al., 2004, 2005) has
shown it is necessary to maintain .8 to 1.0 kg/day weight gain to maintain
production efficiency and to provide meat products with a high acceptability to
customers.  Seventy-five percent of beef producers in the US work with an
environment of periods of zero plant growth, and only the highest quality stored
forages will result in weight gains approaching 1.0 kg/day. 

The grass-fed, natural, and organic segments of the food industry are poised to
significantly change the supply of these products, but they must be supplied in
a profitable manner.  "Cottage" industries can survive with 99-100% grass-fed
beef, but a grass-fed production unit cannot.  Further, an increase in the
customer base for grass-fed beef will be predicated on acceptability of this
product in relation to traditional beef, chicken, and pork. Consumer research
shows the priority for beef-buying decisions are for taste and eating
satisfaction.  The future growth of the grass-fed beef enterprise-with the
validity and consistency supplied by a process verification label from USDA-will
be determined by buying decisions which have a high priority for quality and
taste.  Please be sure the process verification label standards do not diminish
this potential.

--
Dr. John Comerford
Associate Professor
324 Henning Bulding
University Park, PA 16802
814-863-3661
814-865-7442 FAX