From: Elizabeth.Fry@wholefoods.com Sent: Thursday, August 10, 2006 2:25 PM To: MarketingClaim Cc: Margaret.Wittenberg@wholefoods.com%inter2 Subject: Comments re Docket No. LS-05-09 Comments regarding Docket No. LS-05-09 United States Standard for Livestock and Meat Marketing Claim, Grass (Forage) Fed Claim Whole Foods Market is the world’s leading retailer of natural and organic foods. We are committed to high standards of animal welfare and believe raising animals on grass expresses the highest respect for the animal, the land and human beings. We support the proposed USDA standards for the Grass Fed label; however we urge you to clarify the standard to prevent meat from grain-fed animals from being erroneously labeled as Grass Fed. We particularly applaud the integrity of the USDA’s proposed label definition for Grass Fed requiring that 99% of the animals’ diet must be from grass or forage throughout their lives. The strength of the label Grass Fed will promote consumer confidence and will distinguish the producers who raise animals entirely on grass from those who feed grain at some point in the animals’ lives. Environmental stability and enhanced human health will also result from the natural relationship between the animals and the land. We strongly support this part of the label requirement. We have three comments regarding the standard as it is written. 1. The term “grain in its immature stage” is not clearly defined. The inclusion of this unqualified term leaves room for the interpretation that animals that have eaten even large quantities of grain might still be labeled as Grass Fed. We strongly urge the USDA to clarify the meaning of “immature grain” to maintain the integrity of the Grass Fed label. 2. There is no specific prohibition of confinement for Grass Fed animals in this standard. It is possible that animals in confinement might be fed grass and forage and still earn the label Grass Fed. Grass Fed animals must be continually on range or pasture with temporary access to shelter during severe or inclement weather. We strongly urge the USDA to prohibit the confinement of animals within this standard in order to ensure consumer confidence in the integrity of the Grass Fed label, to acknowledge farmers who raise their animals entirely on range or pasture and to protect the environment and human health. 3. We encourage the USDA to issue the “Free Range/Pasture-Raised” label at the same time as it issues the “Grass Fed” label. These two mutually supportive label standards issued together will make a very strong and clear statement regarding their intent and will prevent them from being confused with one another. Margaret Wittenberg Whole Foods Market, Inc. Communications and Quality Standards 550 Bowie St Austin, TX 78703 Phone: 1-512-542-0396 Fax: 1-512-482-7396 This email contains proprietary and confidential material for the sole use of the intended recipient. Any review, use, distribution or disclosure by others without the permission of the sender is strictly prohibited. It you are not the intended recipient (or authorized to receive for the recipient) please contact the sender by reply email and delete all copies of this message.