From: marilyn.wentz@rmfu.org
Sent: Wednesday, August 02, 2006 2:45 PM
To: MarketingClaim
Subject: grass-fed standard proposal



August 2, 2006



To:       U.S. Department of Agriculture

            marketingclaim@usda.gov

Re: Docket No. LS-05-09



Fm:      John Stencel, President, Rocky Mountain Farmers Union



As an organization representing more than 26,000 independent family farmers and
ranchers in Colorado, Wyoming, and New Mexico, we are strongly opposed to USDA’s
proposed protocol for grass-fed labeling, which would allow animals fed
roughage, including corn and other grain silages, in confinement being labeled
as “grass-fed.”

. 

We support the rule that animals must receive 99 percent of their lifetime
energy supply from grass and forage (excluding time nursing on their mothers, we
presume) in order to have their meat or milk labeled “grass-fed.”  While
legitimate grass-fed producers in many parts of the country must, during dry and
cold times of the year, feed dried roughage (hay), the focus of grass-fed
production should be animals raised in grass pastures, not in the confinement of
feedlots and fed corn silage and other grains not separated from their stalks.



If USDA fails to define the standard this way, it will have devastating affects. 
First, it will destroy the legitimate grass-fed industry, which has been
diligently developed by independent family farmers and ranchers trying to carve
out a niche and boost their ability to make a living.  Secondly, defining
grass-fed as USDA has proposed will undermine the confidence of consumers who
expect that a product labeled “grass-fed” is raised predominantly on pasture and
not in a feedlot.  Third, it fall short of ensuring the proven health benefits
grass-fed meats provide to consumers.



Grass-fed beef contains “anywhere from two to 10 times as much omega-3 fatty
acids as regular beef, according to an associate professor of animal sciences at
Auburn University in Alabama.  These healthy fats are known to be important for
the brain, for the heart and possibly for mood.  Studies also suggest that there
could be health advantages to returning to a diet that has more omega-3.



Other possible nutritional advantages include increased levels of beta carotene,
which is converted in the body to vitamin A.  Grass-fed beef appears to contain
more vitamin E, and more conjugated linoleic acid (CLA), a type of healthy fat. 
There is growing evidence that CLA may help reduce risk of cancer, diabetes and
heart disease, and may be linked with a lower percentage of body fat.



Rocky Mountain Farmers Union believes that the rules for grass-fed beef must
recognize this science and maintain the integrity of the market that grass-fed
beef producers have created.



Rocky Mountain Farmers Union represents more traditional producers than niche
market, specialty producers, such as grass-fed.  Nonetheless, in today’s
competitive environment, we believe it is important that independent producers
have options that will enable them to compete against corporate domination of
our food system, especially in the meat area.  Niche or specialty marketing of
healthy food is one way we can do this.  Do not pull the rug out from under the
feet of these entrepreneurial producers by adopting rules that destroy a new,
viable, beneficial and growing production and marketing business!