From: kcapers@ucsusa.org
Sent: Tuesday, August 01, 2006 4:38 PM
To: MarketingClaim
Subject: Please Adopt a Strong Standard for Grass-Fed Meat



Chief, Standardization Branch, USDA Mr. Martin E. O'Connor Agricultural
Marketing Service, U.S. Department of Agriculture Room 2607-S, 1400 Independence
Avenue SW Washington, DC 20250-0254

Dear Chief, Standardization Branch, USDA O'Connor,

I am writing to express my support for the proposed USDA grass-fed meat label
and to urge you to clarify the proposed rule to prevent meat from grain-fed
animals from being erroneously labeled as grass-fed.

In particular, I applaud the USDA for proposing that an animal's diet must be 99
percent grass or forage based in order to be marketed as grass-fed. This strict
standard will ensure consumer confidence in the grass-fed label; help farmers
who raise animals on grass distinguish their products in the marketplace from
meat from animals raised on grain diets; and help protect the environment and
human health.

I am, however, concerned that ambiguous language in the proposed rule could
allow meat from animals that are fed large quantities of corn and other grains
to still be labeled grass-fed. In the USDA's description of what can be fed to
weaned "grass-fed"
animals, forage--typically defined as grass, legumes, and other plant
material--includes "grain in the immature stage." I strongly encourage the USDA
to clarify the meaning of immature grain to maintain the integrity of the
grass-fed label.

Finally, I urge the USDA to quickly issue the "free-range/pasture-raised" label
with the "grass-fed" label.
These two labels will work in tandem to avert confusion about these two similar
but distinct production claims.


Sincerely,

Karla Capers
2 brattle square
Cambridge, Massachusetts 02238