From: lgwin@nature.berkeley.edu Sent: Friday, August 04, 2006 2:24 PM To: MarketingClaim Subject: Docket No. LS-05-09 August 4, 2006 Martin E. O?Conner Chief, Standardization Branch, Livestock and Seed Program, AMS, USDA Room 2607-S 1400 Independence Avenue, SW Washington, DC 20250-0254 RE: Docket No. LS-05-09 USDA?s proposed grass fed standard is a good step toward protecting the integrity of the term ?grass fed.? However, there are several ways this standard should be made stronger. First, as someone who has been conducting research on the emerging grass fed sector for the last three years, and also as an avid consumer of grass fed foods, I am glad that the USDA proposal requires 99% of an animal?s lifetime energy supply be from grass and forage. However, I believe that the standard can and should go further and require that grass fed animals be raised on pasture from birth to harvest. As a consumer, when I buy grass fed meats, I am specifically choosing meat from animals that range freely and are not confined unless absolutely necessary to the health of the animal or the land. As it stands, USDA?s proposal will allow animals to be kept in confinement, fed harvested forage, corn silage and other grains that have not been separated from their stalks. I worry that if this proposed claim becomes law, we?ll have feedlot animals, fed antibiotics and hormones, but legally labeled ?grass fed.? The AMS has said that the grass fed standard should refer only to what the animals eat, and that other aspects of production ­ free-range, for example ­ should be addressed by separate claims. However, there is no reason why ?grass fed,? since it has been designed as a Process Verified Program, can not be more comprehensive, containing other elements apart from what the animals actually eat. The National Bison Association?s Process Verified Program not only includes traceability but that the bison do not eat feeds containing animal byproducts and are not treated with subtherapeutic antibiotics or growth hormones. The grass fed PVP could, then, include not only a free range requirement, but could also include a prohibition on subtherapeutic antibiotics, growth hormones and animal by-products. I agree with the American Grassfed Association that the following language could be added to the USDA standard: ?It is the intent of this standard to prevent the finishing of ruminants for slaughter in confinement such as a feedlot situation, as defined by EPA?s definition of a CAFO, where non grain forage products are substituted for grain concentrates. Grass fed ruminants must graze pasture during the entire growing season and preferably beyond (aside from the exceptions granted in this definition) where they will receive most if not all of their nutrition and be allowed to fulfill their natural behaviors and basic instincts at all times.? Exceptions should be limited to emergencies that may threaten the safety and well-being of the animals or soil, and to management practices such as roundups, sorting, shipping and weaning. In addition, the standard should not be interpreted as to exclude a management intensive or other high intensity rotational grazing system. Thanks very much for the opportunity to comment. Lauren Gwin, PhD Research Consultant 2608A Sacramento Street Berkeley, CA 94702