From: moonchild3321@hotmail.com
Sent: Thursday, August 03, 2006 11:08 AM
To: MarketingClaim
Subject: comment on docket #LS-05-09




Martin E. O'Conner
USDA-AMS, Room 2607-S
1400 Independence Ave, SW
Washington, DC 20250

Dear Martin E. O'Conner,

Martin E. O'Connor
Chief, Standardization Branch
Livestock and Seed Program
USDA-AMS
Room 2607-S
1400 Independence Ave., SW
Washington, DC 20250-0254
Via E-mail: Marketingclaim@usda.gov

Dear Mr. O'Connor;

I am writing to comment on Docket #LS-05-09, the United States Standard for
Livestock and Meat Marketing Claim, Grass (Forage) Fed Claim.

I strongly support the USDA's revision of the grass fed labeling claim so that
it requires that grass and/or forage shall be 99% or higher of the energy source
for the lifetime of the animal.
The requirement ensures that the benefits of a grass fed diet are passed onto
consumers.

As a consumer, I also assume that other values are encompassed in the grass fed
label. Among these values are access to pasture and restriction on the use of
certain feed types. In order to ensure that consumers are not misled by the
grass fed label, I believe the standard should also include the following
requirements:

Access to pasture. There is nothing in the current definition that requires
these animals be out on pasture. This means that feedlots could feed harvested
grass and market that beef as "grass fed." This is misleading and goes against
what consumers expect from the label. The USDA should require that a significant
amount of the grass come from grass and forage consumed by animals while
pasturing. Animals with no access to pasture should not be labeled as grass fed.

Prohibit the use of genetically engineered forage. The growth in markets for
alternative production standards such as grass fed has been fueled by consumers
like myself that do not want their food produced using genetic engineering. USDA
should ensure that the grass fed standard is consistent with this consumer
desire.
The grass fed label should ensure that the grass or forage used as feed is not
sourced from pasture or harvested from grasses using genetically engineered
varieties of alfalfa, bahiagrass, tall fescue, Italian ryegrass or other such
grasses.

Include dairy products. The standard should be written so as to clearly indicate
that dairy products derived from livestock meeting the grass fed standard can be
marketed using grass fed claims.

Thank you for taking my comments into consideration.



Sincerely,

Debra Siegel-Furlin
1763 Main Street
108B
Dunedin, Florida 34698