From: nickmaravell@comcast.net
Sent: Wednesday, May 17, 2006 12:28 PM
To: MarketingClaim
Cc: ericrice@macconnect.com%inter2;
liana@sustainableagriculture.net%inter2; brise@ofrf.org%inter2;
mark@ofrf.org%inter2; sfultz@umd.edu%inter2; vough@umd.edu%inter2
Subject: Docket # AMS-2006-0068 Grass Fed Claim: Comments



Martin O'Connor,

Thank you for speaking with me today about the USDA grass fed standard your
office has put out for public comment.

My comments are in response to a "Notice and Request for Comments" for Docket
AMS 2006-0068 (legacy ID LS-05-09) titled "Standard for Livestock and Meat
Marketing Claim, Grass (Forage) Fed Claim."

In general, I think this standard represents a tremendous improvement over the
previous proposed standard.  I have no objection to the
language included in the standard.   However, I think a small amount of
additional language needs to be added in order to make the standard clear.

Most of the language in the two short sentences I would like added is already
contained verbatim in the Docket in the "Background" section immediately
preceding the standard.

My suggestions are:

1.  Before first sentence, add: "This claim applies to ruminant animals only." 
This will clarify the standard for the consumer.  Free range poultry producers,
such as myself, maintain that their birds eat a substantial amount of forage. 
It should be clear to the consumer that this standard could never be met by a
poultry producer.

2. Add a new sentence after the sentence ending with "prior to weaning"
: "Hay, haylage, baleage, silage, and ensilage may be fed."  This will answer
the obvious question from many producers.

3.  The issue of "immature seed," which is referenced in the background
statement but not in the standard itself, is quite complex. What is an immature
seed?  It would take pages to define the stages of seed in grasses, mixed hay,
small and large grains, brassicas, etc.  The intent of this standard is to avoid
feeding cereal grains (wheat, oats, barley, rye and their derivatives) and large
grains (soybeans, peas etc. and corn, sorghum, millet, and their derivatives). 
Unfortunately, based on the language of the background statement, it might be
permitted to feed grain silage with fully developed heads.

For example, with large grains I could cut corn silage in the late dough stage
and feed it.  I do not consider the seed to have fully matured.
This is corn before it has reached its final dry down stage for grain harvest. 
Ears are fully formed and moisture content of the grain is
above 22%.    The same would apply for cereal grains.   All the seeds
would be naturally still attached to the silage.  Some might be cut or chopped
(as in corn) and others would be fully intact (as in wheat baleage).  Basically,
I would be feeding ensiled grain and stover or ensiled grain and straw.  Is this
the intent of the standard?  Who determines or defines what is an "immature"
seed?

With regard to hay, such as orchardgrass and timothy, or mixed hays with legumes
(clovers and alfalfa), the seed heads do not mature as evenly as for grains,
especially in mixed species hays.  Most hay that has formed a full head will
create viable seed once it has dried.  Hay is often cut in full head.  Are these
immature seeds?  Is it the intent of the standard that no hay with heads can be
fed?

I have a suggestion to clarify the intent of the standard so that small and
large grain silage with fully developed grain cannot be fed.  First, I would
change the way "immature seed" is being used so that it only refers to small and
large grains.  Further, I would define immature seed for small and large grains. 
Then, I would not apply the "immature seed"
concept to other (hay) species.

I would add a "provided" clause at the end of my suggested revision in
#2 above to read as follows in its entirety:

"Hay, haylage, baleage, silage, and ensilage may be fed, provided no grain
species have reached the milk stage nor legume grain reached 10 percent pod
fill."

I hope you find these comments useful.  I would be happy to discuss these issues
further or write additional comments if you think that would be helpful.

Nick Maravell.