Department of Agriculture - Food Safety and Inspection Service Product Labeling: Definition of the Term "Natural": Comments submitted by Mack H. Graves, CEO, Panorama Meats

Good Morning.  My name is Mack H. Graves, and I serve as CEO of Western Grasslands, Inc., doing business as Panorama Meats of Vina, CA.  Our company markets both natural and organic grass-fed beef from our base in California to mainstream conventional retailers, specialty product or natural food retailers, and food service operators on the West Coast and across the U.S.  We have 43 rancher/producers supplying us cattle raised to protocols we have developed that far exceed the current definition of “natural.”

Panorama Meats commends Hormel, and certainly FSIS and AMS, for starting the process to develop a complete definition for the use of the term “natural” for meat and poultry.  The vagueness of the current “natural” definition—“minimally processed and no artificial ingredients”—first established some 24 years ago, has sown seeds of consumer confusion and encouraged clever marketers to trumpet the word “natural” on packages of their meat and poultry, even though such meat may have come from animals that were hardly “naturally raised.”  Such confusion has lasted far too long and a more meaningful definition of “natural” is necessary.

My background also includes serving as President and CEO of Coleman Natural Beef, and interim CEO of Meyer Foods, the parent of Meyer Natural Angus, arguably the largest and second largest natural beef companies in the U.S., respectively, as well as Sr. VP of Marketing and Sales for Perdue Farms.  At both natural beef companies, I learned that a “natural” program that exists from conception to consumption is workable, believable and consumer-trusted.  My experience at Perdue taught me that using the marketing term “natural” resonates with consumers, but it needs a definition that can be easily understood and believed.

Panorama’s Question

The question we at Panorama ask is, “How do you take meat or poultry from animals raised “unnaturally” with growth stimulants, antibiotics, questionable humane practices and poor environmental stewardship and make the meat “natural” by minimally processing it with no artificial ingredients?  Separating livestock raising from processing and marketing in developing a definition for “natural” will only add to the consumer confusion that currently surrounds the term.  The use of the term “natural” must be clearly defined for meat and poultry from “conception to consumption.”

Hormel is Confused – Not Panorama

Although Hormel implies in its petition that some consumers or animal raisers may confuse “natural” products with those that are free of antibiotics or growth stimulants, there is no confusion at Panorama, nor with our consumers, nor with our rancher/ producers.  Our consumers expect our cattle to be raised according to the “natural protocols” as we have defined them, and they trust the resultant beef products will be naturally processed, marketed and labeled accordingly.  They aren’t confused.  Our rancher/producers have to adhere to our “natural” raising protocols or they know that their cattle will never bear the Panorama Grass-Fed Natural or Organic label.  They aren’t confused either.  In our view, Hormel appears to be confused in its zeal to define “natural” as simply minimally processing meat and poultry with no artificial ingredients.

Answers to questions posed in FSIS’ Request

Specifically to the Hormel petition:

  1. Minimally processed and necessary accommodations: Is it reasonable to include as part of the definition of “natural” a stipulation that products can be no more than minimally processed?  This begs the issue.  Minimally processing is a part of the “natural” definition that begins with the animal-raising practices and concludes with a finished product.
  2. Are there accommodations necessary for processing techniques for enhancing safety that may disqualify a product as “natural”?  Yes.
  3. New food processing techniques:  What are the implications and conflicts that exist with regard to using current and new food processing methods?  To parse words and contentious word meanings is not the issue.  Our society thrives on continuous improvement and to disregard any processing improvements may not be in the best interest of food safety.  New processing methods must, however, be judged on whether they change the “naturalness” of the final product.
  4. Consumer studies: Are there consumer studies about what the claim “natural” means on labels?  At Panorama, we have not conducted formal consumer research other than continuously asking questions of those consumers with whom we interact at in-store product demonstrations.  The reactions we receive include commendations for our efforts to market a product that is naturally raised and processed.  We recognize, however, that these are not scientifically grounded consumer research studies.  However, in the International Journal of Consumer Studies, Volume 30, Issue 5, page 439, September 2006, 1,000 households in the Central Coast region of California reported that the highest level of support was for the humane treatment of animals, indicating high consumer interest in raising animals naturally and/or organically.  What do consumers think that the terms “minimal processing,” “artificial and synthetic” and “preservatives” mean?  Our experience is that our consumers think these terms indicate “unnatural.”
  5. Natural definition conflicts: Do food safety and consumer protection benefits of using what historically may have been considered more than minimal processing techniques and antimicrobial agents outweigh conflicts with the meaning of ”natural”?  A new “natural” definition will not be an “organic” standard with its strict rules and exhaustive ingredient research, but rather “natural.”  Consequently, food safety is paramount and deviations for the sake of food safety must be allowed.

It’s Not a Race

In summary, the Hormel petition seeks to dilute the term “natural” by codifying it in its current confusing and mistrusted form.  It justifies this quick codification approach in the terms of a race to beat another Federal agency—the FDA in its response to The Sugar Association’s petition to them to define “natural.”  There is no justification for the race.  Too many live animal producers, meat and poultry processors and marketers and, most importantly, consumers, will rely on a thorough and complete definition of “natural” for it to be recklessly and quickly defined simply to win the “definition” race.  The various federal agencies must work in concert on the definition of “natural” for the greater consumer good, not to mention food safety, rather than be prodded to win a “natural” definition race.

In conclusion, the definition of “natural” must stretch from the livestock’s lifestyle to their diet to the processing and marketing of meat and poultry.  If the new “natural” definition is a process from “conception to consumption” and is verified to have been followed, then the words “USDA Natural” can be confidently and meaningfully placed on the resultant package of meat and poultry.

Thank you.

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