Panorama Grass-Fed Meats response in support of the USDA proposed definition for Grass-Fed Beef.

Sent via email to: martin.oconnor@usda.gov

Dear Mr. O’Connor,

Panorama Grass-Fed Meats is pleased to submit our thoughts and recommendations in support of the proposed voluntary standard for Grass (Forage) Fed marketing claim, Docket No. LS-05-09.

It is our position that a clear grass-fed definition should form the boundaries for the industry’s growth. We believe the industry should be restricted or enhanced by the pressures of a competitive market place, not by artificial and arbitrary efforts to control its size with a definition that is too restrictive with the use of feeding and/or raising claims. We feel that the primary arbiter of the consumer’s desire for any food product, including a grass-fed protein, is based on taste. A grass-fed product, therefore, must satisfy the palatability requirements of prospective consumers if it, and the industry, are to be successful.

Specifically, we would like to comment on three particular points as outlined in the current proposal:

  1. Free range - Panorama Grass-Fed Meats fully supports the AMS determination to keep the terminology for Grass (Forage) Fed and Free Range as two separate and distinct standards. If the grass-fed industry wants to remain competitive in the marketplace by providing a domestically grown grass-fed product, there must be allowances for variations in production methods. The finalized Grass Fed (Forage) voluntary standard must take into account the necessary changes to producer programs, which may be caused by adverse weather conditions causing the need for sacrifice pastures, and variations in grazing programs and pasture rotational practices, among others. So that proper range management can continue, availability of grazing ground, diverse geographical location, economic limitations and efforts to maintain animal health and growth during times when feed is limited must also be considered. Such production variations must be allowed so the grass-fed definition does not change the common goal of all grass-fed producers to create a healthful, domestic product that enables local family farms and ranches to continue for generations to come. Additionally, there are times of the year when grass is simply not available and the animal’s ration must consist of grasses that have been harvested during the year and fed in a controlled situation. Grazing ground is a limited resource, particularly for small sustainable family farms, and to restrict its use by incorporating a confinement parameter as part of the grass-fed definition is a disservice to them and to the industry.
  2. Use of artificial growth stimulants and treatments – While not specifically mentioned in the proposed grass-fed claim, we feel that the use of fed growth stimulants such as subthereapeutic antibiotics, anabolic steroids and any others, should be prohibited and made a part of the grass-fed definition. While the use of antibiotics and steroids are properly addressed in other standards, specifically the Organic rules and Natural guidelines, feeding them makes them a substance that must be addressed within the grass-fed definition. Other aspects of raising animals and processing the resultant meats are properly administered within the National Organic Program and Natural guidelines and need not be a part of the g.
  3. Grass-fed claim. If grass-fed companies wish to make a claim of no hormones or antibiotics used, as we at Panorama do, the feed portion of such claims is properly regulated within the grass-fed definition while other aspects of such claims can be made as part of these other rules and guidelines. The grass-fed definition should be restricted to the diet of the animal.
  4. Silage – Within the statement about the use silage and its synonyms are the words, “grain in the immature stage,” which we feel needs to be more restrictive in its definition to insure that variations in silage production do not allow for mature grains to be fed.

It has been our experience that while interacting with many consumers in the marketplace as we discuss our product and its attributes, they are primarily concerned about what the animal eats during its lifetime, and, not necessarily, where it was raised. Based on these non-scientific market research studies, we have coined the term for our grass-fed beef that it is a diet not a lifestyle. Undocumented consumer reactions, which certainly our experience mentioned above is, as well as other comments stating that consumers are demanding that grass-fed must include life on open pastures, are simply that, undocumented, unsubstantiated and, therefore, not necessarily valid.

Finally, any definition for grass-fed cannot be allowed to restrict legitimate commerce. For those of us in the grass-fed industry who have entrepreneurially taken the risk to be on the vanguard of a new market, we must be allowed to grow within a definition that speaks with clarity, but does not restrict growth by very parochially defining different aspects of the feeding protocols espoused by a few advocates. Such zealously pled beliefs give rise to disparate claims and little opportunity for a cohesive, fair and impartial guideline that is meaningful for the consumer, yet not so restrictive as to prevent those who wish to grow a legitimate business within a fairly arbitrated industry the opportunity to do so.


Respectfully Submitted,


Mack H. Graves
CEO
Panorama Grass-Fed Meats
P. O. Box 94
Vina, CA 96092
Phone: 303-882-5453
Email: latigomack@cs.com

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