Greener Choices https://www.greenerchoices.org Food Safety And Sustainability Fri, 05 Jun 2020 10:34:39 +0000 en-US hourly 1 https://wordpress.org/?v=5.5.1 Organic https://www.greenerchoices.org/usda-organic-label-record/ https://www.greenerchoices.org/usda-organic-label-record/#respond Fri, 05 Jun 2020 10:34:39 +0000 https://www.greenerchoices.org/?p=320

“Organic” is a meaningful label. It is verified and backed by USDA standards that are designed to promote sustainability and prohibit chemical pesticides, GMOs, irradiation, sewage sludge, and artificial ingredients (with some exceptions).

How meaningful is this label?

Meaningful

100% Organic: Highly meaningful. The organic label is highly meaningful for foods that are labeled as “100% organic.” These foods were produced in accordance with the organic standards and were processed without synthetic materials.

ORGANIC on produce: Highly meaningful. We also consider the organic label to be highly meaningful for unprocessed plant-based foods, such as fruits and vegetables. These are rarely labeled “100% organic” but simply “organic,” but would not contain synthetic or non-organic ingredients. The organic standards are highly meaningful for crop growers, who are prohibited from using nearly all synthetic pesticides, as well as all synthetic fertilizers, antibiotics (which continue to be approved for use in conventional fruit orchards), genetically engineered seed, sewage sludge and irradiation.    

ORGANIC on meat, dairy, eggs and processed foods: Meaningful*. The standards are meaningful for promoting sustainable agriculture practices and eliminating toxic synthetic pesticides, fertilizers and other synthetic inputs.  Given the concerns with standards and oversight over the last few years, CR no longer rates “organic” on meat, dairy, eggs and processed foods as highly meaningful but as meaningful.  

The organic standards only address animal welfare in minimal ways, which is why we rate the “organic” label on animal products as meaningful and not highly meaningful. The USDA should implement National Organic Standards Board recommendations on animal welfare. We also have concerns about enforcement of the requirements to grant outdoor access, especially for organic poultry. The organic label also does not address fair trade practices or conditions for farmworkers (“fair trade”) or proximity of production to point of sale (“local”). For additional value, consumers should look for the organic label in combination with a meaningful or highly meaningful animal welfare label,** and a meaningful or highly meaningful fair trade label.***  

*Note: see “Inconsistencies for antibiotic use” section below

**Note: meaningful and highly meaningful animal welfare labels include: Animal Welfare Approved, Certified Humane and Global Animal Partnership (GAP) Steps 3-5+.

***Note: meaningful and highly meaningful fair trade labels include: Fair for Life, Food Justice Certified, Fair Trade Certified and Fairtrade.

For processed foods, our 2014 consumer survey shows that an overwhelming majority of consumers think that the organic label should mean no artificial materials were used during processing (91%) and that the product contains no artificial ingredients (89%). The Organic Foods Production Act (OFPA) permits the addition of artificial ingredients if they are approved and appear on the National List, and materials should only be added to the National List, for a five year period, if they meet certain criteria, including that they should be considered “necessary to the production and handling of the product because of the unavailability of wholly natural substitute products.”

However, organic processed foods, including organic infant formula, containing artificial and non-organic ingredients that have not been approved for use in organic foods now appear on store shelves. We have filed a complaint with the USDA regarding unapproved ingredients in organic baby food, but the USDA has not taken enforcement action.

Moreover, we consider many of the artificial and non-organic ingredients that have been approved for use in organic foods to be not essential.[expert opinion] Some are added to recreate texture, color or flavor. Other non-organic ingredients have been approved even when concerns have been raised regarding their potential negative impacts on human health (e.g., carrageenan). 

Is the label verified?

Yes

Farms and food processing facilities are inspected by a third-party certification agency. Inspections are not conducted by the USDA; rather, the USDA accredits certifying agencies to certify to the USDA organic standards.

Organic standards require annual inspections of farms and processing facilities, and random inspections are possible. Farmers and food processors are also required to submit an updated organic production or handling system plan to the certifying agency annually.

The standards also require random testing for pesticide residues or environmental contaminants. Each certifying agency is required to test samples from at least 5% of the operations it certifies on an annual basis. 

Is the meaning of the label consistent?

No

Any product with the USDA Organic seal must meet the USDA standards for food and agricultural products. On food, the “organic” and “made with organic” labels, even without the USDA Organic seal, are consistent in meaning. Products other than food can be labeled “organic” even if they do not necessarily meet the organic standards. Products with the USDA Organic seal must meet all the requirements in the standards.  

Foods can be labeled “organic” (without the use of the USDA Organic seal) only if they meet all the requirements in the standards, but this does not apply to non-food products such as textiles, personal care products and mattresses.

Recent Inconsistencies Unresolved

Inconsistencies for poultry and eggs: The Organic Foods Production Act of 1990 and the USDA regulations explicitly prohibit continuous total confinement of organic animals, and require that year-round access to the outdoors be granted. However, the USDA has failed to enforce this standard for poultry, and continues to allow a number of industrial-scale producers who have built covered porches as “outdoor access,” inaccessible to the majority of the birds, to label their poultry products “organic.”

Inconsistencies for personal care and cosmetics: Personal care products can display the USDA Organic seal if they meet all the requirements in the federal organic regulations for food. However, unlike foods, non-food products can claim to be “organic” without being certified to the USDA organic standards, without facing enforcement action from the USDA. For non-food products, consumers should look specifically for the USDA Organic seal.

Inconsistencies for antibiotic use: There is a legal allowance for use of antibiotics in poultry hatcheries, where antibiotics can be administered in the egg and on the first day of the chicks’ life. 

Inconsistencies for artificial ingredient approval: While artificial ingredients were supposed to be approved for a five-year period and then “sunset,” there have been a number of cases where these ingredients have been relisted or their use extended well beyond five years, even when human or environmental concerns have been raised.

Recent Inconsistencies Resolved

Access to pasture for ruminants: For ruminants (dairy cows, beef cattle, bison, goats, sheep), the standards were revised in 2010 to clarify that the animals must graze on pasture during the grazing season.

Antibiotic use in apple and pear production: When the organic standards were first developed, antibiotics were prohibited except in day-old poultry chicks and apple and pear orchards. The NOSB voted in 2013 and 2014 to prohibit the use of the antibiotics tetracycline and streptomycin in organic orchards. This prohibition took effect in October 2014.

Organic labeling of fish: There are no organic standards for fish or other seafood at this time. Even if raised to international organic standards, fish should not be labeled as “organic” when sold in the U.S. We continue to find seafood in U.S. stores labeled as “organic.”

Are the label standards publicly available?

Yes

Is information about the organization publicly available?

Yes

The organic standards are federal regulations of the United States Department of Agriculture (USDA). The USDA is a federal executive department. Information about the department’s leadership and financial information is publicly available at www.usda.gov.

Is the organization free from conflict of interest?

Yes

Standards development: Yes. Officials at the United States Department of Agriculture involved in writing and updating the organic standards are subject to  the government’s conflict of interest rules.

Members of the National Organic Standards Board (NOSB), a civilian, multi-stakeholder group, advise the USDA on organic standards but do not have final decision making authority and are prohibited from voting on matters in which they have a financial interest.

Verification: Yes. The organic standards require that accredited certifying agencies prevent conflicts of interest in several ways, including not certifying an operation if the certifying agent has a financial interest in the operation.

Was the label developed with broad public and industry input?

Yes

Standards development: The organic standards are federal regulations, which are required by law to be shared with the public and opened for public comment before they are finalized and adopted. Before the organic standards were adopted in 2002, the public had multiple opportunities for public comment. The final standards addressed many of the concerns that had been raised by public comment.

Standards updates: Updates to the standards are typically reviewed and recommended by the National Organic Standards Board (NOSB), a 15-member expert citizen panel that meets biannually to vote on recommendations. These meetings are open to the public, and citizens have the opportunity to comment both in writing before the meeting and in person during the meeting. The NOSB sends its recommendations to the National Organic Program of the United States Department of Agriculture, which again shares a draft of any proposed changes to the organic standards with the public, and accepts written public comments.

****Note: There have been instances where the USDA has initiated policy changes (such as materials review) which have not gone through public notice and rulemaking–which have been opposed by several groups including Consumer Reports.

Federal law (the Organic Foods Production Act or OFPA of 1990) and United States Department of Agriculture (USDA) regulations require that any food bearing the USDA Organic label or any other organic label on the front of the package must have been produced on farms and processed in facilities that adhere to a comprehensive set of federal standards designed to promote sustainability and minimize synthetic inputs in farming and food production. The USDA Organic standards promote soil fertility through natural methods.

USDA organic standards technically prohibit synthetic materials including synthetic pesticides and fertilizers, artificial growth hormones, antibiotics (See “Inconsistencies for antibiotic use” section below), sewage sludge, genetically engineered crops, irradiation, and artificial processing aids and food additives. Most of these practices are followed rigorously; however, the list of artificial ingredients approved for use in organic is growing and the 5 year sunset period for these materials is under current threat (see “inconsistencies” section below).

“100% Organic”
Foods can carry the “100% Organic” label if all ingredients are certified organic and were not processed with any synthetic materials.

“Organic”
At least 95% of the ingredients in a processed food labeled “organic” must be grown on a certified organic farm. Up to 5% of the product can consist of non-organic agricultural materials or artificial ingredients that have been approved for a 5-year period. These materials are supposed to be approved only when they are deemed essential to organic production, compatible with the principles of organic agriculture, and raise no concerns regarding their impact on human health and the environment. The organic regulations specify that synthetic and other non-organic substances should not be approved for use in organic foods if their primary use is as a preservative or to recreate or improve flavors, colors, textures, or nutritive value lost during processing. However, many ingredients whose primary purpose is to recreate textures, colors or flavors have been approved and appear in certified organic processed foods.

“Made With Organic”
If a product makes the “Made with Organic [specified ingredients]” claim, it means that at least 70% of the ingredients are certified organic. The remaining 30% of ingredients can come from conventional farms, which means they can be produced with synthetic pesticides and fertilizers, antibiotics, artificial growth hormones, chemical processing aids and other inputs that are prohibited on organic farms and processing facilities. The 30% conventional ingredients cannot, however, be genetically engineered, produced with sewage sludge, or irradiated. The Certified Naturally Grown label means that the farm where the food is grown uses the same farming methods as certified organic farms but is not independently verified by a USDA-accredited certification agency and not subject to the legal enforcement of the USDA. The CNG label arose when farmers who did not want to participate in the USDA Organic program sought an alternative certification system with fewer requirements for recordkeeping and lower certification costs.

For More Information

Link to USDA National Organic Program website

The USDA organic standards require that any food labeled “organic” must have been produced on farms and processed in facilities that adhere to a comprehensive set of standards designed to promote sustainability and minimize synthetic inputs in farming and food production. The USDA Organic standards promote soil fertility through natural methods.

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Global Animal Partnership Step 4 https://www.greenerchoices.org/global-animal-partnership-step-4/ https://www.greenerchoices.org/global-animal-partnership-step-4/#respond Fri, 05 Jun 2020 10:08:34 +0000 https://www.greenerchoices.org/?p=318

The Global Animal Partnership (GAP) certification program is comprised of a series of step levels, each corresponding to a set of animal welfare standards. The rigor of the standards increases with higher step levels. The Step 4 label for chickens and pigs means the animals live in an enriched outdoor area. For beef cattle, the label means the animals are raised on pasture.  For all step levels, the GAP standards set limits on indoor ammonia levels, prohibit routine drug use (including antibiotics), prohibit animal waste products in feed, and prohibit routine tail docking of pigs. The label is verified.

Is the label verified?

Yes

Is the meaning of the label consistent?

Partially

Are the label standards publicly available?

Yes

Is information about the organization publicly available?

Yes

Is the organization free from conflict of interest?

Unknown

Was the label developed with broad public and industry input?

Yes

This label can be found on: Beef, chicken, pork, turkey, sheep, goat, bison

ORGANIZATION: Global Animal Partnership

url: www.globalanimalpartnership.org

LABEL STANDARDS: www.globalanimalpartnership.org/5-step-animal-welfare-rating-program/standards

What this label means

The label means that the animals were raised on farms that were verified to meet the farm animal welfare standards of Global Animal Partnership, a non-profit organization that says it “promotes and facilitates continuous improvement in animal agriculture, encourages animal welfare friendly farming practices, and informs consumers about the animal farming systems they choose to support.”

The Global Animal Partnership program uses six tiers, or steps, each representing a different set of standards for how animals are raised on the farm. The step level that is achieved is indicated on the label. Step 1 is the lowest rating; Step 5+ signifies that higher standards of animal welfare were met.

For Step 4, the claim on the label is “pasture-centered.”

In our analysis, we found that the standards for Step 4 fall short for chickens. The standards do not define “pasture” and have very few requirements for pasture management. The standards require that at least 50 percent of the outdoor area ise covered with vegetation and/or forage.

There are benefits to choosing meat and poultry with Global Animal Partnership Step 4 certification: Animals are raised with meaningful access to the outdoors, and beef cattle are not routinely removed from pasture. Also, the standards for all step levels set limits on indoor ammonia levels and prohibit routine drug use, animal waste products in feed, and routine tail docking of pigs.

We take a closer look at some of the requirements in the standards for some of the species that can be certified. Note that this is a summary; to read the standards in their entirety, click on the links above.

A closer look at the standards for broilers (chicken) 

Indoor space per bird

The Step 4 indoor space requirement for a chicken is roughly 11.9 by 11 inches for a 5-pound bird. This is an improvement over steps 1 through 3.

The Step 4 minimum indoor space requirement is roughly 0.91 square feet per 5-pound bird. (The standards state that the stocking density should not exceed 5.5 pounds of chicken per square foot.) This is a 36 percent increase over the industry norm, and chickens are given additional space outdoors; the space requirements are therefore an improvement over the industry norm, which gives each 5-pound chicken roughly 9.6 by 10 inches (0.67 square feet) with no additional outdoor space.

For housing, chickens must be given enough space to express natural behaviors, which include standing, turning around, and preening (using the beak to straighten and clean feathers) without touching another bird.

Clean litter

The standards for clean litter are the same for all step levels. Floors of all houses, including mobile houses that are stationary for more than three days, must be covered with non-toxic, fibrous, and friable litter. Up to 12 inches in width of caked litter would be allowed directly under water lines. Litter must be of quality and quantity to provide a comfortable environment and allow for dustbathing behavior. This requirement exceeds the industry norm.

Indoor air / Ammonia levels

The standards for ammonia are the same for all step levels. The standards state that an intervention plan designed to improve air quality must be implemented immediately if air quality levels exceed 20 ppm or a score of 2 on Global Animal Partnership’s air quality scale, which allows producers to use sensory evaluation to determine whether they should take action. On this scale, a score of 2 means the producer rates the odor as “distinct” and experiences watery eyes and/or coughing. (The human nose can detect the smell of ammonia at around 5 ppm.)

Lighting

The standards for Step 4 require that chickens experience a daily minimum of eight hours of continuous darkness throughout their lives. This is the same as steps 3, 5, and 5+, and it’s an improvement over steps 1 and 2, which require six hours of darkness. All step levels exceed the industry norm of providing only four hours of continuous darkness per 24-hour cycle after the birds’ first four weeks of life.

Environmental enrichment

To qualify as Step 4 rated, chickens must have at least two types of indoor enrichment, which must be provided by the time they are 10 days old (this is the same as Step 3). There must also be at least two types of enrichment in a covered outdoor area. Global Animal Partnership defines environmental enrichments as material that are provided to animals to “add complexity to their environment, encourage the expression of natural behavior, and decrease the expression of abnormal and deleterious behavior.” Examples of acceptable enrichment include bales of straw of hay, raised platforms, provision of forages or brassicas (e.g., broccoli), and scattered grains. Step 3 and 4 are an improvement over Step 1, which requires no enrichment, and Step 2, which requires one type of indoor environmental enrichment. Step 4 exceeds the industry norm. (Step 5 and 5+ chickens live mostly outdoors so indoor environmental enrichment is not needed.)

Outdoor access

The standards for Step 4 require that chickens live continuously in an enriched outdoor area with access to housing during daylight hours. Continuous access to the outdoors during daylight hours must be given to all chicken from the age of  4 weeks.

Outdoor access is defined as pastures, rangelands, lots, cover crop areas, woodlands, and harvested crop areas. Movable chicken coops that confine chickens and only allow them to range in the unit can qualify as Step 4 rated if all other standards are met. If the weather/climate conditions pose a threat to the chickens, they do not need to live continuously in an outdoor area, but they must have continuous access during daylight hours to a covered outdoor area that has natural light and foraging material (such as whole grains, hay, or straw). A covered outdoor area for use when the weather/climate conditions are a risk must have a minimum floor space that is 25 percent of the indoor floor space. The covered outdoor area must also have at least two different types of enrichment and cannot have slatted or wire floors. Acceptable enrichments include bales of straw or hay, raised platforms, provision of forages or brassicas (e.g., broccoli), and scattered grains. Perches, dust baths, and litter are also required. This requirement for a covered outdoor area for chickens only applies to Step 4 standards.

The standards for Step 4 require that at least 50 percent of the outdoor area is covered in vegetation and/or forage; litter does not qualify as forage. The chickens’ occupied outdoor area must encourage the birds to range and provide shade, natural or artificial, in each occupied outdoor area (with bushes and shrubs, shade cloth, A-frame structures, or perches).

Genetics and better breeds / limit on fast growth

For all step levels, breeds and genetic lines must be chosen for good leg health and low levels of mortality.* There is no limit on the rate of growth. This slightly exceeds the industry norm of using chickens that have been bred for rapid growth at the expense of the birds’ health and welfare.

* The standards specify what would be considered a “low level of mortality.” For Step 4, an intervention plan has to be implemented if flock mortality exceeds 0.35percent in a 24-hour period. This is exceeds the standard for Steps 1-3, which is 0.5percent mortality in a 24-hour period.

Slaughter

There are no slaughter standards for chickens for any of the step levels.

A closer look at the standards for pigs (pork)

Indoor space per growing pig

Minimum indoor space requirements vary according to the weight of the pigs and exceed the industry norm. Each group of pigs must have separate areas for lying, exercising, feeding, and defecating.

For nursery pigs up to 35 pounds, the minimum lying space requirement is at least 3.5 square feet per pig, and the lying space must be bedded and sheltered. This is the same space requirement as Step 3, but pigs in Step 4 have additional space outdoors. If the pigs are removed from pasture, there must be at least 1 square foot of outdoor exercise, feeding, and defecation area for each pig.

For nursery pigs between 36 pounds and 55 pounds, the minimum lying space requirement is at least 4.5 square feet per pig, and the lying space must be bedded and sheltered. This is the same space requirement as Step 3, but pigs in Step 4 have additional space outdoors. If the pigs are removed from pasture, there must be at least 1.5 square feet of outdoor area for exercise, feeding, and defecation for each pig.

For market pigs between 56 pounds and 112 pounds, the minimum lying space requirement is at least 5.25 square feet per pig. It must be bedded and sheltered. This is the same space requirement as Step 3, but pigs in Step 4 have additional space outdoors. If the pigs are removed from pasture, there must be an outdoor area of at least 1.75 square feet for each pig for exercise, feeding, and defecation.

For market pigs larger than 112 pounds, the minimum lying space per pig is at least 9 square feet, which must be bedded and sheltered. This is the same space requirement as Step 3, but pigs in Step 4 have additional space outdoors. If the pigs are removed from pasture, there must be at least 9 square feet of additional exercise, feeding, and defecation area for each pig and at least 6 square feet must be outdoors. The remaining square footage can be indoors or outdoors but does not need to be bedded.

For boars, the minimum space requirement is the same for all step levels. For boars less than 350 pounds, the minimum space requirement is 48 square feet per boar, and for boars more than 350 pounds, the minimum space requirement is 64 square feet per boar. This space includes the entire pen and areas for lying, exercise, feeding and defecation.

Crates for gestating and farrowing sows

Gestation crates and farrowing crates are prohibited for all step levels, a standard that exceeds the industry norm of housing pregnant sows (gestating sows) and sows with piglets (farrowing sows) in crates that are too small to allow the sow to turn around or move freely.

For farrowing sows and gilts, both farrowing pens (indoors) and farrowing huts (outdoors) must have a minimum space of 48 square feet, which must allow the sow to turn around and outstretch fully in the pen. This applies to steps 1 through 4.

For group farrowing, sows must have a minimum space of 48 square feet, and the space for farrowing must be a minimum of 35 square feet and cannot inhibit the sow from turning around and lying fully outstretched. This applies to steps 1 through 4.

Farrowing pens and huts must include a protected space for piglets, and proper nest building materials must be provided to sows a minimum of three days prior to the farrowing date. This applies to all step levels.

For gestating sows, the minimum lying space is 16 square feet and must be bedded. This applies to all step levels. If the gestating sows are removed from pasture, an additional area for exercise, feeding, and dunging must be 40 square feet. At least 20 square feet of it must be outdoors or on pasture but it does not need to be bedded. The remaining space can be indoors or outdoors and does not need to be bedded. This is the same as Step 3.

Clean bedding

The standards for bedding are the same for all step levels. All pig housing must have bedding that provides comfort, thermal protection, and cleanliness. The bedding must be maintained daily. Slatted floors cannot exceed more than 25 percent of the total area available to the pigs.

Indoor air / ammonia levels

The standards for indoor ammonia are the same for steps 1 through 4. (Step 5 and 5+ do not address ammonia because pigs live outdoors.) The standards state that an intervention plan designed to improve air quality must be implemented immediately if air quality levels exceed 20 ppm or a score of 2 on Global Animal Partnership’s air quality scale, which allows producers to use sensory evaluation to determine whether they should take action. On this scale, a score of 2 means the producer rates the odor as “distinct” and experiences watery eyes and/or coughing.

Environmental enrichment

Environmental enrichments are required for steps 2 through 4 (not Step 5 and 5+ since those pigs live mostly outdoors). Enrichments must be provided to gestating sows, replacement animals, sows and pigs from weaning throughout the growth period. Global Animal Partnership defines environmental enrichments as materials that are provided to animals to “add complexity to their environment, encourage the expression of natural behavior, and decrease the expression of abnormal and deleterious behavior.” Examples of indoor environmental enrichment include straw bales, hay, silage, wood chips, branches, whole crop peas and barley, compost, peat, or other natural materials.

Outdoor access

Access to an outdoor area that is at least 25 percent covered with vegetation is required. When the pasture is down to 25 percent vegetation, pigs are to be rotated to a different area of the pasture. All pigs over the age of 2 weeks must have continuous access to pasture, and all pigs must have continuous access to housing or shelter to ensure their thermal comfort is maintained.

Physical alterations

The standards prohibit tail docking for all step levels. This exceeds the industry norm of docking the tails of pigs to prevent aggressive tail biting, a problem that arises from various factors, including the animals’ close confinement, heat stress and cold stress, and boredom due to a barren environment. When tail biting occurs on GAP certified farms, the standards require the incident is promptly addressed, managed, and recorded.

De-tusking, teeth clipping, routine teeth grinding/filling, and nose ringing are also prohibited. However, there can be exceptions. If it’s necessary to trim tusks, it must be done without cutting into the sensitive pulp chamber or with the use of bolt cutters/chopping devices. While nose ringing of market animals (pigs raised to be slaughtered) is prohibited, nose ringing is permitted in sows (female pigs that give birth to pigs raised for slaughter) that are given access to pasture in areas where the soil structure can be easily damaged. If the sow loses the ring, it cannot be replaced. Slap marking, which is a temporary tattoo, and tattooing are acceptable for identification. No more than two ear tags per animal are permitted, one in each ear. For pigs, ear notching can only be conducted before 10 days of age.

For steps 1 through 4, piglets must be castrated before the 10 days of age, where the age is calculated from the farrowing date of the sow. Piglets can only be castrated with a sharp, clean instrument (scalpel, razor blade, or surgical scissors). Therefore, the use of side cutters or any instrument not designed to cut soft tissue is prohibited. Global Animal Partnership strongly encourages the administration of anesthetic and postoperative analgesia to help the animal with pain and discomfort, but this is not required.

Blunt force trauma

The use of blunt force trauma—a sharp blow to the head that kills young piglets by destroying the skull and brain tissue—is prohibited as a method of euthanasia for all step levels.

Slaughter

While there are no slaughter standards for beef and chickens, the standards for all step levels require that pigs are slaughtered at a facility that has passed and holds a current third-party animal welfare audit based on the American Meat Institute’s Recommended Animal Handling Guidelines and Audit Guide. Slaughter plants must pass all core criteria and all secondary criteria with a minimum overall score of 90 percent. An effective stun/kill rate of at least 95 percent on the first attempt is required, which means the standards allow up to 5 percent of the animals to suffer between a first failed attempt and the second or successful attempt, whichever comes later.

A closer look at the standards for cattle (beef)

Pasture

All cattle have to spend at least three quarters of their lives on a range or pasture and can only be removed for extreme weather  or seasonal conditions that compromise the cattle’s welfare. Removing an animal for more than four months in a single year or more than a quarter of the animal’s life is prohibited.

Pain relief during castration

For all steps for which castration is allowed, Global Animal Partnership suggests the procedure is done with an emasculator ring and before the animals are 7 days old. For Step 2, 3, and 4, castration of calves must occur before the animals are 3 months of age. The only methods allowed are compression under rings, surgery, and a burdizzo clamp, which crushes the blood vessels, interrupting the blood supply to the testicles. Castration is not allowed for Step 5 and 5+.

Hot iron branding

Face branding is prohibited; branding on other parts of the body is permitted for Steps 1 through 4.

Branding is one of the methods used to identify cattle. Industry guidelines recommend branding on the hip area and state that cattle should never be branded on the face or jaw. While the practice of branding is becoming less common and other methods of identification are increasing in popularity, the most recent survey data, from 2008, show that nearly 40 percent of cattle are still marked by branding.

Disbudding

Routine tipping of the horns, which is the removal of the tips of the horns, and complete removal of fully grown horns are both prohibited. Disbudding, or cauterizing horn buds before they grow into horns, is only allowed before 6 weeks of age. Tipping is permitted only when “it is necessary to prevent the horns from growing into the animal’s head or in response to behavior that puts other animals or handlers at risk.” This is the same as Steps 1 through 4. Disbudding is prohibited for Step 5 and 5+.

Slaughter

There are no slaughter standards for beef at any step level.

A closer look at the standards for: 

The requirements below are the same for all step levels.

Antibiotic use

Global Animal Partnership standards prohibit the use of antibiotics, except for chickens, for all step levels. If a market animal becomes sick and must be treated with antibiotics, that animal must be identified and removed from the Global Animal Partnership program. The standards also state that sick or injured animals must receive immediate individual treatment designed to minimize pain and suffering.

To protect public health and combat the global threat of antibiotic resistance, antibiotics in animal agriculture should only be used to treat diagnosed disease. It is the industry norm to use antibiotics for disease prevention and control, as well as for disease treatment. The Global Animal Partnership standards exceed the industry norm for antibiotic use, except for chickens.

Drugs for growth promotion

Growth hormones (beef only)

Growth hormones are prohibited for all step levels. The FDA allows beef cattle to be implanted with growth hormones, so the GAP standards exceed the industry norm for growth hormone use.

However, the Global Animal Partnership standards do not prohibit the use of hormones such as oxytocin for reproductive purposes.

Beta agonists (beef, pork, turkey)

Beta agonists, which are drugs used for growth promotion, are prohibited for all step levels.

The FDA allows growth promoting drugs, such as beta agonists, to be added to feed for beef cattle, pigs, and turkeys. By prohibiting beta agonists in feed, the GAP standards exceed the industry norm.

Animal by-products in feed

For all step levels, animal by-products are prohibited in feed, including mammalian and avian-derived protein.

For chickens, turkeys, and pigs, the use of mammalian, avian, fish, and fish by-products is prohibited. For beef/cattle, mammalian and avian by-products and wastes (with the exception of milk and milk-derived products) are prohibited. By-products include animal waste and products derived from slaughter, including meat, bones, blood, fat, and feathers. For fish, this includes whole fish, parts of fish, fish meal, fish by-products from the processing industry, and other aquatic species and/or products. It does not include seaweed or oyster shell.

The FDA prohibits ruminant-derived protein sources in dairy cow and beef cattle feed, but it allows pig and poultry slaughter waste products, poultry litter, and feces. In pig and poultry feed, the FDA does not restrict the use of slaughterhouse waste products and waste from livestock operations, such as poultry litter and feces. The GAP standards exceed the industry norm for animal by-products in feed.

GMOs in feed

GMOs are allowed in animal feed. This applies to all step levels.

CONSUMER REPORTS EVALUATION

How meaningful is this label? 

In our analysis, we found that the standards for Step 4 fall short in meeting the “pasture-centered” claim for chickens.

For chickens, the standards do not define “pasture” and do not include a specific requirement for access to pasture. Rather, the standards require access to an outdoor area that “can include pastures, rangelands, lots, cover crop areas, and harvested crop areas.” There are no minimum space requirements, only a requirement that 50 percent of the outdoor area be covered with vegetation and/or forage.  

For pigs, the standards do not define “pasture” but do require that all pigs over two weeks of age are given continuous access to pasture. The Step 4 standards require that pigs are rotated once the pasture is down to 25 percent coverage with vegetation.

For beef, the standards require that animals spend at least three quarters of their lives on pasture when seasonal conditions permit, and animals cannot be removed from pasture for more than four months in any one year or for more than a quarter of the animal’s life. Pasture is not defined, other than to state that at least 50 percent of the occupied area has to be covered with vegetation.

For all step levels, except for chickens, the use of antibiotics is prohibited (except to treat sick animals, which cannot be sold with the Global Animal Partnership label). Growth hormones, growth promoting drugs, and animal by-products in feed are prohibited for all step levels and all species.

Is the label verified?

Yes

Farms are inspected by a third-party certification agency every 15 months to ensure that, over time, farms will be inspected in all four seasons. The policy manual for Global Animal Partnership does not mention unannounced inspections as part of the verification process, and Global Animal Partnership did not respond to our inquiries.

Global Animal Partnership works with three certification agencies: IMI Global, EarthClaims, LLC, and AUS-MEAT Limited (for beef in Australia).

Is the meaning of the label consistent?

While the standards are generally consistent across species, there is an inconsistency: Beef, turkey, pork, and bison meat from animals that were treated with antibiotics cannot be sold as GAP certified under any step, while all steps for chickens allow the therapeutic use of antibiotics.*

*GAP certified meat treated with antibiotics would not be sold at Whole Foods Market stores, which prohibit all antibiotic use. GAP products found outside of Whole Foods follow the antibiotic use described above.

Are the label standards publicly available?

Yes. The standards are posted on the website.

www.globalanimalpartnership.org/5-step-animal-welfare-rating-program/standards

Is information about the organization publicly available?

Yes

Board of Directors: Members of the Board of Directors are listed on its website, including the director’s affiliations.

Financial Information: The organization is a not-for-profit 501(c)(3) organization, and its IRS Form 990 is publicly available.

Is the organization free from conflict of interest?

Unknown.

Standards development: Several members of the organization’s Board of Directors are either GAP-certified livestock producers or employees of companies that sell GAP-certified products. The organization’s bylaws were not shared with Consumer Reports, so we could not verify whether board members with a conflict of interest vote on the standards.

Verification: The organization’s bylaws were not shared with Consumer Reports, so we could not verify whether there is a conflict of interest policy for certifiers.

Was the label developed with broad public and industry input?

Yes.

Standards development: The standards are initially drafted by members of a scientific committee, which includes academics, producers, and other experts in the particular species. The standards are reviewed by invited experts from various stakeholder groups and posted online for public comment.

Standards updates: When changes to the standards are made, GAP distributes the draft to its participating producers and posts the draft on its website, inviting public comments. The draft is revised based on public comments before the board ratifies the changes.

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Global Animal Partnership Step 3 https://www.greenerchoices.org/global-animal-partnership-step-3/ https://www.greenerchoices.org/global-animal-partnership-step-3/#respond Fri, 05 Jun 2020 09:17:40 +0000 https://www.greenerchoices.org/?p=315

The Global Animal Partnership (GAP) certification program is comprised of a series of step levels, each corresponding to a set of animal welfare standards. The rigor of the standards increases with higher step levels. The Step 3 label means that the animals were raised on farms with improved living conditions and animal welfare practices. Chickens and pigs raised according to Step 3 standards have access to an outdoor space, but this space can be very small. The animals are also provided with materials, such as straw bales, forages, or scattered grains, which add complexity to the environment and encourage the expression of natural behaviors. There is no Step 3 for beef cattle.  For all step levels, the GAP standards set limits on indoor ammonia levels, prohibit routine drug use (including antibiotics), prohibit animal waste products in feed, and prohibit routine tail docking of pigs. The label is verified.

Is the label verified?

Yes

Is the meaning of the label consistent?

Partially

Are the label standards publicly available?

Yes

Is information about the organization publicly available?

Yes

Is the organization free from conflict of interest?

Unknown

Was the label developed with broad public and industry input?

Yes

This label can be found on: Chicken, pork, turkey, sheep, goat, bison

(There is no Step 3 for beef cattle.)

ORGANIZATION: Global Animal Partnership

url: www.globalanimalpartnership.org

LABEL STANDARDS: www.globalanimalpartnership.org/5-step-animal-welfare-rating-program/standards

What this label means

The label means that the animals were raised on farms that were verified to meet the farm animal welfare standards of Global Animal Partnership, a non-profit organization that says it “promotes and facilitates continuous improvement in animal agriculture, encourages animal welfare friendly farming practices, and informs consumers about the animal farming systems they choose to support.”

The Global Animal Partnership program uses six tiers, or steps, each representing a different set of standards for how animals are raised on the farm. The step level that is achieved is indicated on the label. Step 1 is the lowest rating; Step 5+ is the highest. Higher step levels signify that higher standards of animal welfare were met.

For Step 3, the claim on the label is “enhanced outdoor access.”

In our analysis, we found that the standards for Step 3 fall short in meeting what consumers might expect from an “enhanced outdoor access” marketing claim, since the minimum space requirement for the enhanced outdoor area for chickens and pigs is very small.

There are benefits to choosing meat and poultry with Global Animal Partnership certification: For example, the standards for all step levels set limits on indoor ammonia levels and prohibit routine drug use, animal waste products in feed, and routine tail docking of pigs. Also, Step 3 offers at least some access to the outdoors, which is better than none. (No outdoor access is required for Steps 1 and 2.)

The benefits of choosing Step 3 over 1 and 2 include higher space requirements for chickens and some outdoor access for chickens and pigs (although the outdoor space is small). For chickens, the requirement for continuous darkness at night is 8 hours instead of 6 in Steps 1 and 2. For beef, there is no Step 3.

We take a closer look at some of the requirements in the standards for some of the species that can be certified. Note that this is a summary; to read the standards in their entirety, click on the links above.

A closer look at the standards for broilers (chicken) 

Indoor space per bird

The Step 3 indoor space requirement for a chicken is roughly 10.9 by 10.97 inches for a 5-pound bird. This is an improvement over steps 1 and 2.

The Step 3 minimum indoor space requirement is roughly 0.83 square feet per 5-pound bird. (The standards state that the stocking density should not exceed 6.0 pounds of chicken per square foot.) This is a slight, 23.9 percent increase over the industry norm, which gives each 5-pound chicken roughly 9.6 by 10 inches (0.67 square feet).

For housing, chickens must be given enough space to express natural behaviors, which include standing, turning around, and preening (using the beak to straighten and clean feathers) without touching another bird.

Clean litter

The standards for clean litter are the same for all step levels. Floors of all houses, including mobile houses that are stationary for more than three days, must be covered with non-toxic, fibrous, and friable litter. Up to 12 inches in width of caked litter would be allowed directly under water lines. Litter must be of quality and quantity to provide a comfortable environment and allow for dustbathing behavior. This requirement exceeds the industry norm.

Indoor air / Ammonia levels

The standards for ammonia are the same for all step levels. The standards state that an intervention plan designed to improve air quality must be implemented immediately if air quality levels exceed 20 ppm or a score of 2 on Global Animal Partnership’s air quality scale, which allows producers to use sensory evaluation to determine whether they should take action. On this scale, a score of 2 means the producer rates the odor as “distinct” and experiences watery eyes and/or coughing. (The human nose can detect the smell of ammonia at around 5 ppm.)

Lighting

The standards for Step 3 require that chickens experience a daily minimum of eight hours of continuous darkness throughout their lives. This is an improvement over steps 1 and 2, which require six hours of darkness. All step levels exceed the industry norm of only four hours of continuous darkness per 24-hour cycle after the first four weeks of life.

Environmental enrichment

To qualify chickens as Step 3 rated (as well as Step 4), they must have at least two types of enrichment, and it must be provided to them by the time they are 10 days old. Global Animal Partnership defines environmental enrichments as material that are provided to animals to “add complexity to their environment, encourage the expression of natural behavior, and decrease the expression of abnormal and deleterious behavior.” Examples of acceptable enrichments include bales of straw of hay, raised platforms, provision of forages or brassicas (e.g., broccoli), and scattered grains. Steps 3 and 4 are an improvement over Step 1, which requires no enrichment, and Step 2, which requires one type of indoor environmental enrichment. Step 3 exceeds the industry norm. (Chickens raised in Steps 5 and 5+ live mostly outdoors so indoor environmental enrichment is not needed.)

Outdoor access

Outdoor access is required for Step 3 through 5+; however, for Step 3, the minimum outdoor space requirement is very small. This is an improvement over steps 1 and 2, which do not require outdoor access.

Beginning at 4 weeks of age for chickens and 7 weeks for turkeys, continuous access to the outdoors during daylight hours must be available. The only exception is if climatic conditions pose a risk to the poultry’s welfare. (Those climatic conditions are not defined.) The openings from the indoor housing to the outdoor area must allow poultry to have continuous access during daylight hours. Any chickens slaughtered before the age of 28 days must have been given access to the outdoors during daylight hours for at least two weeks. The standards also specify that chickens must be managed and maintained to minimize parasites and disease, which means the land should be rotated and rested between flocks.

The space requirement for outdoor areas must be equal to or greater than 25 percent of the total indoor floor space. In order to achieve Step 3 rated poultry, at least 25 percent of the outdoor area must be covered in vegetation and/or forage; litter does not qualify as forage. The chickens’ occupied outdoor area must encourage the birds to range and provide shade, natural or artificial, in each occupied outdoor area (with bushes and shrubs, shade cloth, A-frame structures, or perches).

Genetics and better breeds / limit on fast growth

For all step levels, breeds and genetic lines must be chosen for good leg health and low levels of mortality.* There is no limit on the rate of growth. This slightly exceeds the industry norm of using chickens that have been bred for rapid growth at the expense of the birds’ health and welfare.

* The standards specify what would be considered a “low level of mortality.” For Step 4, an intervention plan has to be implemented if flock mortality exceeds 0.35percent in a 24-hour period. This is exceeds the standard for Steps 1-3, which is 0.5percent mortality in a 24-hour period.

Slaughter

There are no slaughter standards for chickens for any of the step levels.

A closer look at the standards for pigs (pork)

Indoor space per growing pig

Minimum indoor space requirements vary according to the weight of the pigs and exceed the industry norm. Each group of pigs must have separate areas for lying, exercising, feeding, and defecating.

For nursery pigs up to 35 pounds, the minimum space requirement is the same as for Steps 1 and 2: 4.5 square feet or 0.42 square meters per pig and at least 3.5 of the 4.5 square feet  must be bedded and sheltered. For Step 3, the remaining square foot has to be outdoors.

For nursery pigs between 36 and 55 pounds, the minimum space requirement is the same as for Steps 1 and 2: 6 square feet2 or 0.56 square meters per pig and at least 4.5 of the 6 square feet must be bedded and sheltered. For Step 3, the remaining 1.5 square feet must be outdoors.

For market pigs between 56 and 112 pounds, the minimum space requirement is the same as Steps 1-2: 7 square feet or 0.65 square meters per pig and at least 5.25 of the 7 square feet must be bedded and sheltered. For Step 3, the remaining 1.75 square feet must be outdoors.

For market pigs larger than 112 pounds, the minimum space requirement is 18 square feet or 1.7 square meters per pig, and at least 9 of the 12 square feet must be bedded and sheltered, while the other percentage may be either indoors or outdoors. This is larger than that required for Steps 1 and 2 but not as large as the higher steps’ minimum requirement.

The minimum space requirement for boars is the same for all step levels. For boars less than 350 pounds, the minimum space requirement is 48 square feet or 4.5 square meters per boar; for boars more than 350 pounds, the minimum space requirement per animal is 64 square feet or 5.9 square meters. This space includes the entire pen and areas for lying, exercise, feeding, and defecation.

Crates for gestating and farrowing sows

Gestation crates and farrowing crates are prohibited for all step levels, a standard that exceeds the industry norm of housing pregnant sows (gestating sows) and sows with piglets (farrowing sows) in crates that are too small to allow the animal to turn around or move freely.

For farrowing sows and gilts, both farrowing pens (indoors) and farrowing huts (outdoors) must have a minimum space of 48 square feet which must allow the sow to turn around completely and to be fully outstretched in the pen. This applies to steps 1 through 4.

For group farrowing, sows must have a minimum space of 48 square feet,and the space for farrowing must be at least 35 square feet and cannot inhibit the sow from turning around and lying fully outstretched. This applies to steps 1 through 4.

Farrowing pens and huts must include a protected space for piglets, and proper nest-building materials must be provided to sows at least three days prior to the farrowing date. This applies to all step levels.

For gestating sows, the minimum lying space is 16 square feet and must be bedded. This applies to all step levels. For Step 3 specifically, an additional area for exercise, feeding, and defecation space must measure at least 40 square feet. At least 20 square feet must be outdoors, but not necessarily bedded. The remaining space can be indoors or outdoors and does not need to be bedded.

Clean bedding

The standards for bedding are the same for all step levels: All pig housing must have bedding that provides comfort, thermal protection, and cleanliness. The bedding must be maintained daily. Slatted floors cannot exceed more than 25 percent of the total area available to the pigs.

Indoor air / ammonia levels

The standards for indoor ammonia are the same for steps 1 through 4. (Steps 5 and 5+ do not address ammonia because those pigs live outdoors.) The standards state that an intervention plan designed to improve air quality must be implemented immediately if air quality levels exceed 20 ppm or a score of 2 on Global Animal Partnership’s air quality scale, which allows producers to use sensory evaluation to determine whether they should take action. On this scale, a score of 2 means the producer rates the odor as “distinct” and experiences watery eyes and/or coughing.

Environmental enrichment

Environmental enrichments are required for steps 2 through 4 (not 5 and 5+, since those pigs live mostly outdoors). Enrichments must be provided to gestating sows, replacement animals, sows, and pigs from weaning throughout the growth period. Global Animal Partnership defines environmental enrichments as material that are provided to animals to “add complexity to their environment, encourage the expression of natural behavior, and decrease the expression of abnormal and deleterious behavior.” Examples of indoor environmental enrichment include straw bales, hay, silage, wood chips, branches, whole crop peas and barley, compost, peat, or other natural materials.

Outdoor access

The standards for Step 3 require a small outdoor space: 6 square feet of outdoor space for a growing pig weighing more than 112 pounds. Outdoor access is not required for Step 1 and Step 2.

Physical alterations

The standards prohibit tail docking for all step levels. This exceeds the industry norm of docking the tails of pigs to prevent aggressive tail biting, a problem that arises from various factors, including the animals’ close confinement, heat stress and cold stress, and boredom due to a barren environment. When tail biting occurs on GAP certified farms, the standards require that the incident is promptly addressed, managed, and recorded.

De-tusking, teeth clipping, routine teeth grinding/filling, and nose ringing are also prohibited. Exceptions are possible, however: If it’s necessary to trim tusks, it must be done without cutting into the sensitive pulp chamber and without the use of bolt cutters/chopping devices. Nose ringing is prohibited in market animals, or pigs raised for slaughter. But the procedure is allowed in certain cases: for example, sows (female pigs that give birth to those raised for slaughter) can cause damage to soil structures in certain areas of pasture; in those instances, nose ringing is permissible. If the sow loses the ring, it cannot be replaced. Slap marking (a temporary tattoo) and tattooing are acceptable for identification. No more than two ear tags per animal are permitted, one in each ear. For pigs, ear notching must be conducted before 10 days of age.

For steps 1 through 4, piglets must be castrated before 10 days of age, where the age is calculated from the farrowing date of the sow. Piglets can only be castrated using a sharp, clean instrument, such as a scalpel, razor blade, or surgical scissors. The use of side cutters or any instrument not designed to cut soft tissue is prohibited. Global Animal Partnership strongly encourages the administration of anesthetic and postoperative analgesia to ease pain and discomfort, but this is not required.

Blunt force trauma

The use of blunt force trauma—a sharp blow to the head that kills young piglets by destroying the skull and brain tissue—is prohibited as a method of euthanasia for all step levels.

Slaughter

While there are no slaughter standards for beef and chickens, the standards for all step levels require that pigs are slaughtered at a facility that has passed and holds a current third-party animal welfare audit based on the American Meat Institute’s Recommended Animal Handling Guidelines and Audit Guide. Slaughter plants must pass all core criteria and all secondary criteria with a minimum overall score of 90 percent. An effective stun/kill rate of at least 95 percent on the first attempt is required, which means the standards allow up to 5 percent of the animals to suffer between a first failed attempt and the second or successful attempt, whichever comes later.

A closer look at the standards for cattle (beef)

There is no Step 3 for beef cattle.

A closer look at the standards for: 

The requirements below are the same for all step levels. Antibiotic use

Global Animal Partnership standards prohibit the use of antibiotics, except for chickens, for all step levels. If a market animal becomes sick and must be treated with antibiotics, that animal must be identified and removed from the Global Animal Partnership program. The standards also state that sick or injured animals must receive immediate individual treatment designed to minimize pain and suffering.

To protect public health and combat the global threat of antibiotic resistance, antibiotics in animal agriculture should only be used to treat diagnosed disease. It is the industry norm to use antibiotics for disease prevention and control, as well as for disease treatment. The Global Animal Partnership standards exceed the industry norm for antibiotic use, except for chickens.

Drugs for growth promotion

Growth hormones (beef only)

Growth hormones are prohibited for all step levels. The FDA allows beef cattle to be implanted with growth hormones, so the GAP standards exceed the industry norm for growth hormone use.

However, the Global Animal Partnership standards do not prohibit the use of hormones such as oxytocin for reproductive purposes.

Beta agonists (beef, pork, turkey)

Beta agonists, which are drugs used for growth promotion, are prohibited for all step levels.

The FDA allows growth promoting drugs, such as beta agonists, to be added to feed for beef cattle, pigs, and turkeys. By prohibiting beta agonists in feed, the GAP standards exceed the industry norm.

Animal by-products in feed

For all step levels, animal by-products are prohibited in feed, including mammalian and avian-derived protein.

For chickens, turkeys, and pigs, the use of mammalian, avian, fish, and fish by-products is prohibited. For beef/cattle, mammalian and avian by-products and wastes (with the exception of milk and milk-derived products) are prohibited. By-products include animal waste and products derived from slaughter, including meat, bones, blood, fat, and feathers. For fish, this includes whole fish, parts of fish, fish meal, fish by-products from the processing industry, and other aquatic species and/or products. It does not include seaweed or oyster shell.

The FDA prohibits ruminant-derived protein sources in dairy cow and beef cattle feed, but it allows pig and poultry slaughter waste products, poultry litter, and feces. In pig and poultry feed, the FDA does not restrict the use of slaughterhouse waste products and waste from livestock operations, such as poultry litter and feces. The GAP standards exceed the industry norm for animal by-products in feed.

GMOs in feed

GMOs are allowed in animal feed. This applies to all step levels.

CONSUMER REPORTS EVALUATION

How meaningful is this label? 

In our analysis, we found that the standards for Step 3 fall short in meeting what consumers would expect from an “enhanced outdoor access” claim.

For chickens, the requirements would allow a flock of 20,000 chickens to be contained in an enhanced outdoor area (covered with vegetation and/or forage) as small as one-third the size of a standard tennis court. That’s less than one quarter the size of a standard basketball court.

More on outdoor space requirement for chickens: Step 3 for chickens requires that the outdoor space is equal to or greater than 25 percent of the indoor space. Since the minimum indoor space requirement is 0.83 square feet for a 5-pound bird, this means that the minimum outdoor space requirement is 0.20 square feet per bird. That’s approximately 5 by 6 inches of outdoor space per chicken. The Step 3 standard requires that 25 percent of the outdoor space is covered with vegetation and/or forage, which means that each chicken is provided only 0.05 square feet of vegetated or enhanced outdoor space. That is an area of approximately 2.9 by 2.5 inches per 5-pound chicken. In a flock of 20,000 birds, the area of outdoor space with vegetation and/or forage could be 1,000 square feet. For comparison, a standard tennis court is 2,808 square feet,and a standard basketball court is 4,700 square feet.

For pigs, the minimum outdoor space requirement for a 100-pound pig is no larger than two letter-sized pieces of paper. None of this space needs to be covered with vegetation.

More on outdoor space requirement for pigs: For a nursery pig of up to 35 pounds, the standards require 4.5 square feet of space, which is to be divided between the indoor and the outdoor space. Since the standard requires an indoor space of at least 3.5 square feet, that leaves an outdoor space of at least 1 square foot, which is 12 by 12 inches. For a market pig between 56 and 112 pounds, the minimum space requirement is 7 square feet, which is to be divided between the indoor and the outdoor space. Since the indoor space has to be at least 5.25 square feet, that leaves a minimum outdoor space requirement of 1.75 square feet, which is approximately 252 square inches. This is approximately 16 by 16 inches. For comparison, a letter-sized piece of paper measure roughly 8.5 by 11 inches.

There is no Step 3 for beef cattle.

For all step levels, except for chickens, the use of antibiotics is prohibited (except to treat sick animals, which can then not be sold with the Global Animal Partnership label). Growth hormones, growth promoting drugs, and animal by-products in feed are prohibited for all step levels and all species.

Is the label verified?

Yes

Farms are inspected by a third-party certification agency every 15 months to ensure that, over time, farms will be inspected in all four seasons. The policy manual for Global Animal Partnership does not mention unannounced inspections as part of the verification process, and Global Animal Partnership did not respond to our inquiries.

Global Animal Partnership works with three certification agencies: IMI Global, EarthClaims, LLC, and AUS-MEAT Limited (for beef in Australia).

Is the meaning of the label consistent?

While the standards are generally consistent across species, there is an inconsistency: Beef, turkey, pork, and bison meat from animals that were treated with antibiotics cannot be sold as GAP certified under any step, while all steps for chickens allow the therapeutic use of antibiotics.*

*GAP certified meat treated with antibiotics would not be sold at Whole Foods Market stores, which prohibit all antibiotic use. GAP products found outside of Whole Foods follow the antibiotic use described above.

Are the label standards publicly available?

Yes. The standards are posted on the website.

www.globalanimalpartnership.org/5-step-animal-welfare-rating-program/standards

Is information about the organization publicly available?

Yes

Board of Directors: Members of the Board of Directors are listed on its website, including the director’s affiliations.

Financial Information: The organization is a not-for-profit 501(c)(3) organization, and its IRS Form 990 is publicly available.

Is the organization free from conflict of interest?

Unknown.

Standards development: Several members of the organization’s Board of Directors are either GAP-certified livestock producers or employees of companies that sell GAP-certified products. The organization’s bylaws were not shared with Consumer Reports, so we could not verify whether board members with a conflict of interest vote on the standards.

Verification: The organization’s bylaws were not shared with Consumer Reports, so we could not verify whether there is a conflict of interest policy for certifiers.

Was the label developed with broad public and industry input?

Yes.

Standards development: The standards are initially drafted by members of a scientific committee, which includes academics, producers, and other experts in the particular species. The standards are reviewed by invited experts from various stakeholder groups and posted online for public comment.

Standards updates: When changes to the standards are made, GAP distributes the draft to its participating producers and posts the draft on its website, inviting public comments. The draft is revised based on public comments before the board ratifies the changes.

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NOFA-NY Certified 100% Grass Fed https://www.greenerchoices.org/nofa-ny-certified-100-grassfed/ https://www.greenerchoices.org/nofa-ny-certified-100-grassfed/#respond Fri, 05 Jun 2020 08:04:40 +0000 https://www.greenerchoices.org/?p=312

The NOFA-NY Certified 100% Grass Fed label is highly meaningful and verified. It means that the animals used to produce meat and dairy were raised on certified organic farms, and in addition, meat animals must be fed 100% grass or grass-based feed for the entire life of the animal with the exception of milk prior to weaning. Dairy cows must be managed on 100% grass or grass-based feeds for at least 90 days before being eligible to sell milk as NOFA-NY Certified 100% Grass Fed.

Is the label verified?

Yes

Is the meaning of the label consistent?

Yes

Are the label standards publicly available?

Yes

Is information about the organization publicly available?

Yes

Is the organization free from conflict of interest?

Yes

Was the label developed with broad public and industry input?

Yes

This label can be found on: beef, dairy products

PROGRAM NAME: NOFA-NY 100% Grass Fed

ORGANIZATION: Northeast Organic Farming Association of New York

url: www.nofany.org

LABEL STANDARDS: https://www.nofany.org/certification/forms-documents/grass-fed

What this label means 

The label means that the animals used to produce meat and dairy were raised on certified organic farms, and in addition, meat animals must be fed 100% grass or grass-based feed for the entire life of the animal with the exception of milk prior to weaning. Dairy cows must be managed on 100% grass or grass-based feeds for at least 90 days before being eligible to sell milk as NOFA-NY Certified 100% Grass Fed.

The standards require that grazing and intake from pasture must be maximized as much as possible and animals must have continuous access to pasture during the growing season. Producers must have a pasture management plan in place to show pasture is being managed as a crop and is being rotated to allow for proper rest and regrowth before the animals are reintroduced to the area, and is managed in a way that does not degrade the soil or quality of the pasture and natural resources (with the exception of a “sacrifice area” during the non-growing season).

Animals have to be managed in accordance to the USDA organic standards, which means the animals cannot be treated with antibiotics or artificial hormones to promote growth. Organic standards also prohibit the use of synthetic herbicides and pesticides on pasture and crops. Genetically engineered crops, such as genetically engineered alfalfa (hay), are also prohibited. 

Why it matters 

Beef and dairy cattle are ruminants, and their digestive systems have evolved to digest high-fiber and low-starch grasses. They gain weight more rapidly when they are fed grain in addition to grass, which has become standard practice in the beef and dairy industries, but grain-feeding comes with a cost to the nutritional value of the meat and dairy they produce, and the animals’ digestive health.

Nutritional benefits. Studies suggest that there are important health benefits from consuming 100% grass‐fed meat and dairy compared with grain-fed meat and dairy. Studies have found that, compared to grain-fed alternatives, grass-fed meat contains lower levels of overall fat and higher levels of vitamins and antioxidants; grass-fed meat and dairy have also been found to have higher levels of omega-3 fatty acids, which appear to provide health benefits. 

Animal health benefits. Ruminants on a grass-based diet without grain are less likely to suffer from gastrointestinal disorders such as acidosis. With acute acidosis, the acidity level and glucose levels in the animal’s intestines increase markedly due to grain consumption, leading to damage to the intestinal wall or other health conditions. 

Another health effect of a high-grain diet for cattle is a higher rate of liver abscesses. For prevention of liver abscesses in grain-fed cattle, the FDA has approved numerous antibiotics that can be added to cattle feed – the same grain-based feed that is often contributing to the abscesses in the first place. Antibiotics approved for this purpose include the critically important antibiotics tylosin, ceftiofur, virginiamycin and chlortetracycline. A sustainable way to prevent liver abscesses is to promote healthy animals with a species-appropriate diet of grass and forage.

CONSUMER REPORTS EVALUATION

How meaningful is this label? 

Highly Meaningful.

This label combines organic certification with verification that the animal’s diet consisted of 100% pasture and forage, with no grain, for the entirety of a meat animal’s life and for at least 90 days prior to milking for a dairy cow.

It is especially important to look for verification of “Grass Fed” claims on dairy. The Food and Drug Administration (FDA) regulates labeling on dairy products, and does not have a regulatory definition for the grass fed claim. Dairy products can be labeled “grass fed” without verification, and companies can make “grass fed” claims when the cows’ diet consisted of some grass, but 100% grass-based diet is not required.  A verified “Grass Fed” label, such as NOFA-NY Certified 100% Grass Fed, is therefore especially important.

Is the label verified?

Yes.

An annual inspection is required and is conducted together with the annual inspection required for organic certification.

Is the meaning of the label consistent?

Yes. 

Are the label standards publicly available?

Yes.

Standards are available on the NOFA-NY website: https://www.nofany.org/files/NOFA-NY_Grass_Fed_Certification_Manual.v2.pdf

Is information about the organization publicly available?

Yes.

Board of Directors: Yes. A list of the members of the Board of Directors, and their affiliations, is available on the website.

Financial information: Yes. Financial information for NOFA-NY is publicly available.

Is the organization free from conflict of interest?

Yes.

Standards development: Yes. Final approval of standards is granted by the Management Committee, which is free from conflict of interest.

Verification: Yes. NOFA-NY has a comprehensive conflict of interest policy that excludes persons with a conflict of interest from the certification and verification process.

Was the label developed with broad public and industry input?

Yes.

Standards development: The standards were developed by the NOFA-NY Grass Fed Certification Committee through examination of other existing grass fed certification programs, market research, and consultation with knowledgeable industry grass fed specialists. Grass fed producers were also consulted prior for input in the development of these standards.

Standards updates: Updates to the standards are proposed by the NOFA-NY certification staff, and approved or denied by the Management Committee. A draft of the standards is shared with grass fed producers for their input before finalizing and implementing changes. A draft is not posted on the website for public comment.

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“Raised Without Antibiotics” https://www.greenerchoices.org/raised-without-antibiotics-label-review/ https://www.greenerchoices.org/raised-without-antibiotics-label-review/#respond Fri, 05 Jun 2020 07:32:05 +0000 https://www.greenerchoices.org/?p=309 The “raised without antibiotics” claim on meat and poultry means that the animals were not given antibiotics in their feed, water or by injection. Choosing meat and poultry that is raised without antibiotics is an important step in helping address the public health crisis of antibiotic resistance. The U.S. Department of Agriculture performs a one-time review of a producer’s application for using the “raised without antibiotics” labeling claim, but requires no on-farm inspection or annual review. Eggs and dairy products, however, are regulated by the U.S. Food and Drug Administration and it has no established definition for this label and does no verification.Consumers should look for verified labels accompanying the “raised without antibiotics” claim.

Is the label verified?

Sometimes

Is the meaning of the label consistent?

No

Are the label standards publicly available?

Sometimes

Is information about the organization publicly available?

N/A

Is the organization free from conflict of interest?

N/A

Was the label developed with broad public and industry input?

Partially

This label can be found on: Meat, Poultry, Dairy, Eggs

ORGANIZATION: 

There is no single program or government agency behind the “raised without antibiotics” label.

For meat and poultry, the Food Safety and Inspection Service (FSIS) of the U.S. Department of Agriculture requires prior approval of all labels making a “raised without antibiotics” claim.

url: http://www.fsis.usda.gov/wps/portal/fsis/topics/regulatory-compliance/labeling

For eggs and dairy, the Food and Drug Administration (FDA) has authority over labeling claims, but does not have a regulatory definition for the “raised without antibiotics” claim.

PROGRAM NAME: 

There is no single program or government agency behind the “raised without antibiotics” label.

Labels on meat and poultry with a “raised without antibiotics” claim have to be approved by the Food Safety and Inspection Service (FSIS), an agency of the U.S. Department of Agriculture (USDA). FSIS staff performs a review of a one-time application and supporting documentation supplied by the company making the claim.

Labels on eggs and dairy are regulated by the Food and Drug Administration (FDA), and labels with a “raised without antibiotics” claim on eggs and dairy products do not need prior approval by the FDA. The FDA requires that labels on eggs and dairy are truthful and not misleading but does not have a regulatory definition for the “raised without antibiotics” labeling claim. 

LABEL STANDARDS: http://www.fsis.usda.gov/wps/wcm/connect/6fe3cd56-6809-4239-b7a2-bccb82a30588/RaisingClaims.pdf?MOD=AJPERES

What this label means 

Choosing animal products from animals raised without antibiotics is an important step consumers can take to help address the public health crisis of antibiotic resistance.

Meat and poultry. For the “raised without antibiotics” claim on meat and poultry labels, the USDA requires that source animals were not given antibiotics in their feed, water or by injection. This includes ionophores, which are recognized as antibiotics by the USDA (ionophores are antibiotics that are used only in animals, not in human medicine).

Dairy and eggs. For dairy product and egg labels, which are regulated by the Food and Drug Administration (FDA), label approval is not required. The FDA has no regulatory definition for “raised without antibiotics” labels. 

Why it matters 

The U.S. Centers for Disease Control and Prevention (CDC) estimates that every year antibiotic-resistant bacteria cause more than two million infections, killing at least 23,000 people. The rise of antibiotic resistance is driven by the overuse of antibiotics. The overuse of antibiotics can occur in many settings–doctor’s offices and hospitals, for example — but we cannot save antibiotics without meaningful changes to our food system, especially livestock and poultry production. This is because, in the U.S., the use of antibiotics in livestock and poultry production dwarfs their use in humans: about 80% of these drugs go to food animals.

In recent years, several companies that produce or sell meat and poultry have pledged to reduce or eliminate the use of antibiotics. Consumers can support these livestock and poultry producers by choosing meat and poultry with a “raised without antibiotics” label.

CONSUMER REPORTS EVALUATION

How meaningful is this label? 

Raising farm animals without antibiotics is an important practice to combat the public health crisis of antibiotic resistance. However, as a label, “raised without antibiotics” on its own is not meaningful on dairy and eggs, and somewhat meaningful on meat and poultry.

On dairy products and eggs, the “raised without antibiotics” claim is not verified and there is no common regulatory definition, so the label is not meaningful on its own.

On meat and poultry products, producers can make the “raised without antibiotics” claim after submitting a one-time label application with the USDA’s Food Safety and Inspection Service (FSIS), which includes required documentation to support the “raised without antibiotics” label claim. However, there is no requirement for on-farm inspections and no requirement for annual review or auditing of the producer’s records to ensure compliance. 

Look for the following additional labels or seals.

There are several meaningful labels that also address antibiotic use in their standards. If you see any of these labels together with the “raised without antibiotics” label, you can have much more trust in the claim.

USDA Process Verified

Producers making a “raised without antibiotics” claim can choose to have this claim verified by the Agricultural Marketing Service (AMS, an agency at the U.S. Department of Agriculture) through its Process Verified Program.

The Process Verified Program conducts a desk audit and an on-site audit for producers wishing to verify a “raised without antibiotics” label claim. For example, if a company wants to verify that they are raising their poultry without antibiotics, AMS auditors verify hatching, feed mill and on farm records and processes to ensure the company is meeting their processes for antibiotic use. Auditors visit the hatcheries to ensure poultry are not administered antibiotics, before hatching or after hatching. Auditors visit feed mills to ensure that feed does not include antibiotics, review ration and testing records and ensure that requirements included in the company’s Quality Manual are followed. Auditors visit the farm where the poultry are raised to determine if there are any antibiotics on-hand or in use. For new programs, initial approval after the desk audit and on-farm audit lasts for one year, with a surveillance audit conducted within six months of the initial on-site audit. After the first year, on-site audits are conducted annually.

Consumers should be careful to look for the USDA Process Verified seal accompanying a meaningful claim such as “raised without antibiotics” or “no antibiotics ever.” However, not all claims with a “USDA Process Verified” seal are equally valuable to consumers. The USDA Process Verified Program is a service that provides verification for claims and standards written by the company, which vary widely. For example, the program also verifies claims such as “no antibiotics used for growth promotion – antibiotics only used for treatment and prevention of disease.”  This claim offers little value to consumers since the use of antibiotics for growth promotion has been nearly entirely phased out.

USDA Organic

The USDA organic regulations prohibit the use of antibiotics in organic animal agriculture, with the exception of poultry prior to the second day of life (in hatcheries). But if a producer makes a “raised without antibiotics” claim on a certified organic poultry product, it means that the producer has submitted documentation to the USDA that antibiotics are not used at any point, including in the hatcheries. Other than in the hatcheries, the USDA Organic label signifies that a USDA-accredited certifier has verified the prohibition on antibiotic use after day 2. 

USDA Organic label review.

Animal Welfare Approved

The Animal Welfare Approved standards prohibit routine antibiotic use (antibiotics can only be used to treat sick animals). The label is verified.

Animal Welfare Approved label review.

Certified Humane by Humane Farm Animal Care (HFAC)

The Humane Farm Animal Care standards for the Certified Humane label prohibit the use of antibiotics for growth promotion and disease prevention (antibiotics can be used to treat sick animals) for beef and pork. For poultry, the label standards prohibit the use of antibiotics for growth promotion and disease prevention, except in hatcheries. Certified Humane does not have standards for hatcheries, so antibiotics such as gentamicin could be injected in eggs and day-old chicks. The label is verified.

American Grassfed

The American Grassfed label standards prohibit the use of antibiotics. The label is verified.

American Grassfed label review.

GAP Step 1-5+

For beef, pork, turkey, sheep, goat and bison, the use of antibiotics is prohibited. For chicken, the sub-therapeutic use of antibiotics is prohibited, but standards do not specify that antibiotics at therapeutic levels are prohibited for routine disease prevention and control. The label is verified.

Is the label verified?

U.S. Department of Agriculture (USDA) regulations require that labels on meat and poultry with a “raised without antibiotics” claim have to be approved by USDA staff. Companies submit a label application with supporting documentation that supports the “raised without antibiotics” claim. Supporting documentation that is needed includes:

  1. A detailed written description explaining controls for ensuring that the animals are not given antibiotics from birth to harvest or the period of raising being referenced by the claim;
  2. A signed and dated document describing how the animals are raised to support that the claims are not false or misleading;
  3. A written description of the product tracing and segregation mechanism from time of slaughter or further processing through packaging and wholesale or retail distribution; and
  4. A written description for the identification, control, and segregation of nonconforming animals/product (e.g., if beef raised without the use of antibiotics

need to be treated with antibiotics due to illness).

For poultry, the USDA requires a company making a “raised without antibiotics” labeling claim to submit a letter answering questions about whether eggs are injected with antibiotics prior to hatching. The USDA guidelines do not, however, state that this practice is prohibited.

USDA staff only conducts a one-time desk audit (reviewing paperwork submitted by the company) but does not conduct annual audits or on-farm inspections. Third-party certification of the claim is not required. As noted above, companies may choose to be verified through the USDA Process Verified Program, or can obtain other certification that addresses antibiotic use.

On eggs and dairy, the FDA requires that labeling be truthful and not misleading, but the agency does not require that the label be approved or verified and does not have a regulatory definition of the claim that companies have to meet. 

Is the meaning of the label consistent?

No.

On meat and poultry, the USDA allows variations of the claim, such as “raised without antibiotics the last 120 days” or “raised without subtherapeutic antibiotics.” The agency requires that the variation be indicated on the label but does not set a standard or define these variations.

The label can have different meanings on meat and poultry products, when it is regulated by the U.S. Department of Agriculture, than on dairy and eggs, when the label is regulated by the Food and Drug Administration and not defined. 

Are the label standards publicly available?

Sometimes.

For the label on meat and poultry, the USDA has a document with labeling guidelines, which is publicly available.

The FDA does not have a formal rule or publicly available guidelines for the label on dairy and eggs. 

Is information about the organization publicly available?

N/A. There is no single program or government agency behind the “raised without antibiotics” label.

Is the organization free from conflict of interest?

N/A. There is no single program or government agency behind the “raised without antibiotics” label.

Was the label developed with broad public and industry input?

Partially for meat and poultry; the USDA accepts comments from the public on its labeling guidelines, which include guidelines for the “raised without antibiotics” labeling claim. However, the USDA allows variations of the claim, such as “raised without subtherapeutic antibiotics” which were not developed with broad public and industry input.

No for dairy and eggs; the FDA has no regulatory definition for the “raised without antibiotics” label on dairy and eggs.

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“Natural” https://www.greenerchoices.org/natural-label-review/ https://www.greenerchoices.org/natural-label-review/#respond Thu, 04 Jun 2020 21:36:17 +0000 https://www.greenerchoices.org/?p=304 Not Meaningful

The “natural” label is not verified and is not meaningful. There are no consistent standards to ensure that the label means what it implies to consumers: that the food was produced without chemical fertilizers, synthetic pesticides, genetically engineered crops, chemical processing aids, and artificial ingredients. Each company can use its own definition, and definitions vary widely. Government agencies only provide guidance, not regulations, for companies using the “natural” claim.

Is the label verified?

No

Is the meaning of the label consistent?

No

Are the label standards publicly available?

No

Is information about the organization publicly available?

No

Is the organization free from conflict of interest?

N/A

Was the label developed with broad public and industry input?

No

This label can be found on: The “natural” label claim can be found on foods and beverages. 

ORGANIZATION: There is no organization behind the label. Each company can determine its own definition for the “natural” labeling claim.

LABEL STANDARDS: There are no standards. The USDA provides guidance on “natural” labeling on meat and poultry, but there is no formal rule.

What this label means

Food and Drug Administration (FDA): The FDA regulates processed food, produce and most fish, but the agency does not have a formal rule to ensure the consistent and meaningful use of the “natural” labeling claim.

In November 2015, FDA requested comment from the public on whether the agency should define, through rulemaking, the term “natural” in food labeling. There is currently no formal definition and no rule, no verification and virtually no oversight and enforcement.

In its notification of request for comments, the FDA stated that its current policy is to not restrict the use of the term “natural” on foods and beverages, except for added color, synthetic substances and flavors, and that it considers “natural” to mean nothing artificial or synthetic is included in, or has been added to, the product that would not normally be expected to be there. The FDA’s policy for “natural” labeling does not address food production methods, such as the use of chemical fertilizers, chemical pesticides, genetically engineered organisms (GMOs), nanopesticides, nanofertilizers and synthetic processing aids. 

Even the current policy for “natural” labeling is not adequately enforced, since we have found plenty of foods with the “natural” label in the marketplace that contain artificial ingredients.

US Department of Agriculture (USDA): The US Department of Agriculture (USDA) regulates labeling claims on meat and poultry. The agency defines the “natural” claim in its “Food Standards and Labeling Policy Book,” which provides guidance but is not a formal rule. The Policy Book defines “natural claims” as follows:

The term “natural” may be used on labeling for meat products and poultry products, provided the applicant for such labeling demonstrates that:

the product does not contain any artificial flavor or flavoring, coloring ingredient, or chemical preservative (as defined in 21 CFR 101.22), or any other artificial or synthetic ingredient; and (2) the product and its ingredients are not more than minimally processed. 

The USDA’s guidelines define “minimal processing” as follows:

Minimal processing may include: (a) those traditional processes used to make food edible or to preserve it or to make it safe for human consumption, e.g., smoking, roasting, freezing, drying, and fermenting, or (b) those physical processes which do not fundamentally alter the raw product and/or which only separate a whole, intact food into component parts, e.g., grinding meat, separating eggs into albumen and yolk, and pressing fruits to produce juices. Relatively severe processes, e.g., solvent extraction, acid hydrolysis, and chemical bleaching would clearly be considered more than minimal processing.

However, the USDA still allows products containing an ingredient which has been more than minimally processed to be labeled “natural.” The USDA grants exceptions on a case-by-case basis, and would allow the “natural” claim if it is qualified by identifying the ingredient. For example, a “all natural, except dextrose, modified food starch” claim would be permitted.

Meat, from regular or cloned animals, and poultry which has been raised entirely indoors, given antibiotics and other drugs, and fed the remains of other animals as well as GMO feed, can all be labeled “natural.”

CONSUMER REPORTS EVALUATION

How meaningful is this label? 

Not meaningful.

The “natural” label does not mean what the vast majority of consumers expect it to mean. Consumer survey data, from Consumer Reports National Research Center polls conducted in April 2014 and December 2015, show that consumers overwhelmingly expect foods with the “natural” label to:

  • Be grown without the use of synthetic pesticides
  • Contain no genetically engineered organisms (“GMOs”)
  • Be processed without chemical processing aids
  • Contain no added artificial ingredients

For animal products labeled “natural,” a vast majority of consumers expect the animals to be raised with:

  • No antibiotics and drugs
  • No artificial growth hormones
  • No GMOs in feed
  • No artificial ingredients and colors in feed
  • Access to the outdoors 

The USDA verifies whether meat and poultry products labeled “natural” contain no artificial additives and are only minimally processed, and requires that all products claiming to be natural be accompanied (either by appearing directly beneath or beside the claim, or with an asterisk) by a brief statement that explains what is meant by the term natural, i.e., that the product contains no artificial ingredients and is only minimally processed. The USDA’s definition of “natural” does not cover other aspects of food production, such as the animal’s feed or how the animals were raised.

For foods other than meat and poultry, the Food and Drug Administration has no formal definition for the “natural” label and no requirements for verification.

Is the label verified?

No.

The Food and Drug Administration has no requirements for verification.

For meat and poultry, the US Department of Agriculture requires verification from companies that use the “natural” labeling claim. The agency performs a desk audit of an application for label approval from the company, and verifies only whether its narrow requirements are met. The USDA verifies whether the product label meets its definition of “natural,” meaning that the final product must be minimally processed and contain no artificial additives, which falls short of consumer expectations for the “natural” label.

Is the meaning of the label consistent?

No. 

Since each company can determine its own definition for “natural” on foods other than meat and poultry, there is no consistency in the meaning of the label.

Are the label standards publicly available?

No. 

Government agencies only provide guidance, not formal standards, for foods labeled “natural.” Each company can determine its own definition, and does not have to share its definition with the public.

Is information about the organization publicly available?

No. 

There is no organization behind the label.

Is the organization free from conflict of interest?

Not applicable.

There is no organization behind the label. 

Was the label developed with broad public and industry input?

No.

Each company can determine its own definition of the “natural” label for foods other than meat and poultry.

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Public interest groups comment to FDA in support of styrene ban https://www.greenerchoices.org/styrene-abandonment-petition/ https://www.greenerchoices.org/styrene-abandonment-petition/#respond Thu, 04 Jun 2020 20:56:33 +0000 https://www.greenerchoices.org/?p=301 August 2016

Support of petition to remove 7 synthetic flavors or adjuvants

Consumers Union, along with other organizations, submitted comments to the FDA in support of a petition by the Center for Science in the Public Interest that asked the agency to remove its approval of seven synthetic flavors or adjuvants, including styrene, because they could cause cancer in humans.

Read the comment: styrene-abandonment-petition

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Carrageenan https://www.greenerchoices.org/removing-carrageenan-organic/ https://www.greenerchoices.org/removing-carrageenan-organic/#respond Thu, 04 Jun 2020 20:44:04 +0000 https://www.greenerchoices.org/?p=298 An ingredient that should be prohibited from organic foods

Improving the Organic Standards

Removing Carrageenan from Organic Foods

On November 17, 2016, the National Organic Standards Board (NOSB) voted to prohibit carrageenan as an ingredient in organic foods.

However, this doesn’t mean that carrageenan will no longer be allowed in organic foods right away. The NOSB’s vote passed a recommendation to the Secretary of Agriculture to remove carrageenan from the list of substances that are exempt from the organic law’s prohibition on synthetic and non-organic ingredients.

Our advocacy work to remove carrageenan from organic foods will continue until the U.S. Department of Agriculture publishes a final rule to remove carrageenan from organic foods.

Learn More

Carrageenan

Based on our review of the scientific literature on carrageenan, we don’t think it should be allowed in foods with the “organic” label.

Non-organic ingredients like carrageenan are prohibited in organic foods unless they meet all criteria outlined in federal law. One of the criteria that non-organic ingredients have to meet is that they pose no harm to human health.

Based on our review of the scientific literature on carrageenan, we urged the National Organic Standards Board to vote to prohibit carrageenan from organic foods. Animal studies have shown that carrageenan can cause inflammation, ulcerative-colitis-like disease, intestinal lesions and ulcerations in some animals, and may act as a promoter of colon cancer.

What is carrageenan?

Carrageenan is a widely used food additive that is obtained from certain types of red seaweed. It has no nutritional value, but is used as a thickener, gelling agent, stabilizing agent or emulsifier in a variety of processed foods.

Why should carrageenan not be allowed in organic foods?

Carrageenan is derived from seaweed, which is not produced in accordance with the organic standards, and it can be processed with substances that are prohibited in organic food production. Carrageenan is therefore prohibited in organic foods; however, the organic law allows for exemptions, and carrageenan appears on the list of exempt (allowed) materials.

The organic law puts in place many safeguards. It allows for the five-year use of prohibited substances only if the use of the substance meets all criteria outlined in the law: it has to be essential, not harmful to human health or the environment, and compatible with organic production.

In the case of carrageenan, scientific studies raise serious concerns with the safety of carrageenan and its impact on human health. We believe carrageenan should therefore not be allowed in organic foods.

Why does carrageenan fail the human health criterion in the organic law?

We argued that the NOSB should use the Precautionary Principle when making its decision on whether carrageenan meets the criteria in the law. It is nearly impossible to “prove” that a material is harmful to human health, in part because human experimentation is unethical, so we rely on data from animal studies and cell studies. If scientific evidence using animal studies and cell studies strongly points to harmful effects, as is the case with carrageenan, the NOSB should err on the side of caution and protect the safety and health of consumers.

With carrageenan, a substantial body of scientific evidence exists. Research shows that the type of carrageenan used in foods can cause inflammation. Inflammation is well-known to be the basis for many human diseases, including inflammatory bowel disease, rheumatoid arthritis, and arteriosclerosis. Inflammation is also linked to cancer. Laboratory research has shown consuming carrageenan can cause ulcerative colitis-like disease and intestinal lesions and ulcerations in some animals. Additional studies in animals have shown carrageenan may act as a promoter of colon tumors.

Research, including industry-sponsored research, shows that consuming foods with carrageenan can expose consumers to degraded carrageenan (carrageenan with a lower molecular weight). This raises concerns, since degraded carrageenan is classified as a possible human carcinogen (group 2B) by the World Health Organization’s International Agency for Research on Cancer (IARC).

Recent research suggests that carrageenan may also contribute to insulin resistance and to the development of Type 2 diabetes.

Which foods can contain carrageenan?

Here is a partial list of foods that can contain carrageenan:

  • ice cream
  • cottage cheese
  • chocolate milk
  • whipped cream
  • fruit jellies
  • refrigerated mousse desserts
  • non-fat or low-fat salad dressing
  • beer (as a clarification agent)
  • deli meats, including turkey, chicken and ham
  • pre-cooked poultry products
  • ready-to-eat infant formula
  • and more…

Many organic food processors have already removed carrageenan from their products.

Taking Action

Our advocacy work to remove carrageenan from organic foods

Our written comment to the NOSB takes an in-depth look at the science behind carrageenan.

Our Fall 2016 NOSB comment

Consumers Union Comment to the NOSB, Fall 2016

REFERENCES

Inflammation and ulceration

Review study: Tobacman, J. (2001) Review of harmful gastrointestinal effects of carrageenan in animal experiments. Environmental Health Perspectives 109(10): 983-994.

Cell studies published after the Environmental Health Perspectives review:

Borthakur, A., Bhattacharyya, S., et al. (2007) Carrageenan induces interleukin-8 production through distinct Bcl10 pathway in normal human colonic epithelial cells. American Journal of Physiology, Gastrointestinal and Liver Physiology 292(3): G829-38.

Bhattacharyya, S., Dudeja, P.K. et al. (2008) Carrageenan-induced NFkappaB activation depends on distinct pathways mediated by reactive oxygen species and Hsp27 or by Bcl10. Biochimica and Biophysica Acta 1780(7-8): 973-82.

Bhattacharyya, S., Borthakur, A. et al. (2010) B-call CLL/lymphoma 10 (BCL10) is required for NF-kappaB production by both canonical and noncanonical pathways and for NF-kappaB-inducing kinase (NIK) phosphorylation. Journal of Biological Chemistry 285: 522-30.

Borthakur, A., Bhattacharyya, S. et al. (2012) Prolongation of carrageenan-induced inflammation in human colonic epithelial cells by activation of an NK-kappaB-BCL10 loop. Biochimica and Biophysica Acta 1822(8): 1300-7.

Cancer studies using food-grade carrageenan

Watanabe, K., Reddy, B.S. et al. (1978) Effect of dietary undegraded carrageenan on colon carcinogenesis in F344 rats treated with azoxymethane or methylnitrosourea. Cancer Research 38:4427-4430.

Arakawe, S. Okumua, M. et al (1986) Enhancing effect of carrageenan on the induction of rat colonic tumors by 1,2-dimethylhydrazine and its relation to B-glucuronidase activities in feces and other tissues. Journal of Nutritional Science and Vitaminology 32:481-485.

Corpet, DE, Tache, S. et al (1997) Carrageenan given as a jelly does not initiate, but promotes the growth of aberrant crypt foci in the rat colon. Cancer Letters 114:53-55.

Studies showing exposure to low molecular weight carrageenan from consuming carrageenan

Pittman, K.A., Goldberg, L. and Coulston, F. (1975) Carrageenan: the effect of molecular weight and polymer type on its uptake, excretion and degradation in animals. Fd. Cosmet. Toxicol. 14: 85-93.

Ekström L.G. and Kuivinen J (1983) Molecular weight distribution and hydrolysis behaviour of carrageenans. Carbohydrate Research 116: 89-94.

Ekström, L.G. (1985) Molecular-weight-distribution and the behaviour of kappa-carrageenan on hydrolysis. Part II. Carbohydrate Research 135: 283-289.

Capron I, Yvon M and Muller G (1996) In-vitro gastric stability of carrageenan. Food Hydrocolloids 10(2): 239-244

Uno, Y., Omoto, T. et al. (2001) Molecular weight distribution of carrageenans studied by a combined gel permeation/inductively coupled plasma (GPC/ICP) method. Food Additives and Contaminants 18(9): 763-772.

Marinalg International, “Status Report on the work of Marinalg International to measure the molecular weight distribution of carrageenan and PES in order to meet the EU specification: less than 5% below 50,000 daltons.”

Spichtig V and Austin S (2008) Determination of the low molecular weight fraction of food-grade carrageenans. J Chromatogr B Analyt Technol Biomed Life Sci 861(1):81-7.

Insulin resistance and diabetes

Bhattarachyya, S., O’Sullivan, I et al. (2012) Exposure to the common food additive carrageenan leads to glucose intolerance, insulin resistance and inhibition of insulin signalling in HepG2 cells and C57BL/6J mice. Diabetologia 55(1): 194-203.

Bhattacharyya, S., Feferman, L. et al. (2015) Exposure to Common Food Additive Carrageenan Alone Leads to Fasting Hyperglycemia and in Combination with High Fat Diet Exacerbates Glucose Intolerance and Hyperlipidemia without Effect on Weight. Journal of Diabetes Research.

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Stretching Your Dollar https://www.greenerchoices.org/stretching-dollar-fit-organic-produce-budget/ https://www.greenerchoices.org/stretching-dollar-fit-organic-produce-budget/#respond Thu, 04 Jun 2020 20:08:33 +0000 https://www.greenerchoices.org/?p=296 Stretching Your Dollar

How To Fit Organic Produce in Your Budget

Organic food is better for your health and that of the environment. But produce grown organically also generally costs more than conventional options, so here are some tips on how to fit organic in your budget:

  •   Buy whole foods and process them yourself. Whole and unprocessed organic foods are often less expensive than their processed, non-organic counterparts. Carrots are a perfect example: Baby carrots are simply regular carrots that have been peeled and cut into smaller pieces for you. If you don’t mind doing the peeling and cutting yourself, organic whole carrots will often cost less than the non-organic baby variety. The same is often true for organic whole heads of lettuce vs. the bagged non-organic kind, whole organic apples vs. sliced non-organic, etc.
  •   Buy in bulk. It’s often considered as a cost-saving measure when buying grains, dried beans, nuts, and other grocery items, but buying in bulk can also save you money on fresh or dried fruits and vegetables. Look for dried fruit in the bulk section of your store. Many stores offer organic apples, oranges, carrots, avocados, and other organic produce in bulk bags, which can cost less on a per-pound basis than loose produce.
  • Buy in season. Fruits and vegetables are much less expensive when you buy them in season. Stock up during the summer and fall months, when produce is abundant and prices are lower, and preserve them for the winter and early spring months. Canning, freezing, and drying are good options.
  • Find a farmers market. They are a great opportunity to buy in season, directly from local farmers.
  • Join an organic CSA. When you join a CSA (which stands for “community supported agriculture”) program, you will receive a weekly share of the harvest, and you’re likely to spend much less money on fruits and vegetables than if you bought those items at the store. You’ll be supporting local farmers, and you’ll probably end up with more vegetables and fruits than you know what to do with. Consider preserving them for the winter months by canning, drying, or freezing.
  •   Buy frozen. If you didn’t have the chance to freeze produce at home during the summer, look for frozen options in the store. Many organic fruits and vegetables are available in the freezer section of most stores year-round and can cost less than the fresh non-organic options. Because they are frozen immediately after harvest, frozen organic fruits and vegetables have nutrient levels comparable to, or even better than, fresh produce that has been shipped hundreds of miles and arrives less than fresh at the store.
  • Or buy dried. In the winter months, when certain kinds of organic fruits and vegetables are either unavailable or too expensive, look for their dried versions instead. An additional benefit of buying organic dried fruit is that sulfite preservatives—often used in conventional dried fruits—are prohibited in organic foods.
  •   Replace processed snack foods with organic fruits and vegetables. USDA researchers have found that some healthy foods, including fresh produce, often cost less than unhealthy foods, such as sweet and salty snacks. To fit organic fruits and vegetables in your food budget, consider cutting out unhealthy sweet and salty snack foods.

Source: 2015 Pesticide Report

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Certified Pesticide Resique Free https://www.greenerchoices.org/certified-pesticide-residue-free-scs-global-services/ https://www.greenerchoices.org/certified-pesticide-residue-free-scs-global-services/#respond Thu, 04 Jun 2020 19:42:20 +0000 https://www.greenerchoices.org/?p=293

The seal means that the food has been tested for pesticide residues, and that residues were below levels specified in the SCS Pesticide Residue Free Certification Standard. For a food to be certified and carry this seal, the test results do not have to indicate that the residue levels are zero, or that no pesticides are detected. Rather, the limits are 0.01 parts-per-million (ppm) for most pesticides, even though many of these pesticides can be detected at much lower levels. Also, some pesticides can be used in agriculture in ways that would not lead to residues on the food but can have negative impacts on the environment, farmers and farmworkers, and people living near farms. 

The bottom line: If you’re looking for a seal that means no synthetic pesticides that can pose risks to human health and the environment are allowed to be used, look for the USDA Organic seal.

This seal can be found on

Fresh or processed fruits, vegetables, grains, juices

ORGANIZATION: Scientific Certification Systems, Inc., doing business as SCS Global Services

url: www.scsglobalservices.com

LABEL STANDARDS: www.scsglobalservices.com/certified-pesticide-residue-free

What this seal means 

The SCS Certified Pesticide Residue Free seal indicates that the food was tested for pesticide residues, and that residues were below levels specified in the SCS Pesticide Residue Free Certification Standard. The limit for most pesticides is 0.01 parts-per-million (ppm), and up to 0.2 ppm for some. Pesticide residue levels do not have to be zero for a food label to carry this seal, which could be considered misleading because the seal states the product is “pesticide residue free.”

SCS Global Services bases its limits on the limits of detection that apply for the U.S. Department of Agriculture’s National Organic Program screen rather than on the lowest possible limits of detection. In some cases, pesticide residues can be detected at a lower level. For example:  

  • The limit of detection used by the U.S. Department of Agriculture (USDA) for its pesticide testing program (Pesticide Data Program or PDP) is 0.005 ppm for the neurotoxic insecticide chlorpyrifos on cucumbers, but the limit in the SCS Pesticide Residue Free Standard is twice as high, at 0.01 ppm.
  • The limit of detection in the PDP for the neonicotinoid insecticide acetamiprid is 0.0015 ppm on apples, but it is 0.01 ppm in the SCS Pesticide Residue Free Standard.
  • The limit of detection in the PDP for the neonicotinoid insecticide imidacloprid is 0.003 ppm on apples, but it is 0.01 ppm in the SCS Pesticide Residue Free Standard.
  • The limit of detection in the PDP for the sprout inhibitor chlorpropham on potatoes is 0.001 ppm, but it is 0.01 ppm in the SCS Pesticide Residue Free Standard.

The SCS Pesticide Residue Free Standard does not prohibit the use of pesticides, so the seal does not indicate that the crops were grown without chemical pesticides. Some pesticides are used in ways that do not lead to residues on the food, but can have detrimental impacts on the environment, farmworkers, and people living near the farms that use them.

Is the seal verified?

Yes. Compliance with the standard is verified through testing. Is the meaning of the seal consistent?

Yes. All requirements in the SCS Pesticide Residue Free Certification Standard have to be met. Are the standards publicly available?

Yes. The SCS Pesticide Residue Free Certification Standard is available on the SCS website.

Is the organization free from conflict of interest?

Standards development:Yes. The directors of SCS Global Services vote on the final standards. SCS Global Services is financially independent from its clients and receives no financial backing from any institution with an interest in representing its clients or their products. SCS Global Services has an extensive policy to avoid conflicts of interest among its directors.

Verification: Yes. SCS Global Services has a conflict of interest policy that requires individuals involved with verification to declare potential conflicts of interest, and prohibits them from conducting work on behalf of SCS Global Services if there is a conflict of interest.

Were the standards developed with broad public and industry input?

Standards development: Yes. The standards were developed with input from various stakeholder groups, including non-profit organizations such as the Pesticide Action Network, National Resource Defense Council, and others. The initial draft was also reviewed by several government agencies, including the Food and Drug Administration and the Federal Trade Commission.

Standards updates: Yes. Standards are updated in collaboration with various stakeholders. Proposed revisions are shared with stakeholders including non-profit organizations, academics, and producers who participate in the program. Revised drafts are posted for public comment on the website, where revisions are announced. 

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