Transparency & Labeling

If you are trying to purchase food according to your values...how do you know what food actually matches up with them? One way is to actually go on the farm and observe yourself. If that is not possible, or you lack the expertise needed to truly evaluate a system, then you could trust what the producer has to say about the food they produce. If there is not a trusted relationship where you can take the food provider at their word what do you do then? You could trust 3rd party verification organizations to be the gate keepers. If you want a deeper dive into a specific organization with a specific goal (like GHG emissions for example) then you can pursue and Life Cycle Assessment of the product you are interested in purchasing.

Remember we were chatting about certifications like Organic, Demeter (biodynamic), Regenerative Organic, Certified Naturally Grown, non-GMO, etc. These exist mainly as gate keepers to maintain integrity and let the public know what they're getting. They cost money and infrastructure to maintain but may also provide access to higher value markets.

Now - let's explore the food labeling you see every day in the grocery store and explore what it does (and does not) tell us about how our food was raised and brought to market.

Miller Poultry Product Line Claims (which can be verified by a 3rd party?):

1. Antibiotic Free

2. All Natural

3. No artificial ingredients or colorings

4. Non-GMO

5. Hatched, raised, and harvested in the USA

6. Amish Country Poultry

7. USDA inspected

8. Raised without hormones or growth stimulants

9. No animal by-products

10. All Vegetarian Diet

11. National Chicken Council Animal Welfare Certified

12. Sausages only - gluten free, no MSG, no nitrates, no nitrites

13. USDA Organic - on organic products only - all vegetable fed with organic grains - We also allow our organic chickens outdoor access

14. We work with and adhere to the Global Animal Partnership (GAP) standards (Step 2)

15. Cage-Free, Low Stress Growing Practices

16. Our farms are in a smaller regional area, located within miles of our processing plant, so our carbon footprint is minimized.

17. One pound of Miller Poultry ground chicken = $6.99*

    1. • *but this depends on which label it is sold under

Gunthorp Farm Product Line Claims (which can be verified by a 3rd party?):

1. Raised on Organic Pasture

   1. • Are the animals certified organic? -- No -- We believe in using organic practices when it comes to taking care of our land, our animals, & our meat products. Our land & our processing plant are both certified organic, so we are not applying any harsh chemicals to our land OR to food surfaces in the processing plant. We feed our animals all non-GMO grains from local farmers, but the grains are not certified organic. That is the only thing keeping us from having our animals certified organic. Everything else is done to organic certification standards.

2. No Antibiotics

3. USDA inspected

4. Vegetarian Diet

5. Non-GMO feed

6. On-Farm processing plant is certified organic (the most sanitary conditions, least stress on the animal, and least amount of chemicals of any processor in the country)

7. Everything handled on-farm

8. Slower Line Speeds - can make a big difference

9. One pound of Gunthorp ground chicken = $8.90

Growth Hormones

Growth hormones, such as oestrogen, progesterone and testosterone, occur naturally in animals and are essential for various physiological processes.

However, synthetic versions of these hormones have also been used in cattle and sheep farming to increase growth rate and meat production efficiency. This practice is still allowed in the US and some other countries, but the use of hormones for any growth promotion purposes has been banned in the EU since 1981.

Growth hormone use in poultry farming has been banned in the US for more than 50 years, but a survey conducted last year found that 60 per cent of parents in the ‘Millenial’ generation were concerned about hormones and steroids in meat, poultry and dairy products.

Adding to the confusion, many chicken retailers in the US put ‘raised without hormones’ onto the label, despite the fact that hormone addition is illegal. A survey this year found that over 60 per cent of US consumers find chicken labels and packaging confusing.

Antibiotics

A study representing 93% of annual US broiler chicken production and 82% of US turkey production, has shown a substantial drop in the use of nearly all classes of medically important antibiotics from 2013 through 2017, regardless of the route of administration. There was also a shift to greater use of antibiotics that are not medically important. Thees include a decrease in the percentage of broiler chicks that received hatchery antibiotics from 93% in 2013 to 17% in 2017, a 95% drop in in-feed tetracycline use in broiler chicks from 2013 to 2017, a 67% reduction in in-feed use of tetracycline in turkeys, and a 42% drop in hatchery use of gentamicin in turkey poults. The substantial reductions in in-feed tetracycline use in broiler chicks and turkeys, along with major reductions in the use of virginiamycin, are significant because these are the main medically important antibiotics used in chicken and turkey feed. 2017 FDA regulations ended the use of medically important antibiotics for growth promotion in food-producing animals, and required veterinary supervision for use of all medically important antibiotics for disease prevention and control. The reductions are also partially related to the poultry industry's response to growing consumer demand for chicken raised without medically important antibiotics. Many companies have shifted to a "no-antibiotics-ever" production system.

All Natural

The FDA has not formally defined the term "natural". Although the FDA has not engaged in rulemaking to establish a formal definition for the term "natural," we do have a longstanding policy concerning the use of "natural" in human food labeling. The FDA has considered the term "natural" to mean that nothing artificial or synthetic (including all color additives regardless of source) has been included in, or has been added to, a food that would not normally be expected to be in that food. However, this policy was not intended to address food production methods, such as the use of pesticides, nor did it explicitly address food processing or manufacturing methods, such as thermal technologies, pasteurization, or irradiation. The FDA also did not consider whether the term "natural" should describe any nutritional or other health benefit.

Vegetarian Diet

The animals used to produce the meat, dairy, or eggs were fed a vegetarian diet with no animal products. In the absence of such a label, the Food and Drug Administration allows livestock feed to include slaughterhouse by-products and processed litter from the floor of chicken houses. Ruminant-derived protein is not permitted in cattle feed or chicken feed that may be fed to cattle to avoid the spread of mad cow disease. Government agencies that oversee food labeling do not require the “vegetarian fed” claim to be third-party verified through on-farm inspections. This claim on its own does not have to be verified.

No Nitrates or Nitrites

New research has suggested that that level of regulation may be unnecessary, however. Nitrite preservatives have "been found to be safe." This is a complete change in paradigmvfrom what people thought in the 1970s and 1980s. There's no difference whatsoever in the nitrite that you get from cured and processed meats versus what you get from vegetables. It's the same molecule.

However, the food that accompanies nitrate and nitrite into the gut helps determine how the molecules act once they get there (meat leads to more cancer causing nitrosamines produced in the gut) . Meat manufacturers now add the antioxidant ascorbic acid, or vitamin C, to their products, which promotes the formation of relatively harmless nitric oxide and counteracts the development of the possibly cancer-causing nitrosamines.

Raised on Organic Pasture

Government agencies have no common standard that producers have to meet to make a “pasture raised” claim on a food label, no definition for “pasture,” and no requirement for the claim to be verified through on-farm inspections.

On meat and poultry labels, the claim is somewhat meaningful. Producers making a “pasture raised” claim are required to explain the term on the label, but the USDA allows producers to write the explanation and therefore define the term.

On meat and poultry the U.S. Department of Agriculture (USDA) requires labels on meat and poultry with a “pasture raised” claim to be approved by USDA staff. The agency requires that companies explain the “pasture raised” claims on the label with additional terminology to define the meaning of the claim.Companies submit a one-time label application with documentation that supports the “pasture raised” claim. Supporting documentation includes:

• A detailed written description explaining controls for ensuring that the animals are raised in a manner consistent with the meaning of the claim that is valid from birth to harvest or the period of raising referenced by the claim;

• A signed and dated document describing how the animals are raised to support that the claims are not false or misleading;

• A written description of the product tracing and segregation mechanism from time of slaughter or further processing through packaging and wholesale or retail distribution;

• A written description of the identification, control, and segregation of non-conforming animals/product.

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.

The following labels are more specific than "raised on pasture":

American Grassfed

The American Grassfed seal on beef and dairy means that the animals were raised on pasture or range and never fed grain. The American Grassfed seal on beef means the cattle were never confined in a feedlot. The label is highly meaningful and verified.

Animal Welfare Approved

The Animal Welfare Approved seal on meat, poultry, dairy, and eggs means that the animals were raised on pasture. Chickens can be kept indoors without access to pasture for up to 28 days, but only in emergency situations or extreme weather conditions that could affect the birds’ welfare.

PCO Certified 100% GrassFed

The PCO Certified 100% GrassFed label means that the dairy cows were raised according to the federal organic standards, which require access to pasture during the grazing season. The PCO Certified 100% GrassFed standards go further than the federal organic standards by requiring 100 percent of the cow’s feed to be derived from pasture or forage, with no grain in the diet.

NOFA-NY 100% Grassfed

The NOFA-NY 100% Grassfed label means that the dairy cows were raised according to the federal organic standards, which require access to pasture during the grazing season. The NOFA-NY 100% Grassfed standards go further than the federal organic standards by requiring that 100 percent of the cow’s feed is derived from pasture or forage, with no grain in the diet.

USDA Organic (dairy and beef only)

The organic claim on a food label and the USDA Organic seal mean the food was grown, raised, and processed in accordance with the federal organic standards. For dairy and beef cows, the organic standards require access to pasture and daily grazing during the grazing season. Pasture is defined as “land used for livestock grazing that is managed to provide feed value and maintain or improve soil, water, and vegetative resources.” While organic dairy and beef cows are raised on pasture during the grazing season, they are not required to be fed only grass and forage; in fact, the standards require only 30 percent of the cow’s feed to be derived from pasture, and beef cattle are exempt from this requirement for their last 120 days (or one fifth of the animal’s total life, whichever is shorter).

For chickens and laying hens, the organic standards do not require the birds to be raised on pasture.

Certified Humane Raised and Handled + Pasture Raised (eggs only)

If a carton of eggs has both a “pasture raised” claim and the Certified Humane Raised and Handled seal, it means the “pasture raised” claim was verified, and the hens were given roughly 10 by 10 feet of pasture per bird (the standards have an outdoor space requirement of no more than 1,000 birds per 2.5 acres, which translates to 108 square feet per bird).

The standards also require that fields consist mainly of living vegetation and are actively managed to encourage birds outside; prevent or minimize heavily degraded, muddy, or worn areas; minimize the buildup of agents that may cause disease; and prevent hens from coming into contact with any toxic substances.

The pasture has to be rotated, and the hens must be outdoors year-round. While the hens are raised on pasture, the standards require mobile or fixed housing where the hens can go inside at night for protection from predators. Hens can be confined in the housing for up to two weeks out of the year, but only in cases of very inclement weather.

Humane Farm Animal Care does not have standards for “pasture raised” dairy or meat.

American Humane Certified + Pasture Raised (eggs only)

If a carton of eggs has both a “pasture raised” claim and the American Humane Certified seal, it means that “pasture raised” claim was verified, and the hens were given roughly 10 by 10 feet of pasture per bird (the standards have an outdoor space requirement of no more than 1,000 birds per 2.5 acres, which translates to 108 square feet per bird). [G page 98] The fields must be rotated and have a substantial cover of living vegetation. The pasture has to be actively managed with reseeding to encourage regrowth of vegetation.

The American Humane Association does not have standards for “pasture-raised” dairy or meat.

Global Animal Partnership Steps 4 to 5+ (beef cattle and pigs)

The Global Animal Partnership certification program has tiered step levels, each representing a different set of standards for raising farm animals. Steps 4 through 5+ for beef cattle mean the animals are raised on pasture. The label is verified. Step 4 for pigs means animals over two weeks of age are given continuous access to pasture. The Step 4 standards require that pigs are rotated once the pasture has reached 25 percent coverage with vegetation. Global

Animal Partnership Steps 5 and 5+ (all animals)

The Global Animal Partnership certification program has different step levels that each represent a different set of standards for how animals are raised on the farm. Chickens and pigs raised according to Steps 5 and 5+ live on pasture. The label is verified.

These labels have some requirements for “pasture raised,” but the standards fall short in providing meaningful pasture access:

Global Animal Partnership Step 4 (chickens)

The Global Animal Partnership certification program has a series of step levels, each representing a different set of standards for how animals are raised on the farm. Step 4 for chickens means the animals live in an enriched outdoor area.

The “pasture raised” claim on labels with these additional seals is not meaningful:

Certified Humane Raised and Handled (on its own, without a “pasture raised” claim on the label)

The Certified Humane Raised and Handled seal does not mean the animals were raised on pasture. In fact, they could have been continually confined indoors or in a feedlot. does not mean that the animals were raised on pasture or never continually confined indoors or in a feedlot. The seal only provides assurance that the animals were raised on pasture when the seal appears on an egg carton with the “pasture raised” claim.

American Humane Certified (on its own, without a “pasture raised” claim on the label)

The American Humane Certified seal does not mean that the animals were raised on pasture. In fact, they could have been continually confined indoors or in a feedlot. The seal only provides assurance that the animals were raised on pasture when the label appears on an egg carton with the “pasture raised” claim.

USDA Organic (chicken and eggs)

The organic standards only require access to pasture during the grazing season for ruminants, but there is no such requirement for pigs and chickens. The organic seal therefore does not guarantee that pigs, chickens, and turkeys were raised on pasture.

Global Animal Partnership Steps 1-3

The Global Animal Partnership certification program has a series of step levels, each representing a different set of standards for raising farm animals. In Steps 1 and 2, chickens and pigs can be raised indoors with no access to pasture or range. In Step 3, chickens and pigs have access to an outdoor space, but this space can be very small and lacking vegetation. Beef cattle raised under Steps 1 and 2 can be removed from pasture and confined in a feedlot. (There is no Step 3 for beef cattle.) The label is verified.

Additional Labels of Interest:

Salmon Safe

Exhaustive list here

Life Cycle Assessment

Here is a general example for broiler chickens

Further Reading (optional)

#1 - Canada Chicken

#2 - CAFO or pasture?

#3 - UK LCA w/layers