Truth in Labeling is almost a constant whisper, there is always some change predicted, requested, or legislated due to the mess our government agencies have created (and special interest groups have managed to manipulate).
We have organic, cage-free, free-range, grass-fed, grass-finished, antibiotic-free, hormone-free, "naturally" or holistically raised. There are Pasture-raised, humanely raised, and Products that are US-raised.
Honestly? Protein packages could be compared to NASCAR drivers with the amount of labeling and advertising available. A...NASCOW...maybe?
As of 2019 Labeling and Program Delivery Staff (LPDS) of the USDA received 200-plus applications for review and approval weekly. That's more than 10,400 special animal-raising claim labels for 2019 alone! And, that's why I want to cut through the shenanigans that marketers are pulling on all of us. Yes, US. I am a consumer too.
It has gone from 'confusing' to 'frustrating' to 'down-right-dishonest.' The misuse or abuse of labeling was supposed to keep consumers informed and educated about their protein choices. Instead, it is a bonafide tool for deceiving the public into paying higher dollars.
And no one should have to deal with that!
In this post:
CUTTING THE FAT
First, as producers, we must follow specific guidelines and rules before adding certain claims to our labeling. But, as shoppers, we see these labels and feel confident that we're purchasing a protein that meets our personal standards. Some may want organic to reduce the risk of pesticides and other chemicals. Or, perhaps you prefer to know the proteins you're consuming were treated more humanely (whatever your definition of humane might be). And, still, others may wish to avoid GMO grains or the risk that grain-fed proteins may carry a residue that impacts auto-immune diseases.
The Food Safety and Inspection Service (FSIS) of the USDA launched an open-comment period in October 2016 asking for comments to develop guidelines needed for substantiating animal-raising claims. 4600 comments were collected and considered before the launch of the 2019 Labeling Guidelines.
For most of us, the commonly recognized labels include Organic (4 levels were established), Grass-fed or Grain-free, All-Natural, and No Antibiotics/No Hormones. I'm going to include additional label info in this post at the end, but focus primarily on those five most common labels today.
The role of the FSIS is not to assure you that the animal protein you eat was raised as marketed. Instead, the role of the agency is to make the rules and guidelines, review applications and attached protocols that are submitted for specific label statements, and approve or deny those applications. That's the first thing that we need to be clear about. Information that must be submitted to the LPDS with supportive documentation includes:
a written description explaining the controls used for ensuring the claim is valid from birth to harvest or the period of raising being referenced by the claim;
a description of how the animals are raised including feed formulation (vegetarian fed, without antibiotics, grass-fed) to support that the specific claim made is truthful;
a description of the product tracing and segregation mechanism from the time of slaughter or further processing through packaging and wholesale or retail distribution;
a description for the identification, control, and segregation of non-conforming animals/products; and, if a third party certifies a claim, a current copy of the certificate from the certifying organization.
There are rarely any on-site visits or inspections for approval.
In addition, the FSIS doesn't exercise "authority" over other printed point-of-purchase materials. So, a producer can skip putting a label on the protein package but have pamphlets, cards, and other advertising that claim how the animals are raised. And, in this case, if you do not have a fairly personal relationship with the producer, you're simply taking them at their word.
CONSUMER AWARENESS
Generically approved labels aren't required to be submitted to LPDS for approval (Federal Meat Inspection Act ~ 9CFR 412.2(a)(1)). Labels with special statements or claims, including animal-raising claims, must be submitted to LPDS for prior approval (9 CFR 412.1(c)(3) & (e)).
This is important to understand if you pick up a package of store-bought grind that claims "Free Ranging" "Free Roaming" "Grass-Fed" or "Antibiotic-Free", etc. this label had to be submitted, along with the above-described documentation, for review (of meeting guidelines) and approval (that guidelines were met).
The agency approves these claims if the animal raising information submitted with the label application supports the claim made and the claim is truthful and not misleading.
It is up to the producer to decide what documentation is needed based on the type of animal-raising claims used on the product label.
TRUTH IN LABELING - How can you know?
In the simplest of terms? Know your rancher!
For those who aren't geographically close to a ranch, consider buying bulk annually and filling your freezer if that option is conducive to your life. This option affords you cost savings, a variety of choice cuts, and the comfort of knowing you have proteins always available (and fear not, it doesn't all have to go in the freezer, canned meats have a longer shelf life but require a little more labor on the front end. I will be doing a "How To" soon, but our friends at The Homesteading Family beat me to it, so check them out for information now). If you want local options for various proteins, be sure to check out our Local Farm Support page for beef and poultry farms.
If regular farm store visits or bulk buying is not an option for you at this point and you must shop for proteins at grocery stores, you will have to put in the work to know how accurate and honest those labels are.
This blog has been one of the most difficult for me to collect accurate information. It is honestly hard. And, it's by design that this system is so hard to maneuver. I mean, when you can locate 'organic' [Simply] pop tarts versus regular pop tarts, does it even matter anymore?
At the end of this write-up, I've built a drop-down of USDA and FSIS definitions of several approved terms. Rather than convey my interpretation of the label claims, please take a few minutes and familiarize yourself. In the meantime, I'm going to trim away some more waste.
Now, let's discuss the "certification" of what is truthful, acceptable, standard, or humane.
This graphic is a good tool for understanding third-party certifying organizations.
Third-Party Certification
This! This is where I really got lost. I used to believe that using independent entities to police the grower or producer was awesome! And, likely, it is better than just trusting major food companies to submit actual protocols that meet Federal rules and regulations. But, then, as a producer, I started seeking information that I felt would best support our protocols and provide confidence in our supporters that what we 'claim' is truly the reality here.
What I learned however was not what I was seeking. Instead, I learned that if I pay annual fees or memberships, I can submit records and protocols to a third party, they [most always] schedule [at least] an annual inspection of our farm or ranch, and then, they will certify us. That's it.
So, if I were not an honest rancher, theoretically, I could simply stash grain bins away, hide all my pesticide bottles and containers, and clean up my feedlot while my animals are grazing green pastures on the scheduled date for review and inspection. Then, as a dishonest rancher, as soon as my certification was issued, I could just move the animals back into a feedlot, fill their grain troughs as I headed out to spray weed control on my fields.
I mean, who would know?
Fair to say I was disappointed in that avenue of achieving special label claims, it really stuck me in the gut for a while. I mean, as a consumer I used to take time weeding through packages, reading the labels, and heading home to feed my family what I thought was healthier for them (and for the animals before slaughter). "Free Roaming" filled my head with mental pictures of cows out in green pastures their entire life. Non-GMO labels provided my some confidence that I wasn't unintentionally poisoning my family.
And, we'll just not mention the added cost for products that display those labels! You know? We're going to touch on this point more in the third and final article of this series.
So, after much thought, I decided I wouldn't pay the additional costs for a government permission slip that allowed me to tell the truth. Instead, I would utilize my website and social media, and of course, open farm visits so that my local community was confident in our husbandry protocols.
I've spent more hours researching this issue than I had planned. And, just as many trying to decide how to compile that research into an easy read for you. But the truth is, it isn't actually designed to be simple. There is a theme across the board that labeling is just sort of a rule book for a certain type of industrialized food.
I did finally come across this fantastic compilation created by Center for Environmental Farming Services at NC State University. It's probably the most direct and unfluffed information related to label claims. It is short and to the point. Rather than me rewriting and creating images to impress you, just click and review! They really did a great job.
Nutritional Labels
I'm not going to take up too much of your time with this one, it should be a stand-alone article because it is more convoluted than the special claim labels. But, I wanted to just briefly address "bison" meat specifically. Since this is 'truth in labeling' it is important that we bring to the surface something that is always gnawing at my heart.
As I've shared in the past, we started eating "bison" meat because of the claim the National Bison Association promotes, and perhaps you've seen and read the claim also. We believed we were consuming the cleanest, healthiest [red meat] protein available to us for years. Until last year, actually.
If I'm going to be completely honest with our supporters, especially those who are on a health journey similar to ours, I haven't found the USDA nutritional tests that support the protein numbers. In fact, I've gone through all of them, and while there are some that are close - they appear to be cherry-picked by the NBA in order to provide the very best of all that are currently available via the USDA archives. And, most of those are older than some of you. And, what's more, the data was compared to beef at a time when the beef industry hadn't jumped fully on board with the "grass-fed" trend.
Heck, one bison producer has on their website, boasting the health benefits with graphics comparing a variety of species to bison and it clearly shows that Texas Longhorn Beef is higher in protein. And folks, if red meat is your thing, the protein levels in venison is your ticket.
Now don't get me wrong, raised properly and on a natural diet bison or buffalo is extremely healthy, but there are other proteins that are as healthy or healthier. So, taste profiles and personal preferences are as important for a consumer as the nutritional values if bison is your preferred protein...like me. I do love me some delicious beef, and deer tenderloin is a delicacy that is hard to beat. But for my go-to, bison is the best. Bison that is raised and finished grain-free is much healthier Omegas and CLAs, but simply reading the nutritional labels and promotional materials alone will not help you reach your health goals. Watching caloric intake isn't how we lose weight! If it were, obesity wouldn't be a national crisis. Once you acknowledge that you are more accepting that the nutritional labels are only a small piece of the health puzzle.
If you have stayed with me this long you are truly dedicated to learning mundane but important information that ultimately impacts your well-being. And, if humane husbandry and a sustainable protocol that supports environmental health is high on your list of importance, this article was written with you in mind.
The takeaway is there is more than just the label to focus on. Much more. And while we should be able to trust the labels, hopefully, I've raised awareness that not everything is as it appears. Example: "Hormone free" -- bison specific it better be ALL hormone free because the USDA prohibits the use of hormones in bison. Anyone making that claim either isn't trying to be completely honest or they don't know USDA rules and regulations. And, in full disclosure, until I started raising these incredible animals, I didn't know USDA rules and regs either.
The third and final article in this series will be posted next week. I hope you'll join me again for more conversation. I really appreciate the emails you send me with questions and feedback.
Till next week, y'all stay safe and keep the gates closed!
USDA Label Claim Definitions
Certified
The term "certified" implies that the USDA's Food Safety and Inspection Service (FSIS) and the AMS have officially evaluated a meat product for class, grade, or other quality characteristics. When used under the circumstances, the term must be closely associated with the name of the organization responsible for the "certification" process, ex: "XYZ Company's Certified Beef"
Free Range or Free Roaming
"Meat" derived by advanced Meat/Bone Separation and Meat Recovery Systems
Mechanically Separated Meat
Natural
No Hormones (Beef)
No Antibiotics (red meat and poultry)
Organic (There are four different "organic" labels approved by the USDA/AMS)
100% Organic
Made with Organic _____
Specific Organic Ingredients Listings
Organic Meat labeling
*For more information about the National Organic Program and the use of the term "organic" on labels, refer to these factsheets from the USDA Agricultural Marketing Service: Organic Food Standards and Labels: The Facts
PDP (under organic labels) is Pesticide Data Program, here is the Data Sheet
IP (under organic labels) is Identity Preservation, here is the Fact Sheet
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