|April 5, 2004:
If ever an animal were a vegetarian, it is a cow. They are designed
to eat forages. They are ruminants!
It is totally unnatural to feed them animal by-products and manure,
but that is exactly what high-output, industrial factory farms,
especially dairy farms, are doing, since these are cheap sources
of protein. Farmers -- including organic farmers -- who feed pasture,
hay, silage, and grain concentrates are taking steps to minimize
risks of BSE (also known as mad-cow disease).
There are significant differences in meat production management
between certified organic, on the one hand, and industrial, non-organic
systems on the other. They deal with what the animals eat, how precisely
they are traced from farm to retail, and the inspection of feed
mills and slaughter facilities. Let me hit the highlights.
Allowed animal feed ingredients -- To begin with,
there is an absolute ban on the feeding of mammalian and poultry
slaughter by-products to organic mammals and poultry. This contrasts
with non-organic regulations, which still allow the feeding of cattle
and other slaughter by-products to cattle and other livestock.
The FDA banned the feeding of cattle brain and spinal tissue to
cattle in 1997, and has publicly stated that it will ban blood,
poultry litter, and human food wastes. However, they still allow
the following materials to be fed to non-organic cattle:
- Gelatin (rendered from the hooves of cattle and other species;
- Fats, oils, grease, and tallow (from cattle and other species);
- Poultry and poultry by-products;
- Rendered pork protein; and
- Rendered horse protein.
None of the items listed above may be fed to organic cattle or
other organic livestock.
Milk Replacer -- Non-organic milk replacer (used
to feed calves) commonly contains spray dried blood plasma and blood
serum from cattle and hogs. The FDA is now moving to ban this practice.
Research in Europe has shown that BSE can be transmitted by blood,
which is why any U.S. citizen who has traveled to a country with
BSE is prohibited from donating blood.
Most organic calves are fed organic whole milk. Milk replacer may
only be used as an emergency supplement. If milk replacer is used,
the NOP regulation requires that the milk replacer contain no non-milk
products, no antibiotics, and no products from rBST treated animals.
Records and Traceability -- Traceability is a
fundamental requirement for organic certification. The National
Organic Program regulation, in section 205.236.c, requires that
all organic livestock operations must maintain records “sufficient
to preserve the identity of all organically managed animals and
edible and non-edible animal products produced on the operation.”
Section 205.103 further requires that all organic operations, including
those with livestock, maintain records which “fully disclose
all activities and transactions” and “demonstrate compliance
with the Act and regulations.”
This means that records kept by organic livestock producers must
track all animals, including the source(s) of the animals; the sources
and quantities of feed; all medications; and all products produced
and sold. These records are reviewed at least annually by an inspector
representing a USDA-accredited certification agency.
Inspection of Feed Mills -- In order to produce
organic livestock feed, feed mills must be inspected and certified.
If they produce both organic and non-organic feed, they must implement
procedures, documented with written records, to prevent the commingling
of organic and non-organic feed. This includes steps to clean storage
bins and mixing and bagging equipment prior to producing batches
of organic feed. Organic feed mills also must prevent the contamination
of organic feed with antibiotics, hormones, slaughter by-products,
and insecticides which may be added to non-organic rations. They
must also ensure that rodenticides and insecticides used in the
facility do not contaminate organic feed.
Inspection of Slaughter Facilities -- Organic
beef must be slaughtered in slaughterhouses which are certified
organic. As such, slaughterhouses must slaughter organic animals
when all equipment is clean and empty. There must be no chance of
commingling organic with non-organic meat, or contaminating organic
meat with prohibited materials. Records must be maintained of all
organic slaughter activities and steps taken to protect organic
integrity. If a plant can prove that it can segregate organic animals
and meat products and take all steps necessary to protect organic
integrity, then it can be certified. It does not have to be dedicated
to slaughtering only organic animals, however.
Testing for BSE -- Nearly 36 million cattle were
slaughtered in the United States in 2002, yet less than 20,000 were
tested for BSE. In the first 7 months of 2003 in Washington state,
USDA tested no cattle for BSE. At Washington state’s largest
slaughterhouse and at two facilities owned by Tyson, there were
no BSE tests in 2002 or 2003.
100 percent of cattle are tested in Japan. About 75 percent are
tested in Germany and France. All cattle over 36 months old are
tested in the U.K., yet only .05 percent of U.S. cattle are tested.
There are no rapid tests available in the U.S. Such tests are being
used in other countries, including Japan, Italy, Germany, France,
and the U.K. Tissue samples from the cow in Washington state were
sent to the U.K. for confirmation, where results were known in a
When the cow in Washington was slaughtered, its meat went to eight
states and Guam, and it was almost 2 weeks before test results were
known. The meat was allowed to enter the human food supply while
test results were still pending. That is standard procedure in the
BSE on Organic Farms?
There were several cases in Europe where cattle on organic farms
were diagnosed with the disease. Upon further investigation, it
was established that the cattle had not been born on the organic
farms. They had been purchased from non-organic farms, and converted
to organic production.
In the United States, organic cattle must be fed and managed organically
their entire lives in order to be slaughtered and marketed as organic
beef. In fact, a calf’s mother must be fed and managed organically
during the last third of the calf’s gestation in order for
the calf to be sold as organic slaughter stock.
In the U.S., the only animals which can be converted from non-organic
to organic production are dairy cattle, breeding stock, and animals
which produce non-edible products, such as wool. If such animals
are converted from non-organic to organic production, those animals
can never be slaughtered for organic meat.
Hundreds of people in the U.S. die each year of “sporadic
Creutzfeld-Jakob” disease (CJD). New research in Europe, published
in The Proceedings of the National Academy of Science, links a new
form of BSE, found in “healthy” cows, to human cases
of brain-wasting disease, CJD.
One clear option is to stop eating beef. While not a big beef eater,
I do not advocate that position. If you are going to eat beef, eat
smart. Here are nine steps to consider:
- Avoid burger chains.
- Avoid ground beef, unless you know how the animals were raised
and what they were fed. If you want ground beef, buy boneless
roasts and have your butcher grind them or grind them yourself.
- Know the farmers who raise your meat.*
- Buy meat from organic farms or other farms which do not feed
- Shop at your local food coop.
- Look for local, grass-fed meats at the farmers’ market.
- At a corner store or supermarket, ask your butcher where the
meat comes from and how the animals were raised.
- Demand of our policymakers that country of origin labeling (COOL)
- Demand that the practice of feeding animal by-products to ruminants
be strictly prohibited.
After all, cows are vegetarians!
James A. Riddle serves as vice-chair of the USDA’s National
Organic Standards Board. He was the founding chair of the Independent
Organic Inspectors Association (IOIA).