In order to verify claims about animal production practices, the Division
relies on testimonials and affidavits provided by the producer. The affidavits
and testimonials must include the producer’s operational protocol, which
describes, in detail, the production practices employed at the ranch or feedlot
that support the labeling claims. For example, if a claim on a label for a beef
cut conveys that no antibiotics were used during the last 100 days of finishing
the animal from which the beef cut was derived, the protocol should include
information covering that time period. If the claim states that "no antibiotics
were used during raising," the protocol should cover the
entire life of
the animal from which the product is derived. The affidavits and testimonials
must be provided to officials at the Federal establishment at the time of
slaughter. A carcass identification program (i.e., receipt through processing)
is required at the slaughter plant to assure that only the labeling of products
derived from qualified carcasses bear such claims.
During the process of approving labels for meat and poultry products, labeling is
evaluated to ensure that the claim statements are truthful and not misleading.
Claims may only be made about the non-use of a common production practice (e.g.,
administering antibiotics or other growth promotants unless further qualified. For
example, because growth-promoting hormones are not permitted in the raising of
poultry or swine, such claims on the labeling of poultry or pork products would
not be allowed unless qualified by an accompanying phrase, e.g., "Federal
regulations prohibit the use of hormones in poultry." This is an example of a
"negative" labeling claim.
Although the term "organic" has not yet been defined by USDA, and may not be used
by itself as a claim on labeling of meat and poultry products, we are aware of the
public’s interest in "organic" food, including "organic" meat and poultry
products. On January 14, 1999, FSIS released labeling policy guidance that permits
the use of the claim "certified organic by.... (name of a certifying entity)," on
meat and poultry products produced under Federal inspection. By this action FSIS
has not defined the term "organic" or the criteria for applying the term to the
labeling of agricultural products. Another agency in the USDA is responsible for
defining the criteria for using the term "organic."
Passage of the Organic Food Production Act of 1990 established criteria that
broadly govern "organic" labeling claims for agricultural products, including
livestock and poultry. Consequently, the Agricultural Marketing Service (AMS),
another Agency of the USDA, was given the responsibility of developing the
detailed regulations necessary to implement the standards defined in the Act and
is in the process of doing so. Proposed rules for the National Organic Program (NOP)
were published in the Federal Register on December 16, 1997 (FR 62: 65849-65967).
For further information regarding the proposed regulations you may wish to contact
Ms. Johna Pierce at Area Code (202) 720-4623 or connect by computer to the NOP web
site at
http://www.ams.usda.gov/nop/rule.htm.
If you have any questions regarding the use of the terms "natural" and "certified
organic by..." on the labeling of meat and poultry food products, please contact
Ms. Tammie Myrick, Food Technologist, or Mr. Merle Evans, Food Technologist,
Labeling Review Branch, Labeling and Additives Policy Division, at Area Code (202)
205-0623.
