“Natural” claims on meat & poultry

November 13, 2009

Food Safety and Inspection Service
OPPD, Docket Room
U.S. Department of Agriculture
5601 Sunnyside Avenue, Room 2-2127
Beltsville, Maryland 20705

Re: Docket number FSIS-2006-0040A

Dear FSIS,

As the nation’s largest consumer-owned grocery retailer, PCC Natural Markets is delighted to comment on use of the term “natural” in meat and poultry. We sell “natural” and certified organic products in our nine stores in western Washington, doing more than $140 million in annual sales. Our customer base actively expresses its wishes and expectations.

Our customers include the 47,000 member-owner households of our business. They expect us to stock products with labels that are accurate and help them make informed decisions. Their active and steady feedback to our management team over the decades has provided a clear understanding of what they consider fair and accurate, or deceptive and misleading.

Regarding use of the term “natural,” we believe they strongly agree that such a label should not be allowed on products containing any artificial flavor or flavoring, coloring ingredient, or chemical preservative, or any other artificial or synthetic ingredient. We believe they agree that “traditional processes” used to make food edible or preserve it, such as smoking, roasting, freezing, drying and fermenting, should be allowed under a “natural” label. We believe they agree that relatively severe processes, e.g. solvent extraction, acid hydrolysis, and chemical bleaching, do not occur naturally and therefore should not be allowed under a “natural” label.

However, the term “natural” under the current policy guidance falls short of consumers expectations. It does not go nearly far enough in ensuring that products labeled “natural” meet consumers expectations for what they believe and expect the term to mean.

The term “natural” must encompass consumers concerns for animal welfare, natural living conditions, and feed suitable to the species. Meat and poultry products labeled “natural” must be from livestock raised in conditions as nature intended — that ruminants graze throughout the growing season, and that chickens and turkeys may run, flap their wings, and hunt and peck for grubs and insects in a pasture.

Animals unable to engage in such natural behaviors should not be labeled “natural.” Products from animals that have been treated with added hormones, or fed prophylactic antibiotics also should not qualify as “natural.”

The FSIS policy on “natural” specifically must exclude genetically altered and cloned animals, and their offspring. It must exclude the practice of weaning young animals on blood products and feeding unnatural, genetically engineered grains. Rendered animal products for ruminant or poultry rations also must be excluded. Consumers believe that such contrived practices are contrary to nature’s way, and expect them to be excluded.

We disagree with the changes made after rescinding Policy Memo 55 in August 2005. FSIS modified the policy on “natural” to allow sodium lactate (from a corn source) and flavorings from oleoresins or extractives. In the case of sodium lactate, we disagree because it is a compound that is not naturally occurring on its own but rather results from a synthetic reaction of two elements. No matter what the original ingredients are, it is a contrived, synthetic chemical compound, not a single, naturally occurring element.

We therefore, agree with Hormel in its 2006 petition that exceptions for specific chemical preservatives and synthetic ingredients (such as sodium lactate) should not be allowed. We ask FSIS to disallow use of the “natural” label on products that use potassium lactate or calcium lactate, too, at levels providing antimicrobial or preservative effects. We do not support Sara Lee’s petition for premarket, case-by-case reviews of sodium lactate use.

It is critical to distinguish between substances that are formulated or manufactured by a chemical process (synthetic), or are the result of natural roasting, freezing, drying, or fermenting. The mere processing of food, or the outcome of processing, is not synthetic. The manufacturing of a novel compound, such as sodium lactate, is synthetic.

In the case of oleoresins and extractives, the use of synthetic chemical solvents makes them unacceptable as “natural.” The creation of oleoresins, for instance, apparently involves extracting plant material with solvents, which is then evaporated off, leaving behind the thick oily product, with some of the solvent attached. We believe that even conventional food shoppers would be disturbed to learn that chemical solvents are allowed to be used in the manufacture of so-called “natural” foods.

Any attempt to hide, diminish or otherwise obfuscate the fact that consumers are not buying a single-ingredient product should not be allowed in any case. Raw poultry products “enhanced” with salt water for plumping should be clearly labeled, spelling out in a conspicuous fashion exactly what has been added and why. (e.g., “XX (amount of) water and xx mg. salt added to enhance flavor and plumpness,” or “Tenderizing agent, with XX ingredients and XX spices, added”).

The use of carbon monoxide in modified atmosphere packaging also is inconsistent with the FSIS policy on “natural.” We agree with FSIS that the process used to add carbon monoxide to product packages is more than a minimal process, since it involves a sophisticated control system, such that no more than 0.4% CO is added.

Using this packaging process to alter the natural oxidative process of raw meat is not natural; it deceives and misleads the consumer into thinking that the meat is fresh, when it is not. Using carbon monoxide to preserve meat’s appearance artificially — to keep it looking “fresh” even when it may be weeks old — is disgusting to consumers who expect fresh-looking meat to be truly fresh.

Other processing methods, such as steam pasteurization, ultra pasteurization, and high pressure processing also should not be eligible in foods labeled “natural.” They should be labeled stating exactly what they are, providing information to the consumer but without the added weight of a more far-reaching “natural” label.

We ask FSIS to codify the definition of “natural,” according to the strictures above. This means not allowing complex processes or packaging technologies that alter the natural appearance or characteristics of a product; not allowing multi-functional ingredients; and not adopting a more flexible approach, which may only further confuse consumers and diminish trust in the value of labeling. Consumers want clear-cut guidance when shopping, without case-by-case exceptions that weaken the strength of a standard.

They want “natural” to encompass the conditions under which livestock are raised and they expect “natural” refers only to raw, single-ingredient meat and poultry — just as nature intended.

Finally, we ask FSIS to work with the Agricultural Marketing Service to arrive at one uniform standard for “natural” and “naturally raised.” AMS already has proposed a standard for “naturally-raised” that would prohibit use of antibiotics at sub-therapeutic levels, artificial growth promotants, and mammalian or avian byproducts in the feed. These restrictions already are part of marketing claims that many companies incorporate for their “natural” branding messages. We believe these should be the requirements in the FSIS “natural” claim as well.

Sincerely,

Trudy Bialic
Director of Public Affairs
PCC Natural Markets