APPPA Responds to FSIS: Pasture Raised Is not Synonymous with Free Range

Tue, March 24, 2020 10:56 AM | Anonymous

The American Pastured Poultry Producers Association (APPPA), on behalf of our members, submits these comments relevant to the clarification of the label claim of “free range” for poultry products [Docket Number FSIS-2016-0021].

Based on consultation with the AMS, FSIS currently deems the terms “Free Range,” “Free Roaming,” “Pasture Fed,” “Pasture Grown,” “Pasture Raised,” and “Meadow Raised” to be synonymous. By treating all these potentially different management scenarios as synonymous, the proposed directive opens the door for confusion on the part of the producer as well as the consumer.

In their discussion about how the specific claims around these terms are to be made, the proposed FSIS directive states that the documentation “must describe the housing condition for the birds” and “must demonstrate continuous, free access to the outside throughout [the birds’] normal growing cycle.”

However, FSIS has also been clear that it does not want to engage in a definition of these terms, nor in prescribing and auditing specific husbandry practices.

The wording of the proposed directive allows poultry products to be labeled as “pastured raised,” even if the birds have never been outside on pasture in their lives. Additionally, being “outside” is not synonymous with being “on pasture.” Pasture implies vegetation rooted in soil, which is either actively growing or that has been stockpiled for use in the non-growing season.

Access to the Outside / Being Outside Should be Defined more Clearly

Poultry group dynamics ensures that birds who have “access to the outside” may never actually leave their social groups and their area of the house to walk to – and then venture through – the (typically very small) access doors to gain access to open outdoor air.

Additionally, the FSIS directive states, “During winter months in northern climate, birds are not free range if they stay in poultry housing or coops all winter.” While APPPA and our members commend FSIS for clarifying the difference between winter and other seasonal housing, this part of the directive does not offer enough clarity.

In this situation, FSIS deems birds are not free range if they stay in the coops and housing all winter, but does not differentiate this situation from the birds who, by virtue of their normal social behaviors and / or relative lack of access to suitable doors (size, number and location), do not move outside using the pop doors in other seasons. This seems incongruous.

Pasture Raised Eggs and Chicken are Nutritionally Different

There is evidence to support that poultry raised on viable, rooted-in-soil pasture display a nutritional profile that is different than poultry raised in confinement and / or in dirt-lot situations. Multiple research papers, supported by privately funded nutritional testing of poultry raised on growing pastures in a management system that incorporates movement across those pastures, show that there are differences in the nutritional profiles of the pastured birds.

Because of this evidence and because there is additional research currently in progress, APPPA requests that FSIS reconsider their opinions. This research compares the nutritional components in the meat and eggs of pasture-raised birds compared to that of birds raised in other circumstances, including free range.

Logic and laboratory work indicate that claiming “Free Range” as equivalent to “Pastured Raised” would construe and support misleading and untruthful claims.

This lack of clarity and specificity is misleading to consumers and contributes to labels that are not truthful and misleading.  The consumer who is seeking out pastured poultry products specifically because of the differences in nutritional value has expectations about the way the label on the poultry accurately reflects the product contained within the packaging. Continuing to consider these different management practices as equivalent could result in products that are negligently misbranded using fundamentally incorrect labels. 

APPPA proposes that FSIS continue to collate and study the available data and make an empirical assessment of the differences in nutritional content among the meat and eggs from birds raised in different husbandry models, including but not only, pasture-raised and free range. Further APPPA proposes that the final rule be delayed until such time as the research is more fully completed.

Pasture Raised Not Synonymous with Free Range

Since the mission of FSIS includes “ensuring the nation's commercial supply of poultry is correctly labeled and packaged,” it seems self-evident that the guidance offered regarding “Free Range” and “Pasture Raised” should include a clear definition of the claims being made on the labels.  

The current definition of free range is inherently accurate: poultry are “Free to Range,” meaning they can stay indoors or go outdoors as they so choose.  In the Free Range system, a bird can stay indoors its entire life and still be accurately labeled as free range.  That would be an accurate and correct use of the Free-Range label, but it would not represent a Pasture-Raised bird.

We also realize that most poultry must spend their first weeks in a very controlled environment (the brooder) in order to survive. (This is similar to the weaning period for ruminants.). It is unreasonable to propose that requirements for poultry that are “pasture-raised” include the provision that they “[must] demonstrate continuous, free access to the outside through [the birds’] normal growing cycle.”

An accurate description of “pasture raised” is that each bird lives more than 50% of its life on pasture that is covered by rooted-in-soil vegetative cover, which is typically achieved by flock movement to fresh pasture.

APPPA recommends that FSIS does not consider “Pasture Raised” synonymous with “Free Range” based on a growing body of research and fundamental differences in the approach of each system. APPPA proposes further discussion and collaboration with FSIS to more accurately define pasture raised poultry and eggs as a product that is inherently different than free range.

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