Last Day for Naturally Grown Comments

The comment period for the USDA’s proposed dilution of the term “Naturally Raised” is closing soon. Get your comments in now to the Federal Registry if you haven’t yet.

As I write this, over 700 people have left comments – (697 documents, some with multiple signatures). One of my favorites from yesterday is:

I oppose USDA’s proposed definition of “naturally raised” because I think that phrase would falsely convey the impression of “free-range” to the public. I’m not an animal rights activist; I’m a carnivore. But misleading labeling should not be promoted.

There have been a tremendous reaction against the USDA’s proposal from homesteaders, small farmers, consumers, livestock organizations, state attorney generals and even Big Ag. I was surprised to see that a subsidiary of Smithfield didn’t like the proposed regulations. The company stinks and it is very odd to be fighting the same battle from the same side as them…

A few points to make:

1) The label is fundimentally missleading because it implies pasture, outdoors and free ranging yet allows for confinement feeding operations a.k.a. factory farms and CAFO’s. The USDA’s proposed “Naturally Raised” claims standard makes no mention of allowing access to the natural world. By the USDA’s standard you could raise animals in boxes they can’t turn around in, without fresh air and still call it “Naturally Raised” – that’s fundamentally wrong and deceptive labeling.

2) The standard bans feeding milk to pigs which is absurd. The USDA’s proposal bans the feeding of mammalian and avian by-products when it should be banning the feeding of mammalian and avian slaughter by-products. Without the word slaughter in there it is unclear if the feeding of dairy (e.g., milk, whey, cottage cheese, yogurt, cheese trim, etc) is acceptable food. Dairy is an excellent, natural, high quality, protein rich food for pigs and chickens and a good way of recycling excess on the farm, from local cheese processors and dairies. Dairy and eggs are superior feeds for inclusion in swine diets and should be allowed for the entire life of the hogs. The origin of this ban is the Mad Cow scare which is all about ruminants and has nothing to do with pigs, chickens, milk or cheese. The USDA is using bad science and overly broad regulations which do not solve any problems.

3) There is an existing private, farmer and consumer organized Certified Naturally Grown program with far higher standards which are published right on their web site for all to see. The USDA knows about those standards because they approved my meat label for our pastured pork last year with the CNG logo and standards and I personally directed them to that web site and provided them with a printed copy of the entire standards as well as our certification. By the USDA setting their own standards at such a low level they are diluting and destroying the existing term and certification that has taken years to develop. Government should not compete with the private sector and it should certainly not destroy existing standards.

4) Animal welfare is not addressed at all in the USDA’s proposed standard thus allowing for the use of gestation and farrowing grating, battery cages and other inhumane conditions. When we think of “Naturally Raised” beef, pork, turkey, chicken or lamb we’re not imagining an animal kept in a tiny box without access to sunlight, grass and Mother Earth.

5) Genetically Modified Oganisms (GMOs) are allowed under the USDA’s proposal as “Natural”. Whoa. Monstersanto all over again. GMOs are manmade, patented and industrialized. There’s nothing natural in GMOs.

6) Cloned Animals are allowed by the USDA’s proposal. Clones may be fine to eat at Micky-D’s but they are not “Natural”. Clones are man made, patentable and like GMOs, anything but natural.

The USDA’s proposal is the antithesis of “Naturally Grown” and a travesty against common sense. Make sure they know it. Leave your comments now and ask everyone you can to do so too. Here’s the Federal Registry comment link again.

Go to that page and then click on the top little comment balloon over on the right side of the page to get to the actual comment page.

After you have commented, scroll down to the bottom and press the “Next Step” button.

A new page that appears showing your comment.

Scroll down and click the “Submit button in the lower right to actually submit your comment.

A new page appears with a “Thank you” in the upper left. That page also has a number on it to refer to your comment. It then takes up to several days for your comment to actually show up in the Federal Registry.

I have been downloading comments as have several other people to make sure the USDA does not ignore the chorus of voices speaking out against their proposal.

If you don’t jump through all their hurdles, they throw your comment away. Make sure you are heard. Take your time and get that “Thank you” message at the end.

Outdoors: 29°F/-5°F Overcast 2″ Snow
Farm House: 57°F/44°F New Pig Carrier for van
Tiny Cottage: 65°F/54°F

About Walter Jeffries

Tinker, Tailor...
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10 Responses to Last Day for Naturally Grown Comments

  1. Here is a link that redirects through an anonymizing server to hide your identity. Then when you fill in the form do not leave any personal data. If the link ends up taking you to the general Federal Registry page then enter “Naturally Raised” the middle search box. Then click on the yellow Add Comments balloon link and go from there. Your comment should still be submitted anonymously. There are many of these available for surfing the web. Google this to find others. Divide, Divert and Subvert. Cheers, -WJ

  2. Thanks Walter, not just for your dedication but also your informative and thorough postings on this issue…just submitted my comment!

  3. theMickster says:

    Darn Walter! I submitted before you posted the anymous link thingy. Now they’ve got my #……Ugh, hold on….who’s there? USDA who?……
    Got to go Walter, keep up the good work.

  4. Mellifera says:

    Having been initially under the impression that “CNG” was supposed to be like “Organic” only moreso (with higher standards), I am left wondering what exactly it IS supposed to mean. So…

    Do you have a link to where you can read the proposed guidelines? I am currently mining around the USDA website and am having trouble finding it. Cute enough, I did CNG on a USDA page listing “additional and alternative certification programs.” Keep in mind that this page showed up on the first page of search results for “certified naturally grown” on the USDA website whereas the actual CNG proposed guidelines themselves are still nowhere to be seen. As is my understanding at least in environmental law, the point of a comment period is to get your proposal out there and see what people think about it. Man oh nelly, any private company that made their proposal this hard to find would have some harsh words comin’ from the EPA.

    Looking further down the list, CNG (the original, not USDA kind) keeps showing up on pages oriented towards organic growers helping them to market their stuff. So as you can see the left hand clearly knoweth not what the right doeth. Or my guess is the left hand does know and is rather ticked but can’t do anything about it.

  5. Mellifera says:

    And I wouldn’t worry about the USDA stalking you down, themickster… Keep in mind that they can’t even keep track of they own selves. ; )

  6. In the above article is a link (#2) to get to the USDA’s proposed Naturally Raised regulation. That link takes you to the Federal Registry where the information is published for comment. Once you get there the first document (AMS-LS-07-0131-0001) is the USDA’s proposed regulation text.

    CNG (Certified Naturally Grown) is a private, independent organization of farmers which you can find on their web site ( which is a far higher level of standards than the USDA’s watered down proposal. The CNG standard has been around for years. Our farm is Certified Naturally Grown which is like the Certified Organic standard but with some additional stipulations about sustainability, local markets, animal welfare, etc. I’ve written here about CNG a few times before. It is an excellent program and it is sad to see the government diluting it.

    The USDA do know about CNG because when they approved our pastured pork meat labels last year we submitted our CNG documentation, the CNG web site URL and discussed CNG at length with the personnel at the USDA. It may well be a case of the right and the left hand issue.

  7. Jessie says:

    Hey Walter, I posted my comments against the USDA’s proposed CNG standards yesterday. Thank you so much for all your info, I love reading your blog!!

  8. Jessie says:

    I was just parusing another blog and I came across this quote at

    “Totalitarian governments have recognized that the one enemy to their system is the prosperous, independent, yeoman farmer spread out over the whole country thinking independently who doesn’t need anything from his government. That’s a big challenge to totalitarian governments – how to get rid of all these people. In Russia they starved them, in Ethiopia and Cambodia they shot them and in the U.S. and Europe they just pass health laws.”
    -Sally Fallon, Weston A. Price Foundation President in a speech delivered to the OEFFA Conference, March 3, 2007

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