USDA-Label Claims

HEADWATER FARMS USDA-Approved label

Early in the process of developing the Headwater Farms business, we applied for and received approval from the U.S. Department of Agriculture Label Review Branch to make certain claims about the Petite Beef product. Every package of Petite Beef says:

	Raised without any added antibiotics.
	No added hormones.
	No antibiotics added to feed.
	Environmentally Friendly.
	Petite Beef represents animals harvested at approximately 750 pounds live weight, less than one year old and raised primarily on their mothers, ,grass and hay. They are not "fed out" and there is no attempt to "marble" the meat. Tenderness comes from their younger age.
	Packages of ground beef also make a claim about fat content.

Each claim has an associated protocol. All claims were signed by participating farmers and approved by the USDA Label Review Branch in October 2000. Click on the links below to learn more about each:

	Claim #1 - Raised without any Antibiotics: Protocol
	Claim #2 - Raised without any added hormones: Protocol
	Claim #3 - No antibiotics were added to feed - Protocol.
	Claim #4 - Petite Beef - Protocol
	Claim #5 - "Burger" or "Beef in combination with ground beef" - maximum 20% Fat: Protocol
	Claim #6 - "Environmentally Friendly" - Protocol

Claim #1 - Raised without any Antibiotics: Protocol

	A file will be maintained at each farm that would reference each calf as numbered at birth. Data maintained would be treatment data, calf I.D., aproximate weight, dignosis, products used and amount, and injection site. All animals to which antibiotics are administered are eliminated from the program.
	Vaccination for the prevention of disease is allowed with the products used being accounted for as listed above. Currently being used are: Pfizers - One shot Pasteurallai; Bovishield 4L-5: Ultrabac - 7 Somubac. Back to top.

Claim #2 - Raised without any added hormones: Protocol

A file will be maintained at each farm that would reference each calf as numbered at birth. Data maintained would be treatment data, calf I.D., aproximate weight, dignosis, products used and amount, and injection site. All animals to which hormones are administered are eliminated from the program. Back to top.

Claim #3 - No antibiotics were added to feed - Protocol.

Cattle in this program are raised on the cow's milk, grass, and hay with ground feed being used to supplement grass and hay during drought and winter months. No animals in this program will be fed feed containing antibiotics or sub-therapeutic levels or antibiotics to promote animal growth. Back to top.

Claim #4 - Petite Beef - Protocol

We would like to the name "Petite Beef" to represent an animal butchered at or averaging 750 pounds live weight, less than one year old and raised primarily on it's mother, grass, or hay. It is not "fed out" in a feed-lot and there is no attempt to "marble" the meat. The traditional cuts are similar (i.e. traditional beef is butchered at 1150 - 1350 pounds) but smaller ("petite") in size and thus are more in line with USDA's portion recommendations. Tenderness comes from their young age. To our knowledge no one is butchering animals of this size commercially. We wish to call this product "Petite Beef" from Headwater Farms. Back to top.

Claim #5 - "Burger" or "Beef in combination with ground beef" - maximum 20% Fat: Protocol

Results from West Virginia University's Meat Science Laboratory indicate that fat content is less than 10%, which gives us the basis for this claim. We understand that USDA inspectors will monitor this product at butchering and will furnish us with independent results. Those results combined with our continuing monitoring will hopefully allow us to lower our percent guarantee. Back to top.

Claim #6 - "Environmentally Friendly" - Protocol

In this case Headwater Farms has enlisted the service of the Cacapon Institute, a water quality/environmental protection group, the Natural Resources Conservation Services (NRCS), the West Virginia University Extension Service, and the West Virginia Department of Agriculture to form the criteria of compact which sets the requirements for each producers water quality enhancement practices. This would evaluate each farm, each riparian corridor, each animal facility, and each grazing management system with the approach being -- "How can we achieve our water quality/river protection goals while implementing agricultural management practices that are feasible on each farm?" The "group" looks at the total farm with a "USDA-NRCS Best Management Practices (BMPs)" philosophy yet will consider such things as "The stream is a valuable asset to the farmer." In this way we wish to improve water quality because it's a better way of doing business, yet it is not done through laws which do not reflect individual situations. We wish to call this approach "Environmentally Friendly."

We also acknowledge that to implement such a plan requires both financial resources and time. Recognizing that the requirement to meet this objective is the farmer's commitment to the concept and the continued implementation of the strategies as identified by the "group" over a period of time. It is also recognized that BMP's change as the science changes and that the individuals plan is a flexible process.

This protocol was signed by all of the participating farmers in October of 2000.

In February 2001, Cacapon Institute, the Natural Resources Conservation Services (NRCS), the West Virginia University Extension Service, and the West Virginia Department of Agriculture met with all of the farmers and spend a day reviewing and modifying the Natural Resources Conservation Service Conservation Practice Standard for Prescribed Grazing in Riparian areas. After reviewing the protocol line-by-line, we all agreed on certain, common-sense, modifications. The USDA-NRCS agreed to adopt the proposed changes as a demonstration project with the Headwater farms group. The details are below.

NATURAL RESOURCES CONSERVATION SERVICE

CONSERVATION PRACTICE STANDARD

PRESCRIBED GRAZING

SUPPLEMENT

RIPARIAN GRAZING MANAGEMENT

(Acre)

Code 528A

PROPOSED CHANGES BY HEADWATER FARMS PARTNERSHIP IN ITALICS BELOW.

DEFINITION

To convert presently grazed riparian areas to a managed livestock grazing system.

PURPOSE

To stabilize streambanks, help protect water quality, and improve forage production for demonstration purposes.

THE DRAFT HEADWATER FARMS CERTIFICATION DOCUMENT STATES: “The riparian area is not to be managed as other areas on the farm; it is never to be used as a concentrated livestock feeding area nor grazed during wet periods when streambanks are likely to break down and erode. This area is to be managed to preserve its function as a buffer between the stream and animal wastes and other potential pollutants.”

CRITERIA

! Grass height will be a minimum of 8 inches (tall grass) and 5 inches (bluegrass) at the beginning of a grazing period.

! Any grazed period will not exceed 3 days or minimum grass height of 4 inches for tall grasses and 3” for bluegrass.

! The grazing season will extend from May – October.

REWORD: The grazing season will generally extend from May – October. However, limited grazing of stockpiled grass in this area will be allowed at other times so long as this area is not grazed during wet periods when streambanks are likely to break down and erode.

! Stocking density will not exceed 75% of carrying capacity of the riparian area. (Appendix 2)

! Stream or other water bodies will be used for watering livestock only if no alternative method is feasible.

! Temporary or permanent electric fencing and solar charger can be used to limit livestock access to streambank.

! Only livestock trained to electric fence will be released into paddock(s) with temporary electric fence.

! Apply soil amendments according to a soil test every 3 years.

REWORD: Soil amendments will be applied only according to soil test (every 3-5 years) recommendations if needed to maintain the effectiveness of the vegetative buffer.

! No manure will be spread within 50 feet of top of streambank.

! Livestock will be excluded from streambank on slopes greater than 5% and/or slopes with less than 50% ground cover.

REWORD: Livestock will be excluded from streambank slopes with less than 50% ground cover. RATIONALE: a 5% streambank slope limitation would exclude nearly all streams in the Potomac Headwaters region. A well vegetated 30 or 40% slope will perform equally well for erosion control if grazed according to the protocols listed above.

! The minimum width of a grazed riparian area is 50 feet to help insure distribution of manure away from streams and water bodies.

DELETE. RATIONALE: Unnecessary micro-management and, in practice, unnecessarily difficult to implement -- as streams meander. The protocols as described above will achieve the goal of maintaining the riparian corridor as an effective agricultural buffer while allowing an agronomic benefit for the farmer.

CONSIDERATIONS

Consider using portable watering systems to minimize cost.

On severely eroding or unstable streams consider establishing riparian forest (391) to protect adjacent land from downstream meander migration.

For absentee livestock producers consider grazing schedule for weekends.

For pasture subject to repeated flooding consider use of temporary fence.

OPERATION AND MAINTENANCE

Remove livestock and temporary fence if threat of flooding is evident.

Check livestock water sources, temporary fence and grass height daily.

Maintain a record keeping system to support a case study report. MOVE THIS TO CRITERIA .

Conservation practice standards are reviewed periodically, and updated if needed. To obtain the current version of this standard, contact the Natural Resources Conservation Service.