A coalition of 50 environmental, consumer, public health, justice, and animal welfare groups representing millions of constituents are slamming the United States Roundtable on Sustainable Beef’s new “sustainability” framework for beef production in a letter released today. Friends of the Earth is a lead organizer of the detailed letter that includes input from dozens of groups.
This USRSB includes over 100 members from the retail, civil society, producer, processor and allied industry sector who are falsely portraying themselves as promoting a “U.S. beef value chain” that is “environmentally sound, socially responsible and economically viable.” Key USRSB leaders include JBS (the world’s largest beef processor), McDonald’s, Arby’s, Merck and Elanco; the very same companies that for years have opposed or undermined numerous policies that would bring us closer to sustainability in the beef sector. Nature Conservancy is also part of the Executive team and WWF is a founding member.
The letter’s 50 signatories “stand strongly opposed to this framework and initiative in its current form because it does not meaningfully advance sustainability goals.” The framework also fails “to create a plan of action to address corporate consolidation and other core policy and regulatory issues that remain barriers to advancing sustainability.” The letter outlines five major reasons why the framework’s weak approach and metrics will fail to significantly reduce the major harmful impacts of factory farming and poor grazing management. Most of the USRSB’s indicators and metrics do not focus on measurably reducing impacts and continue to allow for the misuse of growth hormones and routine antibiotics, which are a major public health threat.
The groups are especially concerned that member retailers and restaurants like Walmart, Costco, McDonald’s, Darden, Arby’s, Culver’s and Wendy’s will use the framework’s meager and misguided metrics as a basis for “sustainable” beef claims—as McDonald’s did last year—thereby undercutting truly sustainable, organic and/or regenerative beef producers. The letter offers 10 recommendations for how USRSB can promote real sustainability in the beef sector.
The coalition is encouraging the USRSB “to go back to the drawing board and develop a new framework and plan of action — including the need for regulatory change — that generates far more environmental, economic, health and other benefits for stakeholders.” The letter also recommends “that the USRSB remove the term ‘sustainable’ from its name and choose a more accurate term that does not undermine the value of credibly sustainable and regenerative beef production systems.”
The first two pages of the letter are below, including a summary of our recommendations and the framework’s five major flaws. You can find a detailed version of the letter here and Friends of the Earth’s more detailed comments on the framework here.
Dear Stakeholders of the US Roundtable on Sustainable Beef,
We appreciate the opportunity to provide comments to the US Roundtable on Sustainable Beef (USRSB) on its sustainability framework. In this time of intensifying climate change and rising consumer concern about the impacts of the food we eat, we can all agree this is a critical moment to make beef production as climate-friendly and sustainable as possible. The undersigned organizations support well-managed livestock production and are working to advance fair markets and policies that support sustainable beef ranchers in their efforts to protect vital resources, pay fair wages, and employ higher animal welfare practices.
Our analysis finds that the current USRSB framework will not help the U.S. beef sector — either individual producers or the entire industry — realize its great potential to minimize the severe environmental, climate, public health, animal welfare and other impacts of poorly managed cow-calf and feedyard operations. This is unfortunate because well documented research and evidence shows that well-managed ranches and farms can provide valuable benefits to society, including:
- reducing carbon pollution by storing it in the soil;
- increasing soil fertility;
- filtering rainfall runoff to maintain and restore water quality;
- enhancing recharge of ground and surface waters;
- conserving our natural heritage and protecting biodiversity;
- reducing routine non-therapeutic antibiotics use that create antibiotic-resistant superbugs;
- providing valuable recreational opportunities; and
- increasing access to healthier, more humanely produced, nutritious food.
Most of these benefits are generated by well-managed grass-based and grass-finished livestock systems — yet the framework does not explicitly recognize, incentivize or otherwise support these far more sustainable grass-based and grass-finished systems.
America urgently needs a more sustainable beef industry. This means ensuring that ranchers, farmers, and workers are paid fairly for their time and products, and producers are encouraged and supported to implement better management systems and practices. While we acknowledge your intentions to improve beef production practices, we stand strongly opposed to this framework and initiative in its current form because it does not meaningfully advance sustainability goals. We urge USRSB to change course.
Our comments below focus primarily on how the USRSB framework fails to address key structural issues related to sustainability and the most damaging impacts of the cow-calf and feedyard phases of production. However, our feedback also applies to all aspects of the framework and its inadequate approach for establishing effective incentive mechanisms, indicators, and performance measures. We also highlight USRSB’s failure to create a plan of action to address corporate consolidation and other core policy and regulatory issues that remain barriers to advancing sustainability.
In addition, we question the commitment of key USRSB industry leaders to advancing the core tenets of sustainability. This is because even while participating in the USRSB, leading corporate actors in the beef and restaurant industries (and their trade group representatives) have worked behind the scenes for years to prevent, delay or weaken federal and state policy protections for America’s environment, climate, public health, animal welfare, workers and producers.
We strongly encourage the USRSB to go back to the drawing board and develop a new framework and plan of action — including the need for regulatory change –– that generates far more environmental, economic, health and other benefits for stakeholders up and down the supply chain. We also recommend, at least for the time being, that the USRSB remove the term “sustainable” from its name and choose a more accurate term that does not undermine the value of credibly sustainable and regenerative beef production systems.
Below, we describe the impacts of poorly managed beef production that the USRSB framework must address, offer five reasons why the USRSB Framework fails to address these impacts and 10 recommendations for how the USRSB can foster true sustainability in the beef sector.
Serious Impacts Require Serious Action
Nearly 800 million acres of American lands are used for grazing (cow-calf phase, including stocker/backgrounder operations). Poor grazing management causes major environmental harm including:
- soil erosion and compaction and resulting declines in fertility, soil carbon, and water holding capacity;
- freshwater depletion and pollution;
- emissions of heat-trapping emissions, especially methane and nitrous oxide;
- habitat degradation, species endangerment and biodiversity loss;
- heightened vulnerability to drought and extreme weather;
- weed invasions that are often controlled using toxic herbicides harmful to native plants, wildlife, and public health; and
- conversion of native grasslands to irrigated pasture and hayfields.
The beef industry’s concentrated animal feeding operations, which pack together thousands of animals in tightly confined spaces, also cause severe impacts:
- surface and groundwater pollution (by nutrients, pathogens, pesticides, heavy metals, and pharmaceuticals);
- aquatic dead zones that deplete fisheries and harm fishing communities;
- heat-trapping pollution that worsens the climate crisis;
- air pollution, including highly toxic gases such as ammonia and hydrogen sulfide, stomach-turning odor and particulate matter that sickens workers and families and reduces property values in neighboring communities;
- inefficient water use and freshwater depletion;
- an overreliance on antibiotics to manage health problems created by grain-based diets and unhealthy conditions, fueling the dangerous rise of antibiotic-resistant “superbugs”;
- land conversion of native prairie to monoculture feed crop fields, reducing habitat and releasing millions of tons of carbon;
- declines in pollinators and predators of pests due to excessive use of toxic pesticides, particularly to genetically-modified feed crops; and
- inhumane treatment of animals.
In the interest of making beef production credibly more sustainable, we urge you to go back to the drawing board and commit to a major overhaul of the framework and metrics that will credibly address these impacts. In addition, we recommend that the USRSB develop a transparent joint plan of action for establishing policies, and regulatory and structural reforms that foster true sustainability in the U.S. beef sector.
Five Reasons Why the USRSB Framework is Deeply Flawed
- Failure to establish fair pricing mechanisms and address the consolidated structure of the U.S. beef marketplace.
- Lack of meaningful incentives, rewards and technical assistance for ranchers and farmers.
- The USRSB framework’s indicators, metrics, and SAGs are vague, weak, and inadequate for reducing and minimizing impacts and enabling vitally needed progress.
- Weak performance measures set a low bar, open the doors to greenwashing, muddy the waters of “sustainable” beef marketing claims and undercut efforts to recognize and reward credibly more sustainable producers and brands.
- Inadequate approach to feed production.
(see the full text of the letter for more details on these flaws and recommendations below)
Ten Recommendations for USRSB
- Processors, wholesalers and retailers should provide fair pricing mechanisms, concrete purchasing preferences, and price premiums to credibly well-managed operations that provide verifiably more environmental benefits to society.
- Improve the goals, indicators and metrics for the USRSB sustainability framework.
- Endorse and form partnerships with independent third-party certifiers of beef cattle products.
- USRSB corporate members should stop working to weaken, eliminate or otherwise undermine federal and state protections for America’s environment, climate, public health, animal welfare, workers and producers—a credible sustainable beef framework should support federal and state protections that safeguard America’s natural resources (e.g., air, water, soil, habitats and biodiversity), prohibit routine uses of antibiotics, and provide a fair economic return for producers, fair wages and safe conditions for workers, and higher animal welfare.
- USRSB members should pool resources and expand technical assistance to producers.
- Invest in infrastructure—especially local processing facilities—that supports the growth of small and mid-scale production for local, regional and value-added markets.
- Work with policy makers to create public/private investments in irrigation districts that need financial resources to improve infrastructure—particularly to offer producers flexible irrigation scheduling and pressurized water delivery, which many producers currently lack.
- Address barriers to greater sustainability on leased lands.
- Address barriers to advancing sustainability on federal public land grazing allotments managed by the U.S. Forest Service (USFS) and U.S. Bureau of Land Management (BLM).
- USRSB should work with partners in the insurance industry to offer (a) lower livestock loss and crop insurance premiums to producers who implement practices that improve soil health and resilience to our changing climate; and (b) lower livestock loss insurance premiums to producers who implement non-lethal practices for reducing conflicts with predators and other native wildlife.
If the beef industry is truly committed to supporting a scaled-up system for sustainability, we strongly encourage USRSB to address the concerns and recommendations that we have shared above. The goal should be to develop a well-designed solution system supported by effective federal and state policies and protections that (1) incentivize, enable and sometimes mandate good and improving management; (2) offer producers extensive technical assistance and increasing benefits for better results; and thus (3) generate a “race to the top” in which major retailers and brands both use the USRSB framework to raise the floor of their beef supply chains, and purchase an increasing percentage of their beef at fair prices from independent third-party certified sustainable suppliers.
Thank you for your consideration,
A Greener World, Antibiotic Resistance Action Center (George Washington University), Augustians, Cedar Circle Farm and Education Center, Center for Food Safety, Domestic Fair Trade Association, Earthjustice, Fair Farms, Family Farm Defenders, Farm Forward, Food Animals Concerns Trust, Food Democracy Now!, Food Tank, Food Works, Food and Water Watch, Friends Fiduciary Corporation, Friends of the Earth, Genesis Farm, GMO Free USA, The Good Food Brigade, Green America, Healthcare without Harm, IFOAM-Organics International, Illinois Stewardship Alliance, Institute for Agriculture and Trade Policy, Interfaith Center on Corporate Responsibility, Iowa Citizens for Community Improvement, John Hopkins Center for Livable Future, Kiss the Ground, Marist Fathers and Brothers, Mercola.com, MOMS Advocating Sustainability, Natural Resources Defense Council, North Carolina Environmental Justice Network, Northeast Organic Farming Association of Vermont, Oregon Natural Desert Association, Organic Consumers Association, Pesticide Action Network, Public Justice, Organization of Competitive Markets, Real Food Challenge, Regeneration International, Roots of Change, Sierra Club, Sisters of St. Francis of Philadelphia, Sisters of St. Joseph of Chestnut Hill, Sisters, Servants of the Immaculate Heart of Mary, Slow Food USA, Socially Responsible Agriculture Project and Turning Green