SCIENCE science.organd -exporting nations, must be approved
by the US Department of Agriculture
(USDA). Although USDA-approved labels
give RWA claims credibility and value in
the marketplace ( 3 ), the agency does not
require empirical antibiotic testing to vali-
date them. Absent verification, there are
incentives for parties throughout the sup-
ply chain to cheat or limit scrutiny ( 4 ). We
present empirical evidence that some beef
cattle processed for the RWA market have
been administered antibiotics and propose
policies to reform the system.
Consumers choose RWA meats for both
private and public benefits. Some consum-
ers make this choice because they believe
it is safer and healthier for them. Others
may choose RWA products to support mar-
ket-based efforts to reduce antibiotics in
food-animal production and preserve the
effectiveness of these critical medicines
( 5 ). However, neither public nor private
benefits can be achieved if RWA labels are
applied to animals that have been treated
with antibiotics.
RWA label claims that are approved by the
USDA through the Food Safety Inspection
Service (FSIS) include “Raised Without
Antibiotics,” “No Antibiotics Administered,”
“No Added Antibiotics,” “Raised Antibiotic
Free,” and “No Antibiotics Ever.” Producers
wishing to market their products with one
of these labels must submit (i) a description
of controls to ensure that animals are not
given antibiotics; (ii) a protocol for trac-
ing and segregating RWA products; (iii) a
protocol for identifying and segregating
nonconforming animals (i.e., those treated
with antibiotics); and (iv) a signed affidavit
describing how the animals were raised to
support label claims ( 6 ). The USDA does not
conduct or mandate empirical antibiotic
testing for these labels.
Although the USDA occasionally tests
for antibiotic residues in meat animals,
these tests are not conducted to verify
RWA claims. Among the more than 9 bil-
lion animals that are slaughtered in the US
for meat each year, the USDA tests fewer
than 7000 for antibiotics through the US
National Residue Program. Technicians
from this program conduct tests to deter-
mine whether antibiotics in target tissues
exceed their maximum residue limits (a
threshold defined as safe for public con-sumption) and effectively blind themselves
to antibiotics below these concentrations
( 7 ). The National Residue Program is not
designed to assess RWA claims and is not
used to do so.
Other programs, including the Global
Animal Partnership’s Animal Welfare
Certified Program and the USDA’s National
Organic Program, prohibit the use of anti-
biotics in beef cattle and lend credence to
RWA claims ( 8 , 9 ). Beef products are often
branded with multiple label claims, includ-
ing RWA, Animal Welfare Certified, and
Organic, which implies added layers of
scrutiny. However, none of these programs
require empirical antibiotic testing.
RWA cattle generate increased price pre-
miums over conventional products at every
step along the supply chain (fig. S1). There
are also increased costs associated with
RWA production, so these premiums should
not be interpreted simply as added profit.
For example, cow–calf operators—the farm-
ers and ranchers who raise beef cattle—
spend more money on supplements and
spend more time weaning calves without
antibiotics. Feedyards—the companies that
fatten cattle for market—pay higher prices
for RWA cattle and then take on the added
expenses of feeding animals longer with
less energy-rich diets to reduce the risk of
liver abscesses without antibiotics ( 10 ).
Cattle producers use antibiotics to treat,
control, and prevent infections. In the ab-
sence of robust verification, the prospect of
sick animals creates a dilemma: Producers
must decide whether to withhold antibiot-
ics and potentially sacrifice animal welfare;
openly administer antibiotics and forgo
investments and premiums; or covertly ad-
minister antibiotics and enjoy the benefits
of treatment without the costs. From the
perspectives of animal welfare and con-
sumer protection, openly treating animals
is the best option; however, this places a fi-
nancial burden on cow–calf operators and
feedyards ( 11 ). This also creates supply dis-
ruptions for processors and retailers, who
can experience lost revenue, lower plant
utilization, and reduced customer confi-
dence. The stakes are highest for retailers
that exclusively sell RWA meats as they can-
not substitute with conventionally labeled
products when supplies are disrupted.
This could mean costly periods with empty
shelves and missing menu items. In a sys-
tem characterized by lax verification and
enforcement, these financial incentives may
be difficult to overcome.
In a well-functioning market, concern
for one’s reputation should counterbal-
ance the incentives to cheat. In the case
of RWA labels, the USDA grants credence
and also confers a degree of liability protec-tion. The law states and courts confirm that
the USDA has sole authority to determine
whether meat labels are truthful and accu-
rate. Thus, an approved USDA label cannot
be deemed false or misleading by any entity
other than the USDA, even when the evi-
dence suggests otherwise ( 12 ). This changes
every player’s risk calculation. For example,
retailers can avoid doing their own qual-
ity control by relying on the legal safe har-
bor granted by an approved USDA label.
Indeed, meat companies refer to the USDA’s
duty to review and approve meat labels as a
means of preempting consumer protection
laws when challenged in court for mislabel-
ing products ( 13 ). These incentives further
limit scrutiny on a set of claims that are oth-
erwise relatively easy to confirm.
To determine whether antibiotic-treated
animals are making their way into the RWA
supply chain, we tested for antibiotics in
urine from beef cattle being slaughtered for
the RWA market. All of the cattle were part
of a “No Antibiotics Ever” program, with a
subset produced under the third-party–au-
dited Global Animal Partnership program
(see supplementary materials). Using a
rapid immunoassay that screens for 17 anti-
biotics commonly administered in feed and
water, we sampled animals from every lot
of RWA cattle delivered for processing at a
single slaughter facility over the course of
7 months (mean lot size = 122 cattle; mean
number of animals tested per lot = 2). A to-
tal of 699 animals were tested from 312 lots
and 33 different RWA-certified feedyards
(see the figure). The 312 lots sampled in this
study included 38,219 head of cattle, repre-
senting ~12% of US RWA beef production
for this period.
Three feedyards (9%) had multiple lots in
which all samples tested positive for anti-
biotics; 4 feedyards (12%) had all samples
test positive in a single lot; 7 (21%) had a
positive sample in more than one lot; and 14
(42%) had at least one animal test positive
(see the figure). Lots with at least one posi-
tive test represented ~15% of the RWA cattle
processed at the slaughter facility during
the study period (see the figure). These find-
ings provide empirical evidence that a ma-
terial portion of beef products currently be-
ing marketed with RWA labels is from cattle
that were treated with antibiotics.
These findings suggest that today’s RWA
labels lack integrity. Although our testing was
limited to beef cattle, other meat and poultry
sectors are vulnerable to similar incentives.
To protect consumers and restore the integ-
rity of RWA labels, we recommend the follow-
ing policy reforms grounded in the literature,
which has shown that testing programs with
robust standards and public disclosure can
overcome incentives to cheat ( 4 , 14 , 15 ).(^1) Antibiotic Resistance Action Center, Environmental and
Occupational Health, Milken Institute School of Public
Health, George Washington University, Washington, DC,
USA.^2 Food In-Depth, San Mateo, CA, USA.
Email: [email protected]
Feedyards face added expenses to feed cattle
longer and with less energy-rich diets to reduce the
risk of liver abscesses when not using antibiotics.
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