Science - USA (2022-04-08)

INSIGHTS | POLICY FORUM

GRAPHIC: K. FRANKLIN/

SCIENCE

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The USDA should establish a rigorous veri-

fication system to ensure that RWA claims

are truthful and accurate, or they should

cease approving these labels. For meaning-

ful verification, the USDA should conduct

or require continuous, on-site empirical test-

ing for antibiotics on a meaningful number

of animals from every lot delivered for pro-

cessing. For testing to be effective, the USDA

must move beyond maximum residue levels

and use sensitive, real-time technologies that

identify animals that have been treated with

antibiotics. Lots testing positive should be re-

routed and sold on the conventional market.

Positive lots should be tracked and published

on a public ledger. Repeat offenders should

be excluded from supplying animals for RWA

programs until they can demonstrate that

they have taken meaningful steps to elimi-

nate undisclosed antibiotic use.

To ensure that animal welfare is not pit-

ted against the financial welfare of produc-

ers, the USDA must eliminate the financial

disincentives for treating sick animals. We

recommend that the USDA create a fund

to compensate RWA producers for lost pre-

miums if they are periodically forced to ad-

minister antibiotics and segregate animals

from the RWA market. To offset expenses

of robust verification and animal-welfare

compensation, we recommend that the

USDA implement a RWA label user fee. This

should help ensure that these new costs are

passed to RWA producers, retailers, and

consumers of RWA products rather than

placing the burden on the general public.

Until the USDA acts, additional studies

such as ours could weaken confidence in

the RWA labels and decrease consumers’

willingness to pay for these products. Re-

tailers can limit these undesirable outcomes

by taking responsibility for the integrity of

the food they sell and implement a robust,

industry-wide standard that incorporates

empirical testing, strict enforcement, and

transparent administration.

Growing demand for RWA meats and

poultry has the potential to curb antibiotic

use in food-animal production; however,

the integrity of the USDA’s RWA labels is

being undermined by lax verification and

enforcement. Until either the USDA acts

to rigorously verify RWA claims or retail-

ers eliminate their own safe harbor of ig-

norance, consumers should not rely on the

accuracy of these labels. j

REFERENCES AND NOTES

1. C. Dubois, A.M. Roerink, “Mid-Year Meat Department
   Performance Review, Animal Protein Reigns High Amid
   Pandemic; What’s Next?” IRI, June 2020; https://www.
   iriworldwide.com/IRI/media/Library/IRI-Mid-Year-
   Meat-Performance.pdf.


2. N. D. Fortin, Credence Claims and Conditional Labeling
   in Food Regulation: Law, Science, Policy, and Practice
   (Wiley, ed. 2, 2017), chap. 6, pp. 107–115.


3. E. T. Page, G. Short, S. Sneeringer, M. Bowman, “The
   Market for Chicken Raised Without Antibiotics,” 2012–
   17, EIB-224, US Department of Agriculture, Economic
   Research Service (September 2021).


4. B. Holmstrom, Bell J. Econ. 10 , 74 (1979).


5. M. Bowman, K. Marshall, F. Kuchler, L. Lynch,
   Am. J.Agric. Econ. 98 , 622 (2016).


6. USDA, “Food Safety and Inspection Service labeling
   guideline on documentation needed to substantiate
   animal raising claims for label submissions, December
   2019”; https://www.fsis.usda.gov/sites/default/files/
   media_file/2021-02/RaisingClaims.pdf.


7. USDA, “Residue Sampling Plan: Fiscal Year 2020 Blue
   Book,” December 2019; https://www.fsis.usda.gov/
   node/1982.


8. Global Animal Partnership, “Our Standards”; https://
   globalanimalpartnership.org/standards/.


9. USDA, “Organic Livestock Requirements,” July 2013;
   https://www.ams.usda.gov/sites/default/files/media/
   Organic%20Livestock%20Requirements.pdf.


10. C. D. Reinhardt, M. E. Hubbert, Appl. Anim. Sci. 31 , 101
    (2013).


11. R. Singer et al., Front. Vet. Sci. 6 , 452 (2019).


12. United States Court of Appeals for the Ninth Circuit,
    “Robert Cohen, a consumer, on behalf of himself
    and all others similarly situated, Plaintiff-Appellant,
    v. Conagra Brands, Inc., a Delaware corporation”
    (2021); https://cdn.ca9.uscourts.gov/datastore/opin-
    ions/2021/10/26/20-55969.pdf.


13. United States Court of Appeals for the Ninth Circuit,
    Robert Cohen, Plaintiff-Appellant, v. Conagra Brands,
    Inc., Defendant-Appellee, Appellee’s Answering Brief
    (2021); https://www.law360.com/dockets/documents
    /602ea2afef2b439ca7120489.


14. M. Ollinger, J. Bovay, Am. J. Agric. Econ. 102 , 186 (2020).


15. S. A. Starbird, Am. J. Agric. Econ. 87 , 15 (2005).

ACKNOWLEDGMENTS

We thank M. Ollinger and T. Roberts for reviewing the manu-

script and for providing valuable insights. We also thank S.

Levitan for data visualization, manuscript review, and editing.

Antibiotic testing was funded by Food In-Depth Inc. All data,

except for the identities of the feedyards and processing

plant, are available in the supplementary materials.

SUPPLEMENTARY MATERIALS

science.org/doi/10.1126/science.abj1823

10.1126/science.abj1823

A

AA

AB

AC

AD

AE

AF

AG

B C D E F G H I J K L M N O P Q R S T U V W X Y Z

Feedyard

One Lot

No positive tests One positive test All positive tests

No positive tests

85% of cattle

One positive test

10% of cattle

All positive tests

5% of cattle

Average lot size:

122 cattle

Average number

tested from each lot:

2

Total animals

tested:

699

Total animals

from all lots:

38,219

Raised with antibiotics

(Right) Antibiotic testing results for 312 lots of cattle

from 33 feedyards. Each box represents a single lot

in sequential testing order. (Below) Percentage of 38,219

cattle coming from lots in which zero tests were

positive, one test was positive, or all tests were positive.

See supplementary materials for details and data.

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