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November 16, 2015 HLPE consultation on the V0 draft of the Report: Sustainable agricultural development for food security and nutrition, including the role of livestock We commend the CFS HLPE in tackling the issue of livestock, food security and sustainable agriculture development. We believe, however, the draft report falsely assumes that increased industrial livestock operations are a necessary component of feeding the world. The reality is that we already produce enough food for close to 10 billion people on the planet today. 1 While we will need to increase food in some regions, efforts to enhance food security should focus primarily on supporting small-scale farmers and agroecological farming systems and shifting diets in developed countries towards more plants and less meat through nutrition and procurement policies, a trend that we are already seeing today in many Western countries. 2 While meat consumption will inevitably grow in many developing nations, we must pursue effective strategies and policies to ensure that meat consumption levels per capita in developing countries remain far below the typical western diet, and that there is wider availability of meat raised under healthier and more sustainable conditions. Finally, a stronger focus on waste reduction would also reduce the need to expand meat and grain production for factory-farmed animals. Specifically, our recommendations emphasize the following points: 1. Food security and nutrition (FSN) can best be achieved by supporting small and mid-sized farmers and agroecological farming systems, rather than intensive production practices, which require significant chemical and water intensive inputs and generate significant air and water pollution. 2. Reduced meat consumption offers large GHG mitigation and health advantages. 3. Developed nations’ consumers are already demanding meat alternatives. 4. There must be greater emphasis on harmful health impacts associated with industrialized animal production systems, especially irresponsible antibiotic use, growth hormones, and cancer and dioxin risks.

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November 16, 2015

HLPE consultation on the V0 draft of the Report: Sustainable agricultural development for food security and nutrition, including the role of livestock

We commend the CFS HLPE in tackling the issue of livestock, food security and sustainable agriculture development. We believe, however, the draft report falsely assumes that increased industrial livestock operations are a necessary component of feeding the world. The reality is that we already produce enough food for close to 10 billion people on the planet today.1 While we will need to increase food in some regions, efforts to enhance food security should focus primarily on supporting small-scale farmers and agroecological farming systems and shifting diets in developed countries towards more plants and less meat through nutrition and procurement policies, a trend that we are already seeing today in many Western countries. 2 While meat consumption will inevitably grow in many developing nations, we must pursue effective strategies and policies to ensure that meat consumption levels per capita in developing countries remain far below the typical western diet, and that there is wider availability of meat raised under healthier and more sustainable conditions. Finally, a stronger focus on waste reduction would also reduce the need to expand meat and grain production for factory-farmed animals.

Specifically, our recommendations emphasize the following points:1. Food security and nutrition (FSN) can best be achieved by supporting small and mid-

sized farmers and agroecological farming systems, rather than intensive production practices, which require significant chemical and water intensive inputs and generate significant air and water pollution.

2. Reduced meat consumption offers large GHG mitigation and health advantages.3. Developed nations’ consumers are already demanding meat alternatives.4. There must be greater emphasis on harmful health impacts associated with

industrialized animal production systems, especially irresponsible antibiotic use, growth hormones, and cancer and dioxin risks.

5. Report should highlight health benefits of pastured/grass-fed meat and organic/agroecologically produced food.

1. SMALL-SCALE AGROECOLOGICAL FARMING SYSTEMS ARE THE SOLUTION

Far from feeding the world, today’s industrial food system — backed by agribusiness-friendly trade and agriculture policies — accelerates global poverty and hunger through its exploitation of workers and displacement of farmers. Our dominant food system prioritizes mass-scale livestock and monoculture crop production, processed foods, biofuels and exports — all of which undermine small producers, public health and the growth of local, diversified and resilient farming communities. Ironically, millions of small farmers face some of the highest rates of poverty and hunger.3

As the world grapples with how to feed 9 billion people by 2050, overwhelming evidence shows that large-scale industrial food and farming practices are a major part of the problem, not the solution. Our industrial food system — based on monocultures and factory farms, genetically engineered seeds, and chemical pesticides and fertilizers — is rapidly depleting and degrading our soil, land and water.4 This food system is compromising resources that are essential for our

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future food security, while contributing to a major obesity epidemic and health care crisis that is costing the world hundreds of billions of dollars a year.

Agroecology provides a powerful solution — highly productive food systems that can amply feed the world while reducing fossil fuel use, saving water, restoring soils and building vitally needed carbon. A growing body of research, including a recent 2014 UC Berkeley meta-analysis, shows that diversified organic agriculture and agroecology systems are highly productive and can deliver yields just below or in some cases on par with industrial agriculture.5 Impressive research from the USDA shows that agroecological grain production, using fewer synthetic chemicals, can match or exceed U.S. industrial grain yields — particularly over the long term — while providing equal or higher profits to farmers.6

When produced on a smaller, more sustainable scale, animal agriculture can reduce emissions. Pastured and grass-fed livestock require less feed and enable manure to become a fertilizer, rather than a pollutant. As the USDA notes, pastured operations return manure directly to the soil rather than storing it in huge vats, producing fewer methane emissions. Permanent, properly managed grazing grasslands used as pastures, rangelands and hayfields can store great amounts of much-needed carbon, building climate resiliency and reducing GHG emissions.

Comments

“In terms of food availability at the global level, agriculture, including livestock, has recorded impressive progress in production over time, due to a combination of economic development, advances in technology, knowledge and improved management along the supply chain. This increased production has mostly occurred through specialization, intensification, industrialization and economies of scale that depend increasingly on inputs often grown outside the farm, including animal feed from the crop sector and non-renewable sources of energy.” (pg 9)

See comments above.

“The needed increase in agricultural production (including livestock) offers a huge opportunity to lift smallholders out of poverty.” (pg 13)

Lifting smallholders out of poverty requires systemic changes, including support for the millions of small-scale farmers worldwide who produce 70 percent of our food on 25 percent of farmland.7 Rather than increasing agricultural production, poverty reduction can be alleviated through technical assistance for small-scale farmers, protection against land grabs, and building climate resiliency through diversified, agroecological farming. Research published in the Journal of Peasant Studies shows that diversified Cuban farms exhibited crop losses fifty percent lower than neighboring monoculture farms during negative climate conditions, while showing a faster productive recovery. 8

“Second, by facilitating the correction of nutrient deficiencies and addressing undernutrition. For this increase in access to animal-sourced foods, livestock numbers need to increase, but so too will the productivity of these animals, the latter being particularly important if natural resources (particularly water) are to be used wisely, and environmental pressures and greenhouse gas emissions are to be mitigated.” (pg 26)

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While animal food products in small quantities may be necessary in developing nations for FSN, these needs can be satisfied through integrated livestock-crop farming systems. This section fails to account for the negative externalities of the large-scale industrial livestock sector (i.e. water pollution, grain dependence, corporate consolidation) as well as its tendency to lead to overproduction of livestock. A new UN Food and Agriculture Report, puts the cost of the environmental damage from agro-industrial production at $3.36 trillion annually, including $1.1 trillion in costs from livestock production.9 The same report finds that organic and agroecological alternatives, such as holistic grazing, greatly diminish these costs and can provide a path forward that more effectively sustains both humans and the planet.

“The WDR makes the case for liberalization of agricultural markets – domestically and globally – as an important means of revitalizing the sector in support of development and FSN. It notes, for example, that access to world priced imports of food staples can be pro-poor, including for smallholder agricultural producers who are net buyers of food. Similarly, removal of export restrictions on food, often intended to dampen prices in local markets, can hamper access of poor farmers to valuable export market opportunities and noting two-thirds of agricultural value added is in developing countries.” (pg 14)

Liberalizing trade regimes such as the WTO, NAFTA, and CAFTA only prioritize industrial production of export commodities while eroding public investments in small-scale diversified farming for local and regional consumption.10 These regimes promote input-intensive agriculture, pushing millions of farmers deep into debt, causing mass farm closures, poverty and migration.11

“The world is only able to support its present population because of the “green revolution”, which was driven by innovations in plant breeding, including mutation breeding, fertilizer and pest control.” (pg 48)

Others have noted that the “green revolution” actually led to environmental damage, reductions in biodiversity, loss of traditional knowledge, deep debt for poor smallholders and increased farm consolidation for the wealthier farmers.12 Furthermore, this analysis of the green revolution fails to account for an alternative scenario, in which more research and development could have been invested in agroecological solutions. Any modest yield gaps that do exist from industrial agriculture result primarily from a huge gap in public-funded research. In the US, less than 2% of agricultural research spending focuses on improving and expanding organic farming.13

“At the same time, opponents are concerned about currently unknown harmful effects, the escape of genetically modified organisms into the environment and the transfer of allergens into new foods (Buiatti et al., 2013).” (pg 48)

Agribusiness has pushed biotech crops in developing nations as a solution for hunger and drought – but it has failed in many cases, a Cornell University study found.14 Analysis by the Australian government found that “crops genetically engineered for drought tolerance have not been found to outperform traditional varieties.”15 Most GMO crops, including corn, soy and cotton, are grown primarily for animal feed, biofuels, fiber or ingredients for processed foods — and thus fail to address the root causes of hunger or deliver healthful benefits to consumers.

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“In a world of increasing competition for the scarce natural resources on which agricultural production depends, meeting future demands for FSN requires improving the efficiency of current use of inputs rather than expanding land and water inputs.” (pg 48)

See comments above.

“For example, industrial, intensive livestock operations tend to be efficient in production, but sometimes at the expense of water pollution and the welfare of animals, and depend on feedstuffs from the crop sector, with knock-on environmental effects. Extensive livestock operations tend to depend on pasture and conserve land at risk from erosion vulnerability, but sometimes at the expense of productive efficiency.” (pg 65)

As noted in our comments above, production efficiency is only one of many factors to be considered when looking at FSN. For example, pasture-raised livestock not only conserve land, but also offers increased carbon sequestration benefits,16 not to mention improved farmer livelihoods and decreased water pollution. To quote a Nature published paper, “When appropriately stocked and managed, grassland–ruminant ecosystems are an efficient, sustainable method of producing high-quality protein with minimal environmental impacts.”17

2. REDUCED MEAT CONSUMPTION OFFERS LARGE GHG MITIGATION ADVANTAGESThe Potsdam Institute for Climate Impact Research and the UN Intergovernmental Panel on Climate Change (IPCC)’s recent 2014 report on agriculture and climate change mitigation notes that reducing meat consumption would decrease non-CO2 greenhouse gas emissions more than technological mitigation options; combining both approaches would deliver even greater GHG reductions.18 According to Dr. Rajendra Pachauri, the past IPCC chair, “In terms of immediacy of action and the feasibility of bringing about reductions in a short period of time, it clearly is the most attractive opportunity. Give up meat for one day [a week] initially, and decrease it from there.”19

Comments

“The economic yield gap is accompanied by a similar environmental efficiency gap: numerous studies have shown that ASF from animals reared in more intensive and specialized systems have a relatively lower carbon footprint than those from extensive systems” (pg 48)

While many studies do find that intensive livestock systems have lower GHGs for enteric fermentation, feed production, and manure management, those same studies do not consider the carbon sequestration benefits of pasture based systems. Several studies have found that when those sequestration benefits are accounted for, pasture based systems can in fact lower overall GHG emissions.20,21,22,23 In any case, rather than focusing on a singular issue, such as GHGs, it is important to consider the overall environmental harm of intensive systems, and the potential environmental and economic benefits of agroecological alternatives. Meat and dairy raised in sustainable, organic, humane and well-managed pasture-based systems can reduce greenhouse gas emissions, increase climate resiliency, protect natural resources and enhance soil and water quality24,25,26 biodiversity, and pollinator health.27 These practices also improve public health and provide safer conditions for workers. Furthermore, as grass-fed pastures are often not suitable to intensive crop production, these systems can use

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marginal land to actually increase food security. All these factors should be taken into account.

3.3.1 GHG emissions from the livestock sector (pg 52)This section is missing the large GHG benefits from encouraging reduced livestock consumption.

“Mitigation (reduction or prevention) of the sector’s emissions could be achieved by a reduction in production and/or consumption, by an increase in production efficiency, or by shifting the structure of production towards less emission-intensive animal food types.” (pg 62)

This section could further stress the effects of consumption change on mitigation (see footnotes 18 and 19 in the section above).

3. DEVELOPED NATIONS’ CONSUMERS ARE DEMANDING MEAT ALTERNATIVESThe report’s focus on increasing livestock production fails to note that developed nations — who currently over-consume meat and animal products — are beginning to shift towards more nutritionally and environmentally sound plant-based diets. Research suggests that 36 percent of U.S. consumers prefer milk and meat alternatives and that between 26 and 41 percent of Americans have eaten less meat over the past year.28 In fact, many food service providers are aware of these trends and ready to provide such options. One Datassential study found that, “reducing the portion size of animal protein on menus is expected by nearly half of operators to increase the healthfulness of the entrees, and by over a third to increase the culinary innovation involved with the dishes.”29 The same survey found that meals with animal protein as a garnish, rather than as a central portion, appeal to half of consumers; and more than seventy percent of consumers were concerned about transparency in food sourcing.

Comments:

Projections (pg. 13)Implicit in these projections are that total global meat/animal product consumption will increase significantly — a scenario that does not have to happen.

“As diets become richer and more diverse, the livestock sector offers improvements to the nutrition of the vast majority of the world. Livestock products not only provide high-value protein but also are important sources of a wide range of essential micronutrients, in particular minerals such as iron and zinc, and vitamins such as vitamin A. By providing essential nutrients, especially in the critical first 1 000 days from conception, animal-sourced foods can help ensure normal physical and cognitive development. Well-nourished and well-educated children can grow up to be healthy young adults who are able to realize their full potential and contribute to family income-earning and national development. On the other hand, diets rich in livestock products, in particular red meats, are implicated in rising health concerns in some countries, although the scientific evidence and nutritional guidance has often changed through time and can be confusing to consumers.” (pg 28)

This paragraph should open with the acknowledgement that, in developed countries, industrially produced livestock food products are often implicated in some of the most pressing chronic health problems. High consumption of industrially produced meat, especially red and processed meat, is associated with increased risks of diet-related disease, including heart disease,30 diabetes31 and cancer.32 U.S. government guidance on

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need to consume less meat is clear. The 2010 USDA/HHS guidelines recommend no more than 1.8 ounce servings a day of red meat).33 It should also be emphasized that a plant-based diet is a nutritionally appropriate alternative that is beneficial to the health of people and the environment. The USDA,34 Academy of Nutrition and Dietetics,35 and other top health organizations agree that a well-planned vegetarian or vegan diet can provide all necessary nutrients and protein required for a healthy diet. And importantly plant-based diets are associated with decreased risks of all heart disease, diabetes and some cancers.36

Claims that red meat and processed meats are “nutrient dense” are misleading because they ignore all the harmful components of industrially produced meat:

4a. ANTIBIOTICSThe industrial system of food animal production is putting human health at risk due to misuse of vital antibiotics. Seventy to eighty percent of antibiotics sold37 in the United States go toward livestock production. These drugs are often used to accelerate animal growth and prevent diseases stemming from poor diets and crowded, unsanitary conditions, rather than for treatment of sick animals.38 In its 2013 report Antibiotic Resistance Threats in the United States, the CDC states: “Up to half of antibiotic use in humans and much of antibiotic use in animals is unnecessary and inappropriate and makes everyone less safe.”39

Comments:

“Livestock production and products also carry important health risks, especially in terms of food-borne disease, emerging diseases and occupational hazards. There are also social concerns such as human health, animal care and industrialization associated with livestock, with attendant social and economic costs.” (pg 8)

Antibiotic resistance should be included as a health risk.

“Risks in an interconnected world” (pg 50)

Antibiotic resistance should be included as a health risk.

4b. GROWTH HORMONESIndustrial meat production, specifically in the United States, relies heavily on the use of growth hormones and growth promoters in beef, pork and turkey production to fatten animals as quickly as possible with the least amount of feed. While this can be economically advantageous for meat companies and producers, it also may pose serious risks to humans, animals and the environment.40 Numerous studies have found potential links between zeranol (a growth hormone) intake and heightened risk for breast cancer.41

4c. CANCER RISKSThere is strong evidence that diets high in red meat (beef, pork, lamb) and processed meat (hot dogs, bacon, sausage, deli meats, etc.) increase the risk for colorectal cancer.42 Many epidemiologic studies have reported a modest but significant association between high intakes of processed meats and red meats and increases in cancer incidence and mortality in a dose-response relationship, as well as death from other causes.43,44 Both the American Institute for Cancer Research (AICR)’s Recommendations for Cancer Prevention and the American Cancer

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Society’s guidelines mention the importance of nutrition, including reduced red and processed meat, and physical activity for cancer prevention.45

In contrast, plant-based diets are associated with decreased risks of all heart disease, diabetes and some cancers.46

4d. DIOXIN RISKSAccording to the Environmental Protection Agency, 95 percent of our exposure to cancer-causing dioxin like compounds (DLC) come from meat, dairy, fish and shellfish.47 The Food and Drug Administration, Environmental Protection Agency, World Health Organization and National Academy of Sciences all agree that the best way to lower personal dioxin levels is to reduce dietary exposure to dioxins by lowering animal fat intake and increasing consumption of fruits, vegetables, and whole grains.48

5. HEALTH BENEFITS OF GRASS-FED/PASTURED MEATWhen consumed in moderation, responsibly raised meat and animal products can bring health benefits. Grass-fed and pastured meat and dairy provide a dense source for many of the shortfall nutrients identified in the DGAC’s report recommendations, including calcium, iron, and A, E, and B vitamins. Grass-fed meat is leaner than that produced in the grain-fed commodity system and, in the case of both meat and dairy, the fat profile is healthier than that of its grain fed counterparts. A 2010 review of three decades of research found that grass-fed beef provides higher levels of nutrients, including Omega-3 fats, beta-carotene, conjugated linoleic acid and Vitamin E than grain-fed beef.49 A 2013 study published in PLoS ONE found that grass-fed organic dairy has far higher levels of Omega-3 fats than grain-fed dairy.50

REFERENCES

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1 http://www.researchgate.net/publication/241746569_We_Already_Grow_Enough_Food_for_10_Billion_People__and_Still_Can't_End_Hunger2 http://www.foodnavigator-usa.com/Markets/Vegan-is-going-mainstream-trend-data-suggestshttp://www.foodnavigator.com/Market-Trends/Young-Germans-embrace-meat-reduction3 http://apps.unep.org/publications/pmtdocuments/Agriculture_at_a_Crossroads_Global_Report.pdf4 http://www.fao.org/fileadmin/templates/nr/sustainability_pathways/docs/Final_Natural_Capital_Impacts_in_Agriculture_-_Supporting_Better_Business_Descision-Making_v5.0.pdf5 http://rspb.royalsocietypublishing.org/content/282/1799/201413966 http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0047149#pone-0047149-g0037 http://www.fao.org/fileadmin/templates/nr/sustainability_pathways/docs/Coping_with_food_and_agriculture_challenge__Smallholder_s_agenda_Final.pdfhttps://www.grain.org/article/entries/4929-hungry-for-land-small-farmers-feed-the-world-with-less-than-a-quarter-of-all-farmland8 http://www.tandfonline.com/doi/full/10.1080/03066150.2010.538584#abstract9 http://www.fao.org/fileadmin/templates/nr/sustainability_pathways/docs/Final_Natural_Capital_Impacts_in_Agriculture_-_Supporting_Better_Business_Descision-Making_v5.0.pdf10ity of Michigan note. Hit by climate volatility, industrial farming systems “may experience lower productivity, higher vulnerability”11ty, and reduced sustainability Research in the American Journal of Alternative Agriculture found that organic soils hold in more water than conventional plots, allowing for yields that are less affected by drought periods. D.W. Letter, R12 http://monthlyreview.org/2009/07/01/agroecology-small-farms-and-food-sovereignty/#fn113 http://food.berkeley.edu/wp-content/uploads/2014/09/JAFSCD_Closing_Knowledge_Gap_Commentary_Sept-2013.pdf14 http://www.annualreviews.org/doi/abs/10.1146/annurev.energy.31.031405.09131415 http://bioscience.oxfordjournals.org/content/61/3/183.full.pdf+html16 http://www.sciencedirect.com/science/article/pii/S026974910100223817 http://www.nature.com/nature/journal/v418/n6898/full/nature01014.html18 Intergovernmental Panel on Climate Change. (2014). Ch. 11: Agriculture, Forestry and Other Land Use (AFOLU).19 http://www.theguardian.com/environment/2008/sep/07/food.foodanddrink20 Pelletier N, Pirog R, Rasmussen R. (2010) Comparative life cycle environmental impacts of three beef production strategies in the Upper Midwestern United States. Agricultural Systems 103(6):380-389.21 https://kb.wisc.edu/dairynutrient/375fsc/page.php?id=4843122 http://www.nationaltrust.org.uk.23 http://www.sciencedirect.com/science/article/pii/S026974910100223824 Poudel DD, Horwath WR, Lanini WT, Temple SR, van Bruggen AHC. (2002). Comparison of soil N availability and leaching potential, crop yields and weeds in organic, low-input and conventional farming systems in northern California. Agriculture, Ecosystems & Environment.25 Dalgaard T, Halberg N, Kristensen IS. (1998). Can organic farming help to reduce N-losses? Nutrient Cycling in Agroecosystems.26 Bulluck LR, Brosius M, Evanylo GK, Ristaino JB. (2002). Organic and synthetic fertility amendments influence soil microbial, physical and chemical properties on organic and conventional farms. Applied Soil Ecology. 27 Tuck SL, Winqvist C, Mota F, Ahnström J, Turnbull LA, Bengtsson J. (2014). Land-use intensity and the effects of organic farming on biodiversity: a hierarchical meta-analysis. Journal of Applied Ecology.

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28 Crawford, E. (2015, March 17). Vegan-is-going-mainstream-trend-data-suggests. Retrieved September 14, 2015, from http://www.foodnavigator-usa.com/Markets/Vegan-is-going-mainstream-trend-data-suggests. 29 http://www.menusofchange.org/images/uploads/pdf/CIA-Harvard_MenusofChange_AnnualReport_2015a1.pdf30 Pan A1, Sun Q, Bernstein AM, Schulze MB, Manson JE, Stampfer MJ, Willett WC, Hu FB. (2012) Red Meat Consumption and Mortality: Results from 2 Perspective Cohort Studies http://www.ncbi.nlm.nih.gov/pubmed/2241207531 Pan A., Sun Q., Bernstein A. M., Schulze M. B., Manson J. E., Willett W. C., et al. (2011). Red meat consumption and risk of type 2 diabetes: 3 cohorts of US adults and an updated meta-analysis. Am. J. Clin. Nutr.32 Cross AJ, Leitzmann MF, Gail MH, Hollenbeck AR, Schatzkin A, et al. (2007) A Prospective Study of Red and Processed Meat Intake in Relation to Cancer Risk. PLoS Med.33 USDA and HHS (2010), Dietary Guidelines for Americans34 USDA, Healthy Eating Tips. http://www.choosemyplate.gov/ten-tips-healthy-eating-for-vegetarians 35 Craig WJ, Mangels AR. (2009). Position of the American Dietetic Association: vegetarian diets. J Am Diet Assoc. 36 Tuso P, Ismail M, Ha B, and Brolotto C. 2013. Nutritional Update for Physicians: Plant-Based Diets. Perm J. Spring; 17(2): 61–66. http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3662288/37 The Pew Charitable Trusts. “Record-High Antibiotic Sales for Meat and Poultry Production.” Accessed online, April 7, 2015, http://www.pewtrusts.org/en/about/news-room/news/2013/02/06/recordhigh-antibiotic-sales-for-meat-and-poultry-production. 38 Khachatourians, G. Agricultural Use of Antibiotics and the Evolution and Transfer of Antibiotic-Resistant Bacteria. Canadian Medical Association Journal 159 (1998): 1129-1136. http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1229782/ ; Jukes, T. The Present Status and Background of Antibiotics in the Feeding of Domestic Animals. Annals of the New York Academy of Sciences 182 (1971): 362-379.39 http://www.cdc.gov/drugresistance/pdf/ar-threats-2013-508.pdf40 Newbold, R. & Heindel, J. (2010). Developmental exposures and implications for early and latent disease. InT.J. Woodruff, S. J. Janssen, L.J. Guillette, Jr, L.C. Giudice.  (Eds), Environmental Impacts of Reproductive Health and Fertility. (92-102). New York: Cambridge University Press. ; Diamanti-Kandarakis, E., Bourguignon, J.P., Giudice, L.C., Hauser, R., Prins, G.S., Soto, A.S., Zoeller, R.T., & A.C. Gore (2009). Endocrine-disrupting chemicals: an Endocrine Society scientific statement. Endocrine Review, 30(4), 293. doi: 10.1210/er.2009-0002.. 41 Belhassen, H., Jiménez-Díaz, I., Arrebola, J., et al. (2015). Zearalenone and its metabolites in urine and breast cancer risk: A case-control study in Tunisia. Chemosphere, 128, 1-6. 30(4) doi: 10.1016/j.chemosphere.2014.12.055; Lin, Y., Liu, J., Lin, S., et al. (2010). Zeranol may increase the risk of leptin-induced neoplasia in human breast. Oncology Letters, 2(1). doi:  10.3892/ol.2010.214; Xu, P., Ye, W., Jen, R., et al. (2015). Mitogenic activity of zeranol in human breast cancer cells is enhanced by leptin and suppressed by gossypol. Anticancer Research, 29(11). Retrieved from http://www.ncbi.nlm.nih.gov/pubmed/20032412.42 World Cancer Research Fund/American Institute for Cancer Research. Continuous Update Project Report. Food, Nutrition, Physical Activity, and the Prevention of Colorectal Cancer. 2011.43 Kushi LH, Doyle C, McCullough M, et al. American Cancer Society Guidelines on Nutrition and Physical Activity for Cancer Prevention: Reducing the Risk of Cancer With Healthy Food Choices and Physical Activity. CA Cancer J Clin 2012; 62: 30-67.44 Sinha R, Cross AJ, Graubard BI, Leitzmann MF, Schatzkin A. Meat intake and mortality: a prospective study of over half a million people. Arch Intern Med. 2009; 169:562-571.45 Kushi, L. H., Doyle, C., McCullough, M., Rock, C. L., Demark‐Wahnefried, W., Bandera, E. V., ... & Gansler, T. (2012). American Cancer Society guidelines on nutrition and physical activity for cancer prevention. CA: A Cancer Journal for Clinicians, 62 (1), 30-67.46 Tuso P, Ismail M, Ha B, and Brolotto C. 2013. Nutritional Update for Physicians: Plant-Based Diets. Perm J. Spring; 17(2): 61–66. http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3662288/

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47 Food and Drug Administration, A Veterinarian Newsletter July/August 2000 Volume XV, No IV48 Federal Interagency Working Group on Dioxin, Questions and Answers about Dioxins, July 2000http://www.epa.gov/ncea/pdfs/dioxin/dioxin%20questions%20and%20answers.pdf49 Daley CA, Abbott A, Doyle PS, Nader GA, Larson S. (2010). A review of fatty acid profiles and antioxidant content in grass-fed and grain-fed beef. Nutrition Journal.50 Benbrook CM, Butler G, Latif MA, Leifert C, Davis DR. (2013). Organic Production Enhances Milk Nutritional Quality by Shifting Fatty Acid Composition: A United States-Wide, 18-Month Study. PLoS One.