Whole Foods introduces multi-tiered animal welfare certification

From ANIMAL PEOPLE, November/December 2010:
AUSTIN, WASHINGTON D.C.– The 300-store
Whole Foods Markets chain and the Animal
Compassion Foundation, begun by Whole Foods
founder John Mackey, on November 15, 2010
introduced a new system of identifying how
animals slaughtered for meat were raised. The
first standards are for pigs, cattle, and
chickens raised for meat. After a trial interval
the system is to be extended to laying hens and
dairy animals.

Managed by Global Animal Partnership, an
operating name used by the Animal Compassion
Foundation, the tiered certification system
began with more member producers than all other
U.S. farm animal welfare certification programs
combined, just by including all Whole Foods
suppliers. The program is designed, however,
to draw other producers and retailers into
Global Animal Partnership uses an
acronym, GAP, which already has a high
recognition factor from generic use by
agricultural media to designate all programs
which identify Good Agricultural Practices.
GAP allows consumers to choose among
color-coded steps that indicate progressively
higher levels of animal welfare achieved by the
producers. The color codes are to be explained
by signage displayed with the labeled products in
stores. Products not reaching Step 1 are not
sold by Whole Foods. The intended entry-level
steps 1-3 are identified by orange strips; steps
4-5 and 5+ are identified by green strips. Step
1 certification is to mean “No cages, no
crowding”; Step 2 is to mean “Enriched
environment”; Step 3 is to mean “Enhanced
outdoor access”; Step 4 requires a “pasture
centered” husbandry regimen; Step 5 is to mean
“Animal centered; bred for outdoors”; and Step
5+ is to mean “Animal centered; entire life on
same farm.”
The stated goals of the Step 1
requirement parallels the goals of the 2008
California ballot initiative that introduced a
phased-in ban of pig gestation stalls and veal
crating (and battery caging of laying hens, not
yet covered by GAP), but are spelled out in more
detail, with further requirements and
recommendations for producers that point toward
eventually qualifying for more advanced
certification. GAP steps 4-5 and 5+ mostly
overlap the standards required for the Certified
Humane label program administered by Humane Farm
Animal Care and the Animal Welfare Approved
program created by the Animal Welfare Institute.
The standards of the American Humane Certified
program run by the American Humane Association
are inconsistent with those of the other
programs, but appear to be mostly in the GAP
middle range.
There are differences among the programs,
however, including in guiding philosophy. The
Animal Welfare Approved program, for instance,
excludes corporate farmers. Thus, though the
Animal Welfare Approved label has attracted three
times more users than the Certified Humane and
American Humane Certified labels for farm
products, the Animal Welfare Certified label
appears to hold far less market share and has
little chance of directly influencing most major
animal producers, almost all of which are
A leading concern of Adele Douglass, who
founded the AHA program and then founded HFAC to
pursue stricter standards three years later, and
of Cathy Liss, who founded Animal Welfare
Approved, is that consumers may perceive any
level of GAP certification as being equivalent to
the higher GAP levels and to AWC and Certified
Humane, with the possible net effect of
undercutting AWC and Certified Humane progress.
This concern is shared by ANIMAL PEOPLE
president Kim Bartlett. “My perception,” she
said, “is that meat consumers don’t want to know
the details of the animal’s life and death. If a
product has any sort of animal welfare
certification, that will be enough information
for them. If consumers are interested in the
differences between five or more steps, they are
likely to not buy meat at all. I worry that
having so many different animal welfare labels
will just confuse the public and for the most
part assuage their consciences, and meanwhile
the industry will not have a lot of incentive to
make meaningful change.”
A further question is whether Whole Foods
consumer behavior, even if favoring higher
animal welfare by paying higher prices for
higher-rated meats, will be mirrored in the
mainstream marketplace. The upscale Whole Foods
clientele pay higher prices for perceived higher
quality in buying any product–but people on
tight budgets tend to shop elsewhere.
Initially developed for Whole Foods and
tested for six years in Whole Foods stores, the
GAP system is based on standards originally
drafted for Whole Foods by Colorado State
University livestock handling expert Temple
Grandin, whose career was documented in the Home
Box Office film Temple Grandin, winner of five
Emmy Awards in August 2010.
Miyun Park, GAP executive director since
September 1, 2009, in 1997 cofounded the farmed
animal advocacy group Compassion Over Killing.
CoK rose to prominence in 2003-2006 by
successfully challenging the veracity of the
United Egg Producers “Animal Care Certified”
program in appeals to the Council of Better
Business Bureaus, National Advertising Review
Board, and Federal Trade Commission. Park was
later vice president for farm animal welfare for
the Humane Society of the U.S. and Humane Society
The GAP board includes Mackey, who
recently retired as Whole Foods board chair;
Whole Foods global vice president of quality
standards Margaret Wittenberg; HSUS president
Wayne Pacelle; World Society for the Protection
of Animals director general Mike Baker;
Compassion in World Farming director of public
affairs Joyce D’Silva; PETA corporate consultant
Steven Gross, and three representatives of
organic agribusiness.
The evolution of the Whole Foods
standards into GAP began, Mackey told Amanda
Griscom Little of Grist in 2004, when “After
dialoguing with PETA, VIVA, Animal Rights
International, and the Animal Welfare Institute,
we decided that our existing standards for humane
animal treatment were not rigorous enough. We
began a process of working with these groups and
our producers to develop standards species by
Mackey at the same time formed the Animal
Compassion Foundation to administer the Whole
Foods standards. The first Whole Foods standards
were for ducks, followed by standards for sheep,
pigs, and cattle raised for beef. The Whole
Foods standards for ducks and sheep have not yet
been adapted for use by GAP, which has focused
on standards for the species most often raised to
be slaughtered for human consumption. (Laying
hens today are most often either slaughtered for
animal consumption or macerated alive into
fertilizer at the end of their productive lives.)

Fans & Critics

“Whole Foods has consistently done more
for animal welfare than any retailer in the
industry,” declared PETA, giving Mackey a
“Proggy Award” in 2004. Visiting 200 stores in
34 states, WSPA found in 2008 and 2009 that
Whole Foods soffered “twice as many humanely
labeled products per store as the two companies
tied for second.”
But animal rights attorney and author
Gary Francione called a boycott of Whole Foods
for selling products while purporting to be
humane. Robert Ovetz of the Sea Turtle
Restoration Project objected that Whole Foods,
claiming to have stocked only turtle-safe seafood
since 1999, does business with producers and
agencies whose records are not all that they
claim. ANIMAL PEOPLE reader Irene Muschel, of
New York City, wrote to object to Whole Foods’
sale of goose and duck liver pat├ęs, which
technically are not foie gras because the birds
are not force-fed.
“If you speak to the totally pure, you
will cease to exist as a business,” Mackey told
Little. “I made these decisions 25 years ago.
My first store was called Safer Way. I opened it
in 1978. It was a vegetarian store. We did
$300,000 in sales the first year. When we made
the decision to open a bigger store, we made a
decision to sell meat, seafood, beer, wine,
and coffee. We didn’t think they were
particularly healthy products, but we are a whole
food store, not a holy food store.”

Difficult promise

“There will be no mutilations,” Mackey
promised Little in 2004. “Most livestock animals
are mutilated when they’re doing intensive
living, and they have their beaks partially cut
off and their toes amputated without any type of
anesthesia. We’re forbidding that.” But Whole
Foods and GAP have found Mackey’s promise hard to
The GAP standards, below Step 5, allow
that cattle and pigs may be castrated.
Forbidding castration, however, may be
impractical for all but upscale niche pig and
cattle producers. “Boar taint” in pork may be
avoided by slaughtering pigs before puberty, but
that also requires slaughtering them before they
approach the usual market weight for pigs
slaughtered for sale to mainstream consumers.
Castrating bulls to produce steers is done to
avoid fighting within herds, which would be
inevitable in pasture or on the open range.
The GAP standards through Step 5 allow
that young cattle may be dehorned by debudding,
but GAP requires that herds be bred toward
producing “polled” (hornless) cattle. Pigs’
tails may be docked if injured by tail-biting in
a manner that might attract more biting, but GAP
requires that tail-docking may not be done
routinely and that the emphasis of producers must
be on prevention.
The GAP standards for chickens raised for
meat at all levels forbid any physical
alteration, including beak trimming, but GAP
has not yet issued standards for laying hens,
the poultry who are most often debeaked.
Altogether the GAP entry level standards
include more than 60 improvements for raising
each species over agribusiness norms. The GAP
requirements at Steps 1-3, including those for
livestock transport, often echo industry
recommendations, but the industry
recommendations are rarely enforced by any
supervisory body. As producers advance from
Step 1 to Steps 5 and 5+, the top end of the GAP
scale, they will have to accomplish more than
120 improvements over current norms.
“GAP’s 5-Step program is very different
from pass/fail certification schemes such as
Certified Humane and American Humane Certified,”
Pacelle told ANIMAL PEOPLE. “While a step level
in GAP’s multi-tiered system may have
requirements that are below, equal to, or
higher than a comparable requirement in a
single-tiered program, the 5-Step design
promotes continuous improvement.”
Corrected Park, “GAP’s 5-Step program
is also pass/fail, but it differs in that
producers can pass or fail at a number of
different Step levels. One of our goals is to
empower and facilitate producers to move up the
welfare ladder. We’ve already seen this
happening,” Park said, “with some producers
making positive changes to reach a certain step
level, and then making further improvements to
move up to a higher step.
“Step 1 and, to a lesser degree, Step 2
are meant to engage producers,” Park said. “If
we cannot engage a broad spectrum of producers
and instead work only within the niche
agricultural community,” who produce chiefly for
specialty markets, “we won’t be able to help as
many animals.”
“Unlike government regulation,” observed
Monica Eng of the Chicago Tribune , “the GAP
program is all carrot and no stick, offering
entrepreneurs very specific credit for gradual
improvements. In turn, they get access to Whole
Foods’ customers. Whole Foods says that about
1,000 farms have been or are going through
third-party GAP auditing, and a few hundred are
awaiting the process. Most are small regional
producers, but they also include big national
names like Pennsylvania-based chicken producer
Bell & Evans,” currently at Step 2, “and Niman
Ranch pork producers,” a longtime participant in
other animal welfare labeling schemes, “which
are still in the auditing process.”
“This is the first time we get to see how
much the public is willing to pay for specific
practices,” PETA consultant and GAP board
member Gross told Eng. “Let’s say I’m a meat
eater and I think animals should live on pasture;
I would buy a three and above. Or maybe I just
want to make sure they don’t live in cages; I
would buy a one or a two.”

Judgement calls

AWA is usually considered to have the
highest certification standards, with HFAC
having the highest standards that are accessible
to corporate producers. But, said Park, “I
respectfully disagree that HFAC and/or AWA’s
requirements are more stringent than our higher
Step levels. At Step 5+, we prohibit
transportation,” Park pointed out, “requiring
on-farm or local slaughter.” However, this
also requires that the producer have a
slaughterhouse or be very close to one, an
almost impossible standard for producers in most
of the U.S. to meet, especially in view of
environmental quality laws which limit where new
slaughterhouses may be built.
“I don’t see GAP as weaker, but it does
operate in a different way,” said Pacelle.
“5-Step is a program in development and is not
comprehensive at this time. Rather than wait
years to develop, test, and launch a full suite
of multi-tiered standards that cover every aspect
of production, GAP elected to roll-out standards
in phases to more quickly help improve the
welfare of animals. A two-year pilot program
with Whole Foods Market was recently completed
during which [the first] three sets of GAP
standards were tested and implemented. GAP is
currently revising the original three sets of
standards based on lessons from that pilot and
new science; instituting a robust
multi-stakeholder process, which includes public
comment; and developing new sets of standards
for egg-laying hens, turkeys, and sheep.”
The present GAP standards, unlike those
of AHC, HFAC, and AWA, do not specify
euthanasia methods for injured or ill animals,
and do not address slaughter. “Revisions of
current standards and development of new
standards will address specific euthanasia and
slaughter,” Pacelle promised.
A weakness of the GAP standards, Pacelle
acknowledged, is that “There is no specific
standard in GAP’s program that requires parasite
prevention. However, other requirements found
under sections for animal health, housing, feed,
and outdoor conditions incorporate parasite
prevention,” Pacelle said.
Unlike AHC, HFAC, and AWA, the GAP
standards prohibit any use of antibiotics. “GAP
does not allow the therapeutic administering of
antibiotics for animals who are ultimately
marketed as step-rated,” Pacelle said, “but for
each set of standards, it is a requirement that
any medication, including antibiotics, must be
administered if prescribed by a veterinarian.”
The GAP antibiotic rule means, in effect, that
any antibiotic-treated animal must be sold
outside the GAP system. This might be a
disincentive for producers to seek treatment for
infected animals.
Incorporated into the GAP standards at
all levels are a requirement that farm dogs “must
not be tethered.” Use of leghold or
body-gripping traps to prevent predation is
prohibited. Rodent infestation may not be
controlled with glue traps.
“Which standards HSUS prefers is a tough
question. The answer cannot be found just in the
relative strength of the standards,” assessed
Pacelle. “For me, a key issue is the potential
for impact on animal welfare in the entire retail
sector. With Whole Foods Market set to hit $10
billion in total sales next year, that company
itself provides an important marketplace for the
GAP program.
“But ultimately, success will be
determined if it can get picked up by other major
retailers,” Pacelle said. “I believe GAP
already has about 110 million animals under this
program, and that is an incredible start. I see
it ramping up in the coming months and years, as
the program gets more shelf space, standards for
more species are developed, and more
stakeholders invest in it.”

Humane Certified

The next largest animal welfare
certification program, HFAC, as of mid-2010
certified 54 producers, with 2009 output of 25
million animals. Certified Humane products are
sold as an option for consumers in about 4,000 of
the 230,000 supermarkets in the U.S., according
to Douglass, far more than the 300 Whole Foods
stores. American Humane Certified included 40
producers by mid-2010, with no identification of
numbers of animals covered or stores served.
“I am tired of being David in the David
and Goliath contest,” Douglass told ANIMAL
PEOPLE. “I am tired of rumors that the Whole
Foods GAP program is better than ours and that
their standards are better. I have worked very
hard over many years to have a program that makes
a difference.”
“I applaud Adele Douglass for her
tremendous leadership in this arena,” responded
Pacelle. “She was a pioneer in this effort, and
HSUS is proud to have played a key role in
helping HFAC off the ground. We are still
supportive of the program, as evidenced by HSUS
executive vice president Andrew Rowan’s continued
participation on the HFAC board. We see great
value in what she and the entire HFAC operation
are doing.”
Agribusiness beyond Whole Foods suppliers
has been slow to comment on the GAP standards.
But the GAP standards were quickly endorsed by
the Hekhsher Tzedek program, managed by the
United Synagogue of Conservative Judasim and the
Rabbinical Assembly. “The Hekhsher Tzedek will
indicate that a kosher product was made in
compliance with social justice criteria, in
keeping with the teachings of the Jewish faith,”
explained the administrators. “Companies will be
favored for the Hekhsher if they adhere to
[either] the GAP Step 5 standards or the HFAC

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