What are you gobbling for dinner?

Be glad you don't have to kill and pluck it yourself

Christmas is coming, the goose is getting fat!

Please put a penny in the old man's hat.

If you haven't got a penny, then a ha'penny will do.

If you haven't got a ha'penny, then God bless you!

-        (Christmas Is Coming, the Goose Is Getting Fat - YouTube)

By this time, your Thanksgiving turkey is frozen leftovers or a memory.  But Christmas is coming and by the time that fat goose is in your grocer’s freezer, it is lots of pennies and ha’pennies more expensive than the turkey right next to it.  Probably five to ten times more expensive per pound!  Unless you can afford nostalgia for Christmases Past or have a goose hunter in the family, you are likely to be cooking another turkey for Christmas.  Even taking out the loss lead discount some grocers use to get you in the door to buy the marked-up trimmings, turkey is a bargain in any form except sliced at the deli counter.

There was a time when you had to kill it and pluck it yourself!

Figuring out which turkey to buy is still a challenge.  Now that you know the “independent family farmer” branding from large integrators is a marketing myth, you’ve dropped that discriminator off your list.  So what other discriminators should you consider?

As I like to support US farmers, I always look for US agriculture products.  All the turkey labels I have examined claimed they are a “Product of USA.”  That sounds good.  US laws apply for food safety, worker protection, and animal care? There’s been a battle raging over the past 30-some years between farmers and processors over “country of origin labeling,” which we call COOL.  This saga winds around the world as well as through the World Trade Organization and US courts and your grocery store.  Farmers have had wins and losses on this.  That means consumers have had wins and losses on this.  Meat packers and processors opposing COOL have argued for years that consumers don’t care about meat origin and that only price matters to you. Well, in November 2022, the USDA published a rigorous survey on consumer consideration of that label for beef and pork purchases.  Nearly half of you said that you looked for that “Product of USA” (PUSA) label all or most of the time.  You are willing to pay 24-43% more for meat carrying that label.  That same USDA survey also checked consumer understanding of that PUSA label.  Turns out that most of you assume it means that the animal was born and raised and slaughtered and processed in the USA, not merely packaged here.  Logical conclusion. Unfortunately, the USDA is currently allowing the use of “Product of USA” labels on any food product where the last processing step took place in the USA. The PUSA label does not guarantee that the critter was born and raised in the USA as well as completely processed here.  Oops.  

As more consumers have learned that “Product of USA” may mean that only the final processing occurred in the USA, they have joined farmers and ranchers in lawsuits.  Unfortunately, the meat processors have gotten these lawsuits dismissed as recently as 2022.  But in March of this year, the USDA proposed a new rule: FSIS-2022-0015.  This proposed new rule will restrict the PUSA label to meat, poultry, and eggs only when the product is derived from animals born, raised, slaughtered, and processed in the US.  Nearly 3,400 comments were posted during the comment period that ended in June of this year.   If you posted, thanks!  My sampling of comments suggests that nearly all support the proposed rule, with the vast majority coming from farmers and consumers.  A few comments from organizations (not individuals) claim that the rule will raise prices in the grocery store or reduce the prices that US farmers receive for their animals, with one of these noting “that the processors never give up a dime.”  They have a point.  Perhaps that commenter knows this because his organization represents processors.  But I have more faith in you consumers than that.

The final rule version is probably months away, given the amount of money at stake.  Until then, I believe the PUSA label is more meaningful when you are buying poultry than when you are buying beef or pork. The US is the world’s largest exporter of turkey products and the world’s second largest exporter of chicken.  In 2021, poultry ranked 67^th on the list of all US exports, not just food, making it a huge factor in our US trade balance.  There is some poultry being imported into the USA, but the export-to-import ratio is about 14 to 1.  The chances of that bird labeled PUSA having been hatched and raised and slaughtered in the US are very good.  In contrast, our country imports more beef than we export.  Until this rule defining PUSA is finalized, you might want to put PUSA turkey burgers on your grill instead of PUSA beef burgers.  As I mentioned last newsletter, I tend to take a dim view of regulating our way out of a mess – but truth in labeling is one that I have always supported without reservations!

While we are looking at USDA-approved labels like PUSA, what exactly does the USDA-inspection label mean?  You will find some variation of this on all meat and poultry sold retail in US grocery stores, and now my PUSA revelations have given you cause for suspicion.  The package in my refrigerator says “Inspected for wholesomeness by U.S. Department of Agriculture” in a white circle.  What is “wholesomeness” anyway?  The “Ask USDA” website says:  “Wholesome means ‘promoting the health of the body.’  There is no official United States Department of Agriculture (USDA) definition of the word for use in labeling a product.  However, all USDA-inspected products would be considered ‘wholesome.’”  I think that Mr. Carter, my 10^th-grade English teacher who did the most to pound grammar into my head, would call this a “circular definition.”  He would not mean that as a compliment, either.  Oxford’s definition – “conducive to or suggestive of good health and physical well-being” – is only a little better.

This “wholesome” label dates from the 1906 Federal Meat Inspection Act, which made adulterating or mislabeling meat sold a crime.  That law also required that animals be alive and healthy before slaughter.  It mandated sanitary conditions for slaughter and meat processing.  Federal inspection of the animals prior to slaughter and of the process became a requirement for interstate sale of meat under this act.  This law was passed in response to public concern about meat safety raised by Upton Sinclair’s 1905 novel about the Chicago meat-packing industry, The Jungle.  Sinclair wrote the book to draw attention to the miserable conditions for meatpacking plant workers, but the American public reacted to most to its depictions of unsanitary processes and food safety threats.  Because President Teddy Roosevelt suspected that Sinclair was a communist trying to undermine America, he sent his own advisers to investigate meatpacking plants.  That investigation confirmed the food safety allegations of the book and led to Congress passing the Meat Inspection Act. President Roosevelt signed the Act in 1906.  Thus, the USDA’s Food Safety and Inspection Service (FSIS) was born.  Now USDA inspectors are in all meat processing plants with raw meat sales across state lines.  Their work includes running random tests on carcasses and meat looking for bacteria, antibiotic residues, and banned substances.  The USDA also ensures that states have their own intra-state meat inspection program.  The USDA service replaces state inspection programs if the state does not have its own inspection system.  USDA inspectors also test a random sample of foreign meat imports.  Busy people!

Amazingly, poultry was not federally-inspected until the 1957 Poultry Products Inspection Act (PPIA), signed by President Eisenhower (a farmer, incidentally).  Yep, it took over fifty years after starting meat safety inspections to get the USDA involved in poultry slaughter and processing.  The PPIA is more informative on the meaning of wholesomeness:  “sound, healthful, clean, otherwise fit for human food.”  It reveals far more about wholesomeness by defining “unwholesomeness.” It calls out twelve ways that poultry can be unwholesome.  Don’t read these right before dinner.  Your hard-working USDA inspector has memorized these, so you don’t have to.  On second thought, you might want to read these so you know how government shutdowns might affect your safety.  The FSIS inspectors are expected to continue working during a shutdown, but they may be working without pay for the duration.  How long would you do their job without pay?

The main take-away from that USDA inspection label is safety.  It says nothing about quality beyond the guarantee that the product is unadulterated.  USDA meat quality certification comes via another system – voluntary -- called “grading” which is more important for meat than poultry.

Now that you know that any grocery-store turkey is likely to be grown in the US and safe to eat after you cook it to 165 degrees Fahrenheit, what other discriminators do you have?  Take a look at the sodium content, especially if you have a health reason to control your sodium intake.  All critters have some sodium in their muscle because sodium enables a muscle to contract.  Four ounces of un-brined roasted turkey contain about 80 milligrams of sodium.  Yet the integrators “pre-brine” the whole turkeys to “keep them fresh and moist.”  When the label says “flavor-enhanced” or the ingredients also include “turkey broth,” assume that’s a fancy version of pre-brining or soaking the turkey in salt water before packaging it for sale.  Salt is a very cheap preservative.  So is sugar, often added to the brine.  That same brine solution keeps the turkey from drying out if you over-cook it.  But that means somewhere between 4% and 40% of your turkey’s raw weight is salt water and possibly some sugar.  So, 4 to 40% of your purchase price may be going for something besides turkey.  A Butterball “Fresh All Natural” turkey claims to be on the low end of this range at 4%.  Their sodium content appears to be about 60% greater than what turkey left the farm with.  Sodium in Jennie-O turkeys appears to run from 2.5 times the natural baseline (for the “Sodium Smart” version) to 8 times for pre-cooked turkeys.

I have to limit my salt intake.  The year after my first cancer nightmare, I went on a quest to find a turkey for Thanksgiving that was not sloshing with saline solution.  Zero luck in the grocery stores.  I ended up getting a fresh turkey from a nearby Mennonite farmer for the family celebration.  Delicious and 100% guilt free. Not USDA inspected, either.  Cost?  About ten times the price of the same-sized Jennie-O or Butterball turkey in the nearest grocery store. This is not an everyday solution for those of us in the 99%, especially those a long ways from a turkey farm doing its own processing on site.  In fact, that was the only year I splurged like that.  If you have to limit your sodium intake, consider ground turkey.  It is not inundated with salt by the processors.  And, it’s cheaper and easier to cook.  You can put a low-sodium turkey meatloaf shaped like a roast turkey on your holiday table.  No bones, either.

If you like deli meats, be sure to read those labels carefully.  That beautiful, sliced turkey breast may be only sliced turkey and salt. Usually a lot of salt!  And it may contain more than turkey and salt.  Dairy proteins (whey and casein), for instance.  My dairy allergy has taught me that an amazing number of processed foods contain dairy.  Dairy proteins may be added to the turkey as an emulsifier, to keep fat and water from separating and to stabilize the fat.  Sometimes they are added to “improve” texture and “mouthfeel.”  I suppose they help hold the thin turkey slices together long enough for you to make your sandwich. The safest deli meats for someone with a dairy allergy are those certified as Kosher, because Kosher rules prohibit mixing meat and dairy.  You may also find additives such as cornstarch, potato starch, and carrageenan.  These are plant-based “plumping agents,” some with emulsifying tendencies.  Allergy considerations aside, these additions (often paired with innocuous-sounding “turkey broth”) translate into less turkey in your turkey.

Kroger and Shady Brook Ground Turkey, both Cargill Brands. Same store, same day, different price. Kroger was about 50 cents cheaper than the Shady Brook.

What else could be lurking in our turkey?  And possibly not in the ingredients list?  Some labels trumpet “Turkey raised without Hormones or Steroids.”  I don’t know anyone who wants to eat “Hormones or Steroids.”  I recently heard a UK citizen transplanted to the US complain that he couldn’t eat chicken or turkey anymore.  Why? He said: “Because US poultry is loaded with hormones and steroids.”  Some European food producers claim that US animals are loaded with growth hormones and steroids to convince EU residents to spend their food dollar close to home, so I suspected that was the source of his opinion.  Turns out, this attitude does not come from rivalries across the big pond.  Or not only from those rivalries.  The National Chicken Council (a poultry industry advocacy organization) surveyed American consumers in 2015 and discovered that 77% of US consumers believe that poultry contains “added hormones or steroids.”

Would you believe that the USDA banned ALL hormones and steroids in US poultry production in the 1950s?  It’s been about 70 years since then.  Europe waited until 1981 to ban these. Yet many US consumers still believe their poultry contains added hormones and steroids.

A poultry science professor -- recently retired from a major southeastern ag school -- told me that this misconception about hormones and steroids in poultry is not entirely the consumers’ fault.  His school once decided to produce public-service messages to inform the consumer of the laws prohibiting use of these drugs in US poultry.  The campaign was abruptly canceled on the “advice” of the major integrators funding the school’s poultry research program.  The “advice” could be summarized as “you run those ads and we will cut off your research funding.”  Why?  The integrators had marketing studies showing that US consumers would pay more for poultry labeled “raised without Hormones or Steroids” because they believed the product was healthier than poultry without that on the label.  If you knew that none of the US-produced poultry in their grocery stores had ever had these drugs, the integrators would not be able to fool you into paying a little extra.  That little game may be ending.  Note the asterisk after that statement on the labels now.  The asterisks lead a conscientious consumer to a confession that it’s illegal to give hormones and steroids to poultry in the US.  The USDA no longer allows anyone to put “Raised without Hormones or Steroids” on poultry labels without also including the statement about those drugs being illegal for poultry in the US.  The labels don’t have to show those facts together, however.  Or in the same-sized or same-color print.

But how can you be sure no one cheats?  The National Chicken Council has finally realized that maybe we’d eat more poultry if we had a more favorable view of the industry. They launched a website called “Chicken Check In” which tells you why growers don’t cheat.  They even have a video of a poultry scientist explaining why.  This earnest scientist and her viewers could both benefit from getting her an acting coach.  I’ll save you some time and cringe with a summary of her message.  Growers aren’t cheating because it’s much cheaper and easier to grow poultry without hormones and steroids than with them. Imagine you are a poultry farmer with tens of thousands of young birds. The digestive tracts of the birds break down these drugs into ineffective compounds before absorption, so adding them to feed and water is throwing money away.  You have to inject these drugs into each bird individually, every day.  Would you catch every single bird every day to give them a dose of hormones or steroids? If it took you a minute to catch and dose and mark one bird, and you did not need to eat or sleep, you would still get only 1,440 birds dosed in a single day.  That leaves you over 8,000 birds to dose in just that one poultry house.  You have five of these poultry houses.  Your income is already below the poverty line at the price you get for your birds. It’s a lot cheaper to rely on improved breeding programs and good feed.

A quick informal poll of my friends buying “organic” poultry revealed that most believe buying organic-labelled poultry was the only way to avoid hormones and steroids in poultry. The organic growers don’t mind you believing that non-organic growers are loading their birds up with drugs. They want you to think you are getting healthier food when you pay a premium price for that organic label.  I’ll dive deep into organic versus non-organic soon, to help you better understand exactly what you are paying extra for when you buy organic.  In the meantime, you can scratch hormone and steroid content off your list of reasons to buy any particular US turkey, organic or not.

What’s left?  In my deep-dive at Kroger, the only labeled differences I found between the Cargill Kroger-labeled ground turkey and the Cargill Shady Grove-labeled ground turkey are: (1) the prominently-displayed claim that Kroger ground turkey contains “NO Preservatives” and (2) the prominently-displayed claim that Shady Brook turkeys are raised without “growth-promoting antibiotics.” The Kroger-labeled turkey costs about 50 cents per pound less than the Shady Brook turkey.

Kroger’s “NO Preservatives” claim is rather clever.  The package lists just two ingredients: “ground turkey, natural flavoring.” Exactly the same as on the Shady Brook turkey.  Nothing there that sounds like a preservative, right?  Given my allergies, I asked the meat department manager to find out what “natural flavoring” was in the ground turkey with their store brand labels. That “natural flavoring” is a rosemary extract.  It’s in all the ground turkey brands.  The label on pre-formed turkey burgers at a high-end organic market (MOM’s) was a little more specific.  That label said the ingredients were “Organic Turkey, Organic Rosemary Extract.”  According to the USDA’s Food Safety and Inspection Service (FSIS):

“Spices (e.g., black pepper, basil, and ginger), spice extracts, essential oils, oleoresins, onion powder, garlic powder, celery powder, onion juice, and garlic juice are all ingredients that may be declared on labeling as "natural flavor," "flavor," or "flavoring." Spices, oleoresins, essential oils, and spice extracts are listed in the Food and Drug Administration regulations.” (https://www.fsis.usda.gov/wps/portal/fs ... try-labels)

Can you taste the rosemary in the turkey?  I can’t. The “rosemary extract” isn’t added for flavor.  In fact, the “extract” part is the clue. The rosemary oleoresin is added to ground turkey only to prevent oxidation and retain color.  It keeps the meat red (or pinkish, in the case of ground turkey breast).  Without it, oxidation starts immediately upon grinding and turns the ground meat gray-brown.  “Looks like a duck, quacks like a duck, is a duck,” my father used to say. Here I suppose we should say “Looks like a turkey, gobbles like a turkey, is a turkey.”  Rosemary oleoresin preserves the meat, so it’s a preservative.

Serendipity!  A plant that we routinely use for seasoning is also a preservative.  But wait, how is rosemary oleoresin extracted?  Rosemary leaves are treated with a food-grade version of a solvent such as ethanol or acetone.  The dissolved extract is filtered, the solvent is removed, and the residue is dried and ground into a fine powder.  The solvent is organic because it belongs to the class of organic chemicals, which has nothing to do with how the organic turkey is raised.  If the use of this solvent worries you, you might want to do a search on how caffeine is removed from that decaf coffee you are drinking.

The big picture: Both Kroger and Shady Brook ground turkey contain a preservative. So does the organic turkey burger from MOM.  It’s a preservative with a somewhat more natural lineage — rosemary is a plant — than, say BHT (butylated hydroxytoluene), BHA (butylated hydroxy anisole), the preservative that rosemary oleoresin replaces.

So, one less reason to pay a premium for your ground turkey. I suppose that Kroger’s “NO Preservatives” labeling may be trying to discriminate its store brand from other store brands rather than compete with Cargill-branded products.  I checked a bunch of other store brands for you such as Publix (supplied by Prestage, which bought out Swift Turkey some years ago) and Food Lion.  They all contain rosemary oleoresin and no other preservatives.

That leaves the possibility of less antibiotic residue in one brand or another. Perhaps the Shady Brook turkey has less antibiotic residue than the Kroger turkey, but I have not been able to trace the Kroger turkey that far.  “Growth-promoting antibiotics” means that antibiotics are mixed into feed or water provided to the birds, both to prevent disease and because birds treated like this grow up to slaughter weight faster or on less feed. Use of growth-promoting antibiotics in agriculture is complicated enough to merit its very own newsletter.  The fine print on Shady Brook’s label reads that antibiotics are “used responsibly to treat disease.”  That means they will give sick birds antibiotics.  As a former livestock farmer, I endorse use of antibiotics to treat disease and limit livestock suffering; however, we eliminated their use as a feed additive to promote growth on our farm long ago.

If you are really concerned about antibiotic residue in your turkey, consider Cargill’s Honest Turkey “No Antibiotics Ever” labeled product, which they claim is completely antibiotic-free.  This does not mean that a grower is going to let a disease sweep through her flock without any action.  She can’t afford to lose an entire flock. Nor can she afford the long-term hit to her reputation sure to result from sending sick turkeys to slaughter. Here’s my take – based on how this is done on sheep and cattle farms – on what “completely antibiotic free” means.  Every time a critter gets sick with a disease that can be treated with antibiotics, you separate that critter from others and treat the sick critters with whatever antibiotic is necessary to save them.  Then, you keep those critters separated.  You now have two separate slaughter streams. The ones that have recovered with the antibiotic are heading for the “antibiotics are used responsibly to treat disease” branding. The rest are heading for “no antibiotics ever” branding.

Note that the critters who were treated with antibiotics will not be slaughtered for a USDA-mandated withdrawal period to ensure you won’t be eating any antibiotic residue. The USDA inspectors check for antibiotic residues.  It may further comfort you to know that antibiotic residues are in organ meats, not muscle.  However, keep in mind that the Honest Turkey supply chain is not participating in the USDA’s “Process Verified Program,” so Cargill is not going to send you a third-party audit proving that the bird on your table has never had any antibiotics ever.  If you are concerned that your turkey may be contaminated with antibiotic-resistant bacteria in processing, the “no antibiotics ever” brand probably won’t address that concern.  According to ProPublica, Honest Turkey and Honeysuckle White are being processed in the same plant. It’s possible that your organic, free range, no-antibiotics-ever bird was processed there, too.  Bacterial contamination during processing deserves its own deep dive – stay tuned. In the meantime, cook your poultry carefully and completely, no matter what brand it is.

For now, I give you permission to buy the cheapest turkey in your favorite grocery store without a load of guilt.  If you don’t need to worry about sodium level or allergies, you may want to help the environment by buying the product with the least amount of packaging. Or buy the brand with the plastic tray that can be reused to start your tomato plants in the spring or hold your beading project.

If Mom is visiting, you might want to buy the brand your mother prefers.  Just don’t tell her that her favorite brand has been bought up by some major processer since she was a newlywed, perhaps canceling the once-valid reasons for her preference.  At least, wait until after Christmas dinner for that conversation. There is nothing in any grocery store turkey today worth having a family fight over.  Just try not to waste your grocery money on stories that don’t add value to your food.  Buy food, not stories. If you are not on the edge financially, consider giving the money you save directly to farm preservation, animal welfare, and food safety organizations. Or to your local foodbank.

Enjoy that turkey dinner. And share this post with friends. Subscription is free.

Fun rendition of an old round that has nothing to do with turkeys: Christmas Is Coming, the Goose Is Getting Fat - YouTube                                                                            

“Product of USA” Regulatory Docket:  Regulations.gov

USDA Proposes New Requirements for the “Product of USA” Label Claim | USDA

Survey on Product of USA labels: Analyzing Consumers’ Value of “Product of USA” Labeling Claims (usda.gov)

Poultry Industry Exports around the World: Poultry Meat in United States | The Observatory of Economic Complexity (oec.world)

Who is eating the poultry exported from the US: USDA ERS - Poultry Expected To Continue Leading Global Meat Imports as Demand Rises

Beef Imports/Exports for comparison to poultry: National Beef Wire | U.S. Beef Imports vs. Exports By Year | The

Ask USDA: What is meant by "wholesome" in regards to foods? (usda.gov)

Information on poultry for consumers, from the chicken industry: www.chickencheck.in

Information on hormones and steroids in poultry for consumers, from Mississippi State University: chickens do not receive growth hormones: so why all the confusion? (msstate.edu)

Poultry Products Inspection Act original text: STATUTE-71-Pg441.pdf (govinfo.gov)

The searchable on-line version of the PPIA: Poultry Products Inspection Act | Food Safety and Inspection Service (usda.gov)

List of Federal Regulatory Actions associated with food safety: Federal Register Rules | Food Safety and Inspection Service (usda.gov)

USDA Food Safety and Inspection Service (FSIS) website: https://www.fsis.usda.gov/wps/portal/fs ... try-labels

Report on crowd-source activity finding where your poultry may be processed: Your Free-Range Organic Chicken May Have Been Processed at a Large Industrial Poultry Plant — ProPublica