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COOL procedures win consensus
With implementation of the long-awaited county-of-origin labeling nearing, livestock producers across the country came to a final agreement on the paper trail that will follow their animals.
Representatives from about 30 industry organizations met with USDA Under Secretary for Marketing and Regulatory Programs Bruce Knight on Sept. 5 to brief him on a standardized affidavit system the groups had agreed on a week earlier.
“Our goal was to create a simple, efficient, and effective means of declaring livestock origin from conception to consumer, and we believe this affidavit does exactly that,” said Andy Groseta, Arizona cattle producer and NCBA president.
Producers can fill in information specific to their cattle and assert the origin of any animal being sold, he said. Livestock marketers further along the ownership chain can use individual affidavits to create a single, combined affidavit for a group of animals.
“Representatives from every point in the supply chain unanimously agreed to use this standardized affidavit, which will greatly ease the burden that mandatory country-of-origin labeling places on producers,” Groseta said.
Originally passed in the 2002 Farm Bill, COOL was tweaked in the 2008 Farm Bill, and is scheduled to take effect Sept. 30.
“This meeting went very well,” said Bill Bullard, R-CALF-USA CEO. “The results are good news for members of R-CALF USA.”
“R-CALF has been working on this for many years, and we’re certainly looking forward to the September thirtieth implementation date, particularly now that we know the process of verifying the origin of live animals has been greatly simplified,” he said, adding that the entire beef supply chain worked together to accomplish the affidavit recommendation.
Burdell Johnson, president of the American Sheep Industry Association and a North Dakota producer said the goal of industry groups was to have universal language for the documents required to move livestock-origin claims along the ownership chain to ensure that the meat covered by COOL is accurately labeled at retail.
In an effort to achieve compliance in the most effective, least burdensome and least costly approach for producers, marketing businesses, feeders and packers, the coalition of organizations developed the language for a universal Country of Origin Affidavit/Declaration of Origin document, he said
The affidavit, deemed an official document by USDA, plainly identifies the origin of the livestock being moved. The groups also recommended that the document remain in effect for a period of time rather than requiring a new affidavit each time livestock ownership is transferred, he added.
U.S. Cattlemen’s Directors Danni Beer, of Keldron, S.D., and Chuck Kiker, of Beaumont, Texas, were also part of the industry effort to get that accomplished.
“This was a very important step towards the effective implementation of COOL in an efficient, speed-of-commerce and cost-effective manner for producers,” said Beer, who also serves as USCA’s COOL committee chairman. “The groups involved represent a broad-based, national consensus on key proof of origin issues, and I expect that USDA will listen closely to these recommendations.”
The three affidavit or declaration statements agreed upon include: a continuous country-of-origin affidavit which can be kept on file by the market, stocker, feeder or slaughter plant until revoked by the affidavit’s signer; a supporting declaration of origin for specific transactions involving livestock from producers, which will serve as a “stand alone” document related to a specific transaction; and the third statement covers direct transactions to packers from producers, marketing firms and feeders, Beer said.
Beyond the new affidavit process, USDA is permitting packers to rely on an official ear tag or marking on animals that are part of a National Animal Identification compliant system or the Canadian and Mexican official marking systems.
The group also agreed to encourage USDA to permit producers selling live animals to visually inspect their livestock for marking for foreign origin. It was agreed that the presence or absence of such markings constitutes first-hand knowledge of the animals’ origin, and would support an affidavit of origin.
“The initiatives arrived at during this meeting represent bold ideas that will benefit not only livestock producers, but consumers as well,” Kiker said.
The interim final COOL rule was published in the Federal Register on Aug. 1.
USDA issued the rule to allow for industry comment prior to issuing a final rule, while simultaneously meeting the Sept. 30 COOL implementation deadline. The interim final rule contains definitions, requirements for consumer notification and product marking, and the responsibilities of both retailers and suppliers for covered commodities.
The full rule is available online at http://federalregister.gov/page2.aspx.
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