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What Will Be Required Of Cow Calf Producers Under COOL

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Anonymous

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5/14/2008 8:04:00 AM


What Will Be Required Of Cow Calf Producers Under The COOL Rules This September?



The title of this article asks a question that is not yet totally answered. However, the answer is beginning to be clearer and soon may be finalized. As you likely know, in 2002, the US Congress passed a law requiring certain “covered commodities” to be verified and labeled as to their county of origin. The acronym used commonly for this law is COOL, denoting County of Orgin Labeling. Final rules for COOL will be written following final passage of the 2007 Farm Bill which has passed the Senate and House Conference Committee and will likely be sent to the President’s desk soon. If the President signs the Farm Bill, final rules will then be written. As of now, the following definitions and requirements are likely to become rules. Let’s examine some of these as they apply to cow-calf producers in Colorado:

Beef as a Covered Commodity: Meat cuts and ground product from beef are defined as a “covered commodity”. More specifically, under the current rules, “a meat product from beef (including veal), pork, and lamb must bear a COOL label or is subject to labeling providing COOL information if: 1. It is sold at retail, AND, 2. It is a muscle cut, or 3. It is a ground product. The product is EXEMPT from COOL labeling requirements if: 1. The meat product is sold at foodservice (e.g., restaurants, institutions, etc.), OR, 2. The meat product is an ingredient in a processed product or, in effect, is processed.” (Source: http://www.countryoforiginlabel.org, link to DOES A MEAT PRODUCT NEED A LABEL?, accessed 13 May 2008).

Jack’s Comment: From this we can assume that home-raised and harvested beef that is not sold at retail will not be required to be COOL labeled. Beef served on a menu at a restaurant will be exempt, as will beef served in a cafeteria or other food service institutions.

Recordkeeping Requirements: The current language states: “Any person engaged in the business of supplying a covered commodity to a retailer, directly or indirectly, must maintain records to establish and identify the immediate previous source (if applicable) and immediate subsequent recipient of the product. The record must identify the product unique to that transaction by means of a lot number or other unique identifier, for a period of one (1) year from the date of the transaction.

“Establishments that slaughter livestock are considered initiating suppliers of a covered commodity. The Agricultural Marketing Service (AMS) has indicated that the initiating supplier (packer) either must have the records in its possession or have access to records of the livestock supplier that substantiate the country of origin of the meat product at issue.” (Source: http://www.countryoforiginlabel.org, link to Recordkeeping Requirements, accessed 13 May 2008.).

Jack’s Comment: Since cow-calf producers indirectly supply beef to packers, I interpret this to mean that cow-calf producers will be responsible to have records to substantiate the country of origin of their calves, cull cows and bulls. While these records may not be required at time of sale, it is likely that there will be an increasing demand for such record verification at the time of sale.

Seed Stock / Cow Calf Responsibility: “Provide enough information for an auditor to verify the origin and ownership of the animals identified and to verify the stated designation. Properly identify and record all animals according to the designation.” (Source: http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELDEV3103374, accessed 13 May 2008.).

Jack’s Comment: I interpret this to mean that a rancher must have sufficient documentation so that in the event of an audit from USDA, they can verify the country of origin of the cattle they sold into the marketplace.

Examples of records and activities that may be useful. The following record examples are listed in the 2002 version of COOL. “Birth records, receiving records, purchase records, cow/calf tag ID system, sales receipts, feed bills, feeding records, animal inventory, acreage inventory, site maps, APHIS VS forms, production estimates, health records, ownership records, segregation plan, state brand requirements, replacement activities, beef quality program (BQA), breeding stock information.” (Source: http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELDEV3103374, accessed 13 May 2008.).

Jack’s Comment: In reality, it will likely be a combination of information that will be used to substantiate the origin of cattle. Records such as brand inspections, bangs vaccination records, sales receipts, etc. will be used to verify that the cattle did in fact originate at the ranch, or were purchased from a qualifying location.

“In the Normal Conduct of Business” clause: The National Cattlemen’s Beef Association (NCBA) website explains recent revisions language in the current Farm Bill legislation as follows: “Language in both the Senate and House bills helps alleviate the paperwork burden on producers requiring only documents used “in the normal conduct of business” to verify origin.… While the current law is far from perfect, the compromise language in the Farm Bill is an improvement for cattle producers. Mandatory country-of-origin labeling is scheduled to take effect on September 30, 2008.” (Source: http://www.beefusa.org/goveFarmBill.aspx, accessed 13 May 2008.).

Jack’s Comment: In my opinion the implementation of COOL should not be viewed in a panic mode for cow-calf producers. Most, if not all, of the documentation needed to meet the COOL requirements is likely already part of your normal cow-calf production system. However, I suggest that we all do a better job as record-keepers and make certain that the history of our cattle can be substantiated. I also foresee that such records will enhance the value of cattle when they leave the farm of origin. One of the great principles of our market-driven system is the reward for value and the discount for absence of value. As we look back in 10 years, my prediction is that COOL will add value at the ranch level for those who document and market country of origin information.



Source: Jack C. Whittier, Colorado State University
 

PORKER

Well-known member
Full-Chain-Traceability and Archiving System
for Country of Orgin, BMP, GAP, Bio-Terrorism

--------------------------------------------------------------------------------
Effective Start Date for the C.O.O.L. Law: September 30, 2008
133 days left as of May 20, 2008
C.O.O.L Law recordkeeping requirements
www.ams.usda.gov/cool/records.htm

--------------------------------------------------------------------------------
The only complete Global Database
for worldwide traceback and traceup recordkeeping and documentation
of agricultural products with Point-to-Point Traceback™
for each individual Commodity/Entity
in just seconds

WHO NEEDS TO LABEL ? Ranchers and farmers so that the Retailers have correct information to label in the store as required by the COOL Law.


The 2002 Farm Bill requires many, but not all, retailers to ensure that certain beef, lamb, and pork and goat products (covered commodities) bear country of origin labeling and the law directs the Secretary of Agriculture to issue regulations to implement these labeling requirements. Packers and processors that supply covered commodites to their retail customers must provide COOL information to the retailers with source information. That information can be provided to retailers in a number of ways, including providing the labels themselves.
 

PORKER

Well-known member
Modified - but still "onerous"
The Farm Bill's COOL provisions will still be costly, but maybe the paperwork won't be so bad


(MEATPOULTRY.com, May 30, 2008)
by Steve Bjerklie

It’s not COOL anymore. It’s modified COOL.

The 2007 Farm Bill passed earlier in May by the U.S. Congress, with an expected congressional override of Pres. Bush’s veto of the bill to come next month, includes provisions requiring mandatory country-of-origin labeling (COOL) on retail meat products sold in the U.S. A similar provision was part of the 2002 Farm Bill but never implemented. This time, however, Congress apparently means business, according to Mark Dopp, the American Meat Institute’s senior vice president for regulatory affairs and general counsel. "Even if the Farm Bill didn’t go forward, the COOL amendments would still probably be enacted," he told MEAT&POULTRY.

That much seemed apparent when certain paperwork and bookkeeping requirements for COOL were modified in the final bill. "As I understand it -- and we won’t know for sure until we see the final language — the COOL provision has been modified to make it a little less onerous," commented Laurie Bryant, executive director of the Meat Importers Council of America. "But how much less onerous, we can’t say yet."

He adds: "It’s going to be costly no matter what, mostly to the domestic industry. It won’t cost importers much because the product we bring in is already labeled, and it isn’t typically sold at retail directly. It is repackaged by a processor." The labels for ground meat, which often contains meat from several sources, could become veritable world atlases -- "this product may contain meat from Canada, Australia, New Zealand, Uruguay," for example.

"The modifications offer a bit more flexibility in terms of whether a particular country’s product has to be noted on a label," Bryant said. "But there will still be a labeling requirement."

COOL is scheduled to take effect Sept. 30, 2008.
 

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