TraceabilityTraceability

• The ability to trace and follow a food, feed, or food producing animal or substance intended to be or expected to be incorporated into a food or feed, through all stages of production, processing, and distribution

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BackgroundBackground

• Host of Names and Related Issues– Quality Assurance– Identification systems– Identity preservation– Segregation– Process control– HACCP– Process verification– COOL

Forces for TraceabilityForces for Traceability

• Risk and Liability– Loss of customers– Loss of business

• Food Safety• Food Quality

– Intrinsic and extrinsic characteristics

• GMO Crops • BSE• Biosecurity

Are Consumers Willing to Are Consumers Willing to Pay for Traceability?Pay for Traceability?

• Traceability has Some Value Itself• More Value as Means of Verifying

Other Characteristics Like Food Safety• Can Add Value from Marketing

– Not necessarily just a cost

Animal IdentificationAnimal Identification

• Biosecurity and Disease Forced Issue• ID Itself is Not the Solution

– Doesn’t make food safe– Doesn’t prevent foreign disease

• Market Access– US beef exports to Japan

Animal IdentificationAnimal Identification

• Disease– Monitoring– Control and eradication– Emergency preparation

• Food Safety• Compatibility

– Defined standard– Compatible systems through sector

Role For GovernmentRole For Government

• Regulation• Set the Standards• Oversight and Inspection• Credibility• Process Verification

SummarySummary

• Rapidly Changing Area– Take some work to remain abreast of

changes

• Animal ID System Moving Forward– Industry and government action

• Moving Forward in All Areas

Country of Origin Labeling (COOL) and the Cattle

Industry

Source: Derrell S. Peel, Livestock Marketing Specialist, Oklahoma State University

Mandatory COOL

• Proposed Mandatory Rules – Issued October 27, 2003

• Comment Period– Ends December 29, 2003

What is Country of Origin Labeling

• Included in 2002 Farm Bill (PL 107-171)

• Amends Ag Marketing Act of 1946• Covers 500+ retail products

– Beef, Pork, Lamb (whole muscle and ground)– Fresh and Frozen Fruits and Vegetables– Seafood (wild and farm-raised)– Peanuts

• Administered by AMS

What Country of Origin Labeling Isn’t

• Is not animal health or food safety– FDA (food)– FSIS (meat)– APHIS (animals)

• Is not market grading– AMS

Components of COOL

• Retail product must be labeled• Food service excluded

– Including deli’s and salad bars in retail establishments

• Excludes processed foods• Becomes mandatory September 30,

2004

Who Must Label - Retailer

• Retailer has meaning given in Perishable Agricultural Commodities Act (PACA) – a business engaged in the selling of fresh and frozen fruits and vegetables at retail with an annual invoice value of more than $230,000−Approximately 4,500 licensees (37,000

stores)−PACA definition excludes butcher shops, fish

markets, and exporters

• Exempts food service establishments including those within retail establishments (e.g. delis and salad bars)

Consumer Notification Required at Retail

• Country of Origin• Label or notice must:

– Be legible– Be in English– Not obscure other required

information

Exclusions

• Covered commodities are excluded if an “ingredient in a processed food item”

• Regulation defines “processed food item”

• Does not exclude covered commodities just because they have been further prepared for consumption

Processed Food Item – Change of Character

• A combination of ingredients that include a covered commodity that has undergone a physical or chemical change, and has character that is different from that of the covered commodity

• Examples of covered commodities excluded because of change of character:– Oranges squeezed to make orange juice– Pork bellies cured and smoked to make bacon

Processed Food Item – Combination of Substantive

Food Components

• A covered commodity that has been combined with:– Other covered commodities– Other substantive food components, And has a character different than that of the

covered commodity• Examples of covered commodities excluded

because they are a combination of substantive food components:– Bagged salad (e.g. lettuce, carrots and cabbage)– Fruit trays/Vegetable trays (e.g. party trays)– Seafood medley (e.g. shrimp, scallops and clams)– Mixed nuts

Covered Commodities Required to be Labeled

• Examples:– Solution-enhanced and seasoned pork

loin– Cooked beef roast– Canned salmon– Bagged lettuce– Canned roasted and salted peanuts– Breaded shrimp

Covered Products – Muscle Cuts of Beef, Lamb and Pork

• “All muscle cuts of beef, lamb and pork whether chilled, frozen, raw, cooked, seasoned or breaded.”

Beef Products

• Whole muscle meats– Product of U.S.A.– Mixed Origin– Imported

• Ground beef– Each specific origin included in the

blend must be included on the label in alphabetical order

Labeling Requirements

• Product of U.S.A.– Born, Raised and Slaughtered in the U.S.

• Product of Country X– Labeled from entry until final sale– Label only covers importing country (not

other countries of birth or production)

Labeling Requirements cont.

• Mixed Origin (whole muscle)• Examples

– Imported from country X, raised and slaughtered in U.S.

• With records: Born (and raised) in country X, raised and processed in U.S.

– Imported from country Y, slaughtered in U.S.• With records: Born in country X, raised in country Y,

processed in U.S.

Labeling Requirements cont.

• Mixed Origin (ground or blended)• Example

– Ground beef – Product of Australia; Imported from Mexico, Raised and Slaughtered in U.S.A.; Product of U.S.A.

Recordkeeping

• Retailers must label covered commodities– Must keep Point of Sale records for 7 days– Must keep records of origin for 2 years

• Suppliers must provide information about country of origin– Producers, handlers, processors, packers,

importers

• Verifiable (auditable) records– Suppliers must maintain records– Affidavits may be used to certify origin and

existence of records

Recordkeeping - Suppliers

• “Any person engaged in the business of supplying a covered commodity to a retailer, whether directly or indirectly, is required to maintain records to establish and identify the immediate previous source and the immediate subsequent recipient of a covered commodity, in such a way that identifies the product unique to that transaction, for a period of 2 years from the date of the transaction.”

Recordkeeping - Suppliers

• Suppliers must provide origin information to buyers

• Records must identify previous source and subsequent recipient of product

• Must possess or have legal access to records that substantiate origin claims

• Must maintain records unique to each transaction for 2 years

Recordkeeping - Suppliers

• “For suppliers that handle similar covered commodities from more than one country, the supplier must be able to document that the origin of a product was separately tracked, while in their control, during any production or packaging processes to demonstrate that the identity of the product was maintained.”

Enforcement and Violations

• Retailers and suppliers are subject to enforcement provisions– $10,000 fine for willful violations

• USDA-AMS will conduct compliance reviews

• USDA-AMS will initiate investigations and enforcement actions

• Other statutes may apply as well

COOL is a Food Labeling Bill

• Food Labeling is covered by the Food and Drug Administration (FDA)

• Code of Federal Regulations– Title 21, Chapter I, Part 101.18 – Misbranding of Food

• “Among the representations in the labeling of a food which render such food misbranded is any representation that expresses or implies a geographical origin of the food except when such representation is a truthful representation of geographical origin”

Implications for Cattle Industry

• Probable minimum cow-calf records– Owner and location– Breeding herd inventory

• Purchased animals• Cull sales• Raised animals

– Number and Sex of Births by year– Animal sales

• Buyer• Date• Animal sex

• Breeding animals are covered by COOL

Implications for Cattle Industry

• Probable minimum stocker records• Put-together groups

– Seller and location of purchased animals• Date and sex of purchased animals

– Animal sales• Buyer• Date• Animal sex

• Must be able to trace animals from different source groups through management sorting and commingling into several sales groups

Implications for Cattle Industry

• Probable minimum feedlot records• Each pen

– Seller and location of purchased animals• Date and sex of purchased animals

– Animal sales• Buyer• Date• Animal sex

Implications for Cattle Industry

• Probable minimum packer records• Each shift or slaughter group

– Owner and location of purchased animals• Date and sex of purchased animals

– Meat sales by slaughter/fab group• Lot number, date and plant

Individual Animal ID

• Required? – No, in fact, forbidden as a USDA mandate

• Necessary? – Maybe not• Helpful? – Definitely

– Especially for stocker and feedlot sectors

Current Status of COOL

• House and Senate Appropriations actions have different language regarding implementation of COOL– These differences are yet to be

reconciled

• Various proposals to modify or repeal COOL

Challenge for the Industry

• Plan for compliance– Rules are uncertain and subject to

change

• Make beneficial use of new information– Use records to improve production

and marketing