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Leo McDonnell Jr. August 9, 2002 U.S. Department of Agriculture Re:
Comments of
R-CALF United Stockgrowers of America (R-CALF USA) on the Issuance of Guidelines
for Voluntary Country of Origin Labeling Dear Sir or Madam: The Ranchers-Cattlemen Action Legal Fund - United Stockgrowers of America (R-CALF USA) is pleased to offer comments on the issuance of guidelines for the voluntary implementation of the mandatory country of origin labeling law (Act). R-CALF USA appreciates USDA’s solicitation of public input in its efforts to maintain continuity between implementation of both voluntary and mandatory labeling. R-CALF USA is a non-profit association of U.S. cattle producers. R-CALF USA members are located in 42 states, and it has 30 local and state cattle association affiliates. Various main street businesses are associate members of R-CALF USA. R-CALF USA focuses upon market and trade matters of interest to cow-calf operators, backgrounders, and independent feedlot operators. The USDA has had a voluntary geographic labeling program since at least the early 70s, though the program was not widely used. The reason for this appears to be that unless all segments of the beef industry jointly participate to effect a geographic label, any one of the distinct industry segments can disqualify a product’s eligibility by simply declining to participate in the program. In other words, labeling under the program would only occur if the live cattle producer voluntarily substantiated that the animal’s origin was a specific geographic region; the processor voluntarily agreed to segregate the product to maintain the integrity of the geographic substantiation throughout the processing phase; and the retailer voluntarily agreed to affix the appropriate geographic label on the product. The new voluntary labeling program will require this degree of inter-industry cooperation in order to be successful. To accomplish this heightened level of cooperation, USDA must provide an incentive to encourage each of the three industry segments to participate in the voluntary program. Lacking a more creative solution to impart such needed incentives within the present industry structure, and given the fact that country of origin labeling is scheduled to become mandatory in two years, R-CALF USA recommends that USDA adopt interim rules with which to implement mandatory labeling from the outset. However, pending the September 30, 2004, implementation date for mandatory labeling, the retailer’s decision regarding whether to retain the country of origin label upon final sale of the product would be left voluntary. In support of this recommendation, it should be noted that the mandate for labeling is a mandate on the retailer of the covered commodity, but the retailer is necessarily dependent upon the product’s origin identification and segregation by the two principle upstream suppliers – packers and producers.
R-CALF USA, therefore, offers the following comments with an eye toward
the establishment of comprehensive country of origin labeling rules to allow any
retailer, inclusive of exporters and food service establishments, the
opportunity to label beef and ground beef at their discretion, beginning
September 30, 2002. R-CALF USA’s
specific comments include only beef and cattle but could be applied to lamb and
lambs and pork and hogs. It views
the process of establishing guidelines to accommodate beef and cattle as
necessitating the following four distinct categories. Part
I:
Determining Eligibility of Beef Derived From Live Cattle Slaughtered in
the United States for the United States Label Part
II:
Segregating Domestic and Imported Beef During the Processing/Slaughtering
Phase To Retain the Proper Country of Origin Label Part
III:
Communicating Information Regarding the Origin of Beef from Packer to
Retailer, Maintaining an Auditable Trail of that Communication, and Achieving
Compliance Through Enforcement and Fines Part
IV:
Labeling Beef with Multiple Countries of Origin, Including Live Cattle
Transshipped from a Third Country R-CALF USA previously submitted comments on Part I to USDA on May 31, 2002. R-CALF USA will summarize its May 31, 2002, submission here and will thereafter address Part II through Part IV. PART
I:
Summary of R-CALF USA’s May 31, 2002, Submission on Determining the
Eligibility of Beef Derived From Live Cattle Slaughtered in the United States
for the United States Label The preponderance of live cattle
slaughtered in the United States are born, raised, and slaughtered in the United
States and, therefore, eligible for the United States label. It is only through the physical act of importing a live
animal from a foreign country that causes a disqualification for the United
States label. This single
disqualifying factor for eligibility for the United States label is already
tracked by USDA-APHIS for other purposes, principally safety, through health
certificates. These health
certificates can be combined with the issuance of a certificate of importation
to provide clear evidence that an animal has been imported.
Moreover, these health certificates and the proposed Certificate of
Importation would identify the importing country. In addition, the practice of physically identifying imported
live animals is currently accomplished with permanent ear tags affixed to
Mexican live cattle imports, cattle tested for Brucellosis, as well as U.S.
cattle exported to Canada, and this practice could readily be expanded to
include imports from all countries.
To accomplish the objective of determining eligibility of live cattle
slaughtered in the United States for the United States label, R-CALF USA
recommends:
USDA should
conduct annual audits of both permit holders and packers to ensure proper
disclosure of all live cattle ineligible for the United States label upon
delivery to the packer. [Note
change in audit frequency. Original
submission suggested periodic audits.] R-CALF USA
believes this proposal represents a reasonable, efficient and low-cost means of
determining the eligibility for a United States label, or a label denoting the
country from which the cattle were imported.
In the event that USDA finds it necessary to verify the origins of
domestic cattle, R-CALF USA recommends that a system of affidavits be used
similar to that presently used by producers to certify that they have not fed
ruminant byproducts to their cattle. A complete copy of R-CALF USA’s May 31, 2002, submission of Part I is attached. PART
II: Segregating Domestic and Imported
Beef During the Processing/Slaughtering Phase To Retain the Proper Country of
Origin Label
According to the official listing of USDA domestic product suppliers
dated July 19, 2002, there are 49 U.S. beef packing plants eligible to provide
meat products to the Federal Purchase Program.
USDA approves these plants as either Domestic Only facilities or
facilities with approved Segregation Plans.
In addition to many smaller packers, included on the list are plants
owned by the nation’s four largest packers:
ConAgra, Excel, IBP, and National Beef.
This model can be applied to all other U.S. packing and processing
facilities following certain modifications needed to accommodate the Act.
Packers, processors, wholesalers and retailers have demonstrated their
ability to segregate separately labeled products as exemplified by the numerous
branded beef products in the market place today.
The segregation of products to enable the proper labeling of muscle cuts
of beef and ground beef can be readily accomplished using the industry’s
present models and technology. A.
USDA should mandate that meat processors that process both domestic and
imported live cattle and beef implement an approved segregation plan.
USDA
should modify the current model employed by the audit and approval program
presently used in the Domestic Origin Verification Program of the Audit, Review,
and Compliance Branch for establishing processor eligibility to supply meat and
meat products to the Federal Purchase Program as contractors and/or
subcontractors. The program would
require slight revisions to comport with the new country of origin labeling law.
The revisions would include:
i. A plan to segregate and to retain the identity of meat derived from cattle exclusively born, raised, and slaughtered in the United States, and
ii.
a plan to segregate animals transported from an importing country
directly to a United States slaughter plant and to retain the identity of
the importing country on the resulting beef (to accommodate fed cattle arriving
in sealed trucks without ear tags), and
iii.
a plan to segregate and to retain the identity of beef derived from
cattle ineligible for the United States label by virtue of spending a portion of
their life cycle in a foreign country.
iv.
a plan to segregate and to retain the origin designation of imported beef
or beef products intended either for further processing or for purposes of
commingling with either domestic beef or beef products or beef or beef products
from yet another importing country.
B. USDA should
mandate that meat processors which exclusively process animals exclusively from
livestock born, raised, and slaughtered in the United States to register with
the proposed Country of Origin Verification Program and to immediately report if
its domestic only status is changed.
Packing and processing facilities that do not currently handle imported cattle, beef, or beef products should register with the Country of Origin Verification Program as a Domestic Only facility. If the Domestic Only facility plans to begin handling imported cattle or beef products, it must first obtain approval of a Segregation Plan as discussed in A above prior to handling any imported cattle or beef. PART
III: Communicating
Information Regarding the Origin of Beef from Packer to Retailer, Maintaining an
Auditable Trail of that Communication, and Achieving Compliance Through
Enforcement and Fines A.
Communicating Information Regarding Origin of Beef from Packer to
Retailer The
procedures for monitoring compliance and enforcement should not and need not be
onerous. The determination and
conveyance of origin designation from the live cattle producer, backgrounder,
feeder, and importer to the packer, along with establishing an auditable trail
for ensuring compliance was discussed in Part I. The determination and conveyance of origin designation for
imported beef carcasses, beef, and beef products from an importing country to a
U.S. packer, processor, wholesaler, or retailer in their original shipping
container is achieved under the current trade law administered by the USDA Food
Safety Inspection Service (FSIS). It
is only the actions subsequent to the removal of the products from their
original shipping container that the USDA must address in connection with the
Act.
The
discussion in Part II above describes an approved Segregation Plan that packers
and processors must adopt and USDA must approve if they are recipients of
imported beef or beef products. The
requisite approval by USDA of the Segregation Plans contemplated in Part II
includes approval of the procedure to be used to retain the origin designation
throughout the slaughter and processing stage, not unlike the current practice
presently used for the current Federal Purchase Program.
Retailers must rely upon the accurate conveyance of a product’s origin
designation from either the imported product’s original shipping container, a
wholesaler (who may receive the product in its original shipping container or
from a packer or processor), a processor (who may receive the imported product
in its original container or from a packer), or a packer (who may also receive
an imported product in its original container, from a live cattle producer, or
from their own live cattle inventories).
In all cases, the retailer’s ability to accurately label a product is
dependent upon the accuracy of information communicated by upstream suppliers.
Therefore, USDA’s plan for monitoring compliance and for enforcement
beyond the reporting requirements for phase of live cattle suppliers (Part I)
and the implementation of a Segregation Plan (Part II) should focus on the
accurate conveyance between the retailer and the packer/processor supplying the
product. B.
Maintaining an Auditable Trail of the Communication Regarding Country of
Origin
In addition to the reporting of imported cattle discussed in Part I, and
the Segregation Plan Audits discussed in Part II, USDA should require reporting
from all persons who supply imported beef carcasses, beef and beef products
(beef importers) to U.S. processors, wholesalers, and retailers.
Such reporting should include the volume and nature of imports along with
the name of the purchaser. This
reporting will enable USDA to ensure that imports arriving in the form of beef
carcasses, beef, and beef products are funneled into the same food distribution
system as are products derived from imported live cattle, all of which would be
subject to USDA’s oversight. In
the case of retailers and wholesalers, conventional documentation accompanying
purchases that identifies product sources would suffice for maintaining an
auditable trail. C.
Achieving Compliance through Enforcement and Fines
Monitoring compliance at the
retail level could be accomplished with a cooperative agreement between USDA and
each state’s food safety inspection programs.
In establishing such a program, USDA should review the program instituted
by the state of Florida to implement its state’s preexisting labeling law.
It is R-CALF USA’s understanding that the Florida model for monitoring
compliance is relatively streamlined and involves periodic spot checks of retail
stores conducted by state employed inspectors.
Monitoring compliance at the packer/processor level could be accomplished
with a cooperative agreement with state programs that inspect state inspected
plants, and by USDA inspectors that already inspect USDA inspected plants.
Again, a periodic spot check of the accuracy of the labels could be
conducted on products leaving the plant.
If USDA receives a complaint regarding inaccurate labeling or if periodic
spot checks reveal discrepancies, USDA should conduct an investigation to
identify the party or parties responsible for the non-compliance. Truth in labeling should not be taken lightly. The U.S. cattle industry has spent nearly $1 billion under a government-mandated program for research, promotion, and education, in part to strengthen consumer confidence in beef. The U.S. cattle industry was also a global leader in pursuing regulations to ban the feeding of ruminant byproducts to prevent outbreaks of BSE. Country of origin labeling is the best tool U.S. producers have to maintain consumer confidence in beef derived from the U.S. cattle herd if a disease such as BSE is ever detected in imported beef products. Therefore, R-CALF USA recommends a stringent and progressive penalty schedule for individuals who violate the Act.
During the initial and voluntary phase of the Act’s implementation,
fines should be sufficient to act as a meaningful deterrent to inaccurate
labeling, but also realistic in recognition of unforeseen difficulties that may
arise during start-up. Therefore,
R-CALF USA recommends that fines be progressive with the first finding of a
party willfully affixing an inaccurate label during the first year of voluntary
labeling leading to a written warning. Fines
sufficient to discourage violations should apply to subsequent violations and
repeated offenders should face a suspension from handling imported cattle, beef,
and beef products. PART IV:
Labeling Beef with Multiple Countries of Origin, Including Live Cattle
Transshipped from a Third Country The Act establishes a standard for determining a
United States origin from birth to slaughter, but does not include further
processing of beef as a criterion for determining such origin.
Therefore, if imported beef carcasses, beef, or beef products are further
processed, i.e., removed from their container or packages and cut up, and/or
repackaged by a United States processor, the final product shall retain the
original country of origin label of the country from which the derivative beef
carcasses, beef, or beef products was imported and the “United States” shall
not be included on the label. With respect to criterion that is included in the
Act, there are two options USDA may want to consider regarding the contents of a
label associated with muscle cuts of beef or ground beef at the retailer,
including exporter, level. R-CALF
USA believes Congress made it very clear about what muscle cuts of beef may have
a United States label and that ground beef must be labeled with its country of
origin. Given Congress’s mandate,
R-CALF USA recommends that USDA implement the first option, Option A, below as
an interim rule. Option A meets
Congress’s mandate and does not require any additional level of international
harmonization than what currently exists in order to be nondiscriminatory. Option A The United States label shall be reserved
exclusively for beef derived exclusively from cattle born, raised, and
slaughtered in the United States. Muscle
cuts of beef and ground beef either imported or derived from imported cattle
shall bear the label of the country from which the beef or cattle were imported,
regardless of the length of time the cattle spent in the importing country or in
the United States during any phase of its production cycle.
The single exception would be the provision within the Act concerning the
transport of cattle from Alaska and Hawaii.
A ground beef label, however, would include each country from which any
of the commingled beef or beef product originated, i.e., either listing each
country included in the specific ground beef product or each country from which
the grinder sources its beef for grinding.
The “United States,” however, should only be listed on the ground
beef label if beef derived exclusively from cattle born, raised, and slaughtered
in the United States was commingled in the final ground beef product. Under current international harmonization of
country of origin labeling, Option A is an appropriate means of implementing the
labeling requirements of the Act. Lacking
further international harmonization, any variation of Option A would be
discriminatory toward any imported beef or beef product derived from animals not
slaughtered in the United States. Such
imported beef or beef products would be relegated by current international
standards to bear only the label of the country in which it was either
slaughtered or transformed. Therefore,
should the United States attempt to afford muscle cuts of beef or ground beef
derived from cattle slaughtered in the United States with a multi-country label
based on where the cattle spent its distinct production phases, e.g., born in
the United States, raised in Canada, and slaughtered in the United States, such
beef from imported cattle slaughtered in the United States would receive
preferential treatment by having a more descriptive label. In addition, any deviation from Option A, i.e., a
multiple label for animals born in one country and perhaps fed and slaughtered
in another, would require the United States to track the various production
phases of cattle while they reside in a foreign country or countries in order to
afford the resulting muscle cut of beef or ground beef with a more descriptive
label depicting where the animal spent its various production phases.
Because the United States does not have the authority to require such
tracking of imported animals in foreign jurisdictions, another mechanism must be
instituted if a multiple label denoting where cattle that produced the imported
beef was born, raised, and slaughtered. Option B If the United States and its foreign trading
partners were to harmonize international standards for labeling to allow the
delineation of where cattle were born, raised, and slaughtered, Option B, would
be available for USDA’s consideration. Under this option, USDA would further define the
individual terms: born, raised, and
slaughtered. Once these individual
terms are defined, beef could be eligible for a multi-country label reflecting
the respective countries in which the animal underwent its various production
stages. For example, beef derived
from an animal born in the United States, fed in Canada, and slaughtered in the
United States could be labeled “Born in the United States, Fed in Canada, and
Slaughtered in the United States.” Similarly,
beef carcasses, beef, and beef products imported into the United States would
bear labels denoting the country or countries in which the derivative spent its
various production stages. Thus, all cattle, beef, and beef products would be treated
equitably with respect to labeling regardless of the country in which the cattle
were slaughtered or processed, and the consuming public would be afforded more
descriptive information regarding the specific origin of the beef they purchase. This
option would also help to identify the true origin of cattle that had been
transshipped into an importing country from a third country prior to arriving in
the United States, provided the definition of the term “raised” contemplated
such transshipments. CONCLUSION R-CALF
USA appreciates the opportunity to submit these comments and looks forward to
working with USDA as it proceeds to first establish and implement voluntary
guidelines and then to promulgate final rules for the implementation of
mandatory country of origin labeling. Sincerely, Leo McDonnell May 31, 2002 Bill Sessions Re:
Preliminary
Comments of R-CALF USA on the Issuance of Guidelines for Voluntary Country of
Origin Labeling Beginning September 30, 2002. Part I:
In the Matter of Determining Eligibility of Live Cattle Slaughtered in
the United States for the United States Label Dear Mr. Sessions: R-CALF USA is pleased to offer its current insights on the issue of formulating guidelines for the voluntary implementation of country of origin labeling. Please recognize that the following comments are preliminary in nature and intended only as a starting point. R-CALF USA will circulate this proposal among its various affiliated organizations to solicit additional input and will report any modifications that may be made to this proposal. R-CALF USA looks forward to the opportunity to continue working with you to develop effective guidelines. The Ranchers-Cattlemen Action Legal Fund - United Stockgrowers of America (R-CALF USA) is a non-profit association of U.S. cattle producers. R-CALF USA members are located in 41 states, and R-CALF USA has some 28 local and state cattle association affiliates. Various main street businesses are associate members of R-CALF USA. R-CALF USA focuses upon matters of interest to cow-calf operators, backgrounders, and independent feedlot operators.
R-CALF USA has refined its comments to include only beef and cattle.
It views the process of establishing guidelines to accommodate beef and
cattle as necessitating four distinct categories.
The four categories are: Part I:
Determining Eligibility of Live Cattle Slaughtered in the United States
for the United States Label Part II:
Segregating Domestic and Imported Beef During the Processing/Slaughtering
Phase To Retain the Proper Country of Origin Label Part III: Communicating Information Regarding the Origin of Beef from Packer to Retailer, Maintaining an Auditable Trail of that Communication, and Achieving Compliance Through Enforcement and Fines Part IV:
Labeling Beef with Multiple Countries of Origin, Including Live Cattle
Transshipped from a Third Country In the essence of time, R-CALF USA
will provide separate comments for each of the four aforementioned parts.
The instant comments concern Part I. Part I: In the Matter of Determining Eligibility of Live Cattle Slaughtered in the United States for the United States Label A.
Criteria
for Determining Eligibility for the United States Label
The 2002 Farm Bill, under Subtitle
D – Country of Origin Labeling (Act) requires retailers of covered commodities
to inform consumers, at the final point of sale of the covered commodity to
consumers, of the country of origin of the covered commodity.
The Act only requires that the country of origin of a covered commodity
be identified, and the standard for determining eligibility for the United
States label for beef is if the beef was exclusively derived from cattle
exclusively born, raised, and slaughtered in the United States.
No greater detail is required by the Act.
The Act does not require the identification of an animal’s state or
province, county or township, or individual breeder or feeder. The single determinate of
eligibility for the United States label is whether or not an animal has spent
any time during its life cycle outside the geographic borders defining the
United States. Therefore, the only
circumstance that would disqualify beef derived from an animal slaughtered in
the United States from the United States label would be if the animal were, at
any time during its life cycle, imported into the United States from another
country. If the animal was
never imported from another country, its origin could be none other than the
United States. The single exception
would be cattle born and raised in Alaska or Hawaii and transported for a period
not to exceed 60 days through Canada to the United States. The Act addresses this exception. To ascertain eligibility for the
United States label for live animals slaughtered in the United States, only
animals imported into the United States would need to be affirmatively
identified. It would be impossible
for live animals residing in the United States, that have never been imported,
to lose their eligibility for the United States label. Therefore, there is no need to establish a tracking mechanism
for these animals for purposes of country of origin labeling. According to 1999 U.S. slaughter
figures, only about 5 percent (approximately 1.9 million head) of all cattle
slaughtered in the United States (approximately 36 million head) were imported.
Thus, approximately 95 percent of all cattle slaughtered in the United
States would be eligible for the United States label.
From a standpoint of efficiency and practicality, it would be preferable
to establish effective guidelines to accurately identify the minority of cattle
ineligible for the United States label. B. Methodology
for Differentiating Live Cattle Eligible for the United States Label and Live
Cattle Eligible for a Multi-Country Label
USDA’s guidelines for the voluntary country of origin labeling of covered commodities should be grounded in a methodology that (1) affirmatively identifies all live cattle imported into the United States, and (2) identifies the country or countries from which these imported cattle originate. 1.
Affirmative
identification of all live animals imported into the United States The Canadian Food Inspection Agency
(CFIA)
administers the Restricted Feeder Program for cattle exported from the United
States. This program requires
Canadian feedlot operators to obtain an annual import permit, with a permit
application process resulting in feedlot certification. Among other things, this
program requires that all imported cattle be identified with either a USDA ear
tag or a CFIA approved ear tag. Additionally,
a fee is associated with the import permit; audits are conducted on the feedlot;
health certificates are required; on-site inspections are authorized; and
restrictions are imposed on the disposition of cattle from the permit holder’s
premises. It is R-CALF USA’s understanding
that USDA-APHIS presently requires all cattle imported into the United States to
be accompanied by a USDA-APHIS health certificate, which, among other things,
requires documentation as to the country from which the cattle were imported.
This health certificate is presumably filed and recorded by USDA-APHIS. R-CALF USA also understands that in addition to a
USDA-APHIS health certificate, cattle imported from Mexico are required to be
tagged with a metal ear tag, similar to the Brucellosis tags used in the United
States. USDA should require all importers of cattle to
obtain an import permit and USDA should issue a “Certificate of Importation”
(Certificate) for all imported cattle. This
Certificate should reference the USDA-APHIS health certificate accompanying the
imported cattle. This Certificate
should be required to remain with the cattle and transferred to any new owner at
the time of resale, or to the packer at time of slaughter.
The permit holder would have an affirmative duty to disclose the
Certificate at the time of sale or time of slaughter and this duty would
transfer to any new owners of the imported cattle. USDA should further require all persons who may
subsequently purchase imported cattle to also obtain an import permit.
Such permits could be obtained from USDA within a reasonable period
following the purchase date. Such a
permitting process could be fashioned similar to the permits required of peanut
handlers who buy and sell peanuts under quota. 2.
Identifying the country or countries from which imported cattle
originate USDA should include on the Certificate the country
or countries from which the cattle were imported. Cattle that have resided in two or more countries, i.e., the
United States and one or more additional countries, while ineligible for the
United States label, should not be precluded from including the United States as
one of the countries in which the animal resided. This would allow for multi-country labels, e.g., “Product
of Mexico and the United States,” Product of Australia, Mexico, and the United
States,” or “Product of Canada and the Untied States.” The principle identifier for
determining whether an animal was imported should be the Certificate.
Consistent with the proposed mandate to disclose imported cattle, the
secondary identifier is accomplished by the metal ear tag previously discussed
for Mexican cattle imports, the tags used for Brucellosis testing, or the ear
tags presently used by the CFIA. R-CALF
USA proposes that a similar tag be required for all cattle imported from all
countries. Color-coded ear tags could be used to denote the various
countries from which the cattle were imported.
Cattle arriving from Alaska and Hawaii and spending no more than 60 days
in Canada during transport would be exempted, and the accompanying health
certificates originating in Alaska or Hawaii would be the basis for determining
this exception. Fat cattle
imported directly to a U.S. packing plant for slaughter could be exempted from
the ear tag requirement if they arrive in sealed trucks as is presently the
practice.
All live cattle slaughtered in
the United States that do not have the accompanying Certificate indicating the
animal had been imported, and do not have an import ear tag, hence, have spent
their entire live-cycle in the United States, would be eligible for the United
States label. Cattle that have been
imported would be eligible for a multi-country label. C.
Ensuring Compliance with Imported Cattle Disclosure Guidelines Under R-CALF USA’s proposal, all importers of cattle and persons who subsequently purchase these imported cattle, whether stockers or feeders, would be required to obtain an import permit. USDA should require an annual year-end report from each permit holder requesting information regarding the number of cattle imported during the year, the disposition of imported cattle during the year, including the name and address of any buyers or the packer if delivered for slaughter, the dates of such transfers of ownership, and the inventory of imported cattle remaining at the end of the year. This report would be filed with USDA and would be subject to audit. In addition, USDA will issue the initial importer a Certificate for all cattle imported into the United States by a permit holder. The Certificate will be required to be transferred to any future owners of the imported livestock. If the imported cattle are transferred to a new owner, not a packer, the permit holder would report the sale to USDA and the buyer would have a reasonable time period with which to obtain a permit. If the transfer is to a packer, the packer will additionally submit a report of the slaughter of the transferred cattle. Packers would also be required to file an annual report of all imported cattle slaughtered during the year. The packer should be required to retain records of all imported animals slaughtered for a period of three years. The original certificates of importation, the annual reports from permit holders, the records of ownership transfers, and the annual report of cattle slaughtered by packers will provide a verifiable trail of the life cycles of cattle imported into the United States. USDA will be able to conduct periodic audits of packing facilities to ensure disclosure of all imported cattle delivered to the packer for slaughter.
D.
Conclusion The preponderance of live cattle slaughtered in the United States are born, raised, and slaughtered in the United States and, therefore, eligible for the United States label. It is only through the physical act of importing a live animal from a foreign country that causes a disqualification for the United States label. This single disqualifying factor for eligibility for the United States label is already tracked by USDA-APHIS for other purposes, principally safety, through health certificates. These health certificates can be combined with the issuance of a certificate of importation to provide clear evidence that an animal has been imported. Moreover, these health certificates and the new Certificate of Importation would identify the importing country. In addition, the practice of physically identifying imported live animals is currently accomplished with permanent ear tags affixed to Mexican live cattle imports, cattle tested for Brucellosis, as well as cattle exported to Canada, and this practice could readily be expanded to include imports from all countries. To accomplish the objective of determining eligibility of live cattle slaughtered in the United States for the United States label, R-CALF USA recommends:
R-CALF USA appreciates the
opportunity to submit these comments. Please
recognize that these comments are preliminary in nature and are only intended to
provide a starting point upon which effective voluntary guidelines can be
implemented. R-CALF USA will
circulate this proposal among its various affiliated organizations for purposes
of soliciting additional input and will report any modifications that may be
made to this preliminary proposal. R-CALF USA will be submitting
comments concerning Parts II through IV mentioned in the introduction of this
submission. If the USDA has any
questions regarding these comments, please do not hesitate to contact me. Sincerely, |
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