Mandatory COOL Deadline Approaching, Are You Ready?

By Sarah Young Livestock Editor
Thursday, August 21, 2008 8:50 AM CDT

The mandatory Country of Origin Labeling deadline of Sept. 30 is approaching quickly. Are you prepared?

Most producers have heard the term COOL kicked around, but the 2002 Farm Bill Provision is quickly going to become a part of day to day operations for some livestock producers if they haven’t been keeping records.

Now is not the time for panic, but a time for preparation.

Instead of panicking, producers should pay attention, understand and know what is going to be expected of them when COOL begins.

Even though livestock producers are not directly regulated by the COOL interim final rule as livestock are not considered covered commodities, only producers have first-hand knowledge concerning the origin of their animals.

Definitive origin information must be provided to slaughter facilities so that meat covered commodities can be accurately labeled at retail.

All animals in the U.S. as of July 15, 2008 are considered to be U.S. origin. It is important for producers to document herd size and composition for these animals that are “grandfathered” in under this date. Young cows that may not be sold for several years may need this documentation to verify the status as of July 15.

Presumption of origins by packers is not allowed. For example, it is not acceptable to assume that if an animal has no ear tag and/or brands identifying that the animal was born and/or raised in Canada or Mexico, the animal is of U.S. origin.

The USDA will consider a producer affidavit as acceptable evidence on which a packer may rely upon to initiate an origin claim, as long as the affidavit is made by someone having first-hand knowledge of the origin of the animal and can identify the animal. Evidence that identifies the animal unique to a transaction or sale can include a tag ID system along with other information such as the type and sex of the cattle, number of head involved in the transaction, the date of the transaction and the name of the buyer.

Producers will have to rely on each others record keeping ability to create accurate affidavits.

A backgrounder or feed lot operation that commingles cattle from several sources is authorized to rely on previous producer affidavits as a basis to formulate their own affidavit for the origin of the new lot.

The affidavits must also identify the animals involved in the transaction. In contrast, first-hand knowledge would not include an affidavit made by someone such as a truck driver whose knowledge would be limited to where he picked up the load. The driver would not have first-hand knowledge as to whether the animals were necessarily born at that location.

While buyers may ask producers to sign an affidavit stating the origin of the animals they are selling, it’s nothing to panic over.

“The normal business records that producers keep are all that are needed to prove compliance if they are audited,” says John Lawrence, director of Iowa Beef Center. “These [records] may include the inventory records, sales receipts, health papers, etc., that most farmers already have.”

If you aren’t keeping track of these items, you should be as a good business practice. If not, its time to start and keeping these records will prepare you for COOL and hopefully aid your business in the process.

Other records that could be used to assist in a COOL verification include birth records, receiving records, purchase records, animal health papers, sales receipts, animal inventory documents, feeding records, APHIS VS forms, segregation plans, State Brand requirements, breeding stock information, Beef Quality Program papers, and other similar documents.

In addition, participation in USDA Quality System Verification Programs (QSVP), such as the USDA Process Verified Program (PVP) and the Quality Systems Assessment (QSA) Program that contain a source verification component is also considered as acceptable evidence to substantiate COOL claims.

Despite the possible worry of producers that COOL will have a large impact on their day-to-day operations, the main change that COOL will demand is an increase in communication, he says. Cattle producers should be communicating with their buyers in advance to know exactly what kind of requirements the buyer will have.

“[There will be] more communication and paperwork between buyers and sellers,” Lawrence said. “Keep documentation. If you have animals of different origin on the same farm then be able to inform the buyer.”

Along with communicating with buyers to be clear on what they need, livestock producers should just work on better understanding COOL altogether, he adds.

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