Mandatory COOL to Increase Record Keeping; Not a Food Safety Measure

By Sarah Young Livestock Editor
Thursday, August 28, 2008 8:50 AM CDT

With mandatory Country of Origin Labeling beginning in September, some small meat processors in Wisconsin may see increased time spent on record keeping.

“The impact could be very little to quite a bit,” says UW-Extension Meat Specialist Jeff Sindelar. “It depends on where they are selling their products to.”

Since COOL is mainly pointed at the retail end, it may or may not affect some processors, depending on where the processor is selling the product.

COOL is mandated at the retail level by the Agriculture Marketing Services.

Those retail outlets that have to comply with COOL must sell $230,000 of fresh or frozen fruits and or vegetables per year. So generally grocery stores and larger all-in-one stores that sell groceries, like Wal-Mart, will have to comply.

“They would be required to do Country of Origin Labeling on whole muscle or ground single ingredient meat and chicken products,” Sindelar explains.

For some meat processors, this won’t be a problem because they only sell in their own shops, but others that sell to larger grocers will likely have to bring COOL record-keeping into their daily routine.

Grocery stores would essentially force smaller processors to abide by the COOL labeling since it is a requirement for them.

“It’s like looking back and saying ‘Listen if you want to supply to us you have to do the Country of Origin Labeling’,” says Sindelar.

At that point, processors would have to make one of two decisions, abide by the grocers request and implement COOL labeling and continue to sell whole muscle or single ground products, or cease selling those specific products to the store.

Sindelar believes most processors in that situation will choose the route of COOL labeling, although it could increase costs.

Larger processors selling whole muscle cuts and single ground products to smaller processors would not require COOL labeling. However, if the larger scale processors are implementing COOL, then most likely, all their products would be COOL labeled.

More records equal more time in labor and more money.

USDA Agriculture Marketing Service projected the costs at $2.5 billion nationwide. With $375 million placed on producers and ranchers and $235 million for retailers including small processors.

“There’s no question there’s going to be some cost, probably more of a time standpoint,” he says. “We’re talking about a paper trail n a tremendous amount of additional paperwork.”

For a single package of a whole muscle or single ground product, the USDA has to have the ability to trace back a product to its origin via a paper trail provided at the retail level.

“The fines for not following or not meeting the Country of Origin Labeling are between $1,000 and $10,000 per fine,” he says. “It sounds like it can be very expensive.”

Sindelar says UW-Extension will be working with DATCP for the state inspected plants to meet and visit about COOL implementation including what forms are required for COOL.

COOL is an Agriculture Marketing Service program and has nothing to do with food safety, Sindelar says.

“This is a marketing system,” he said.

The marketing aspect is causing some acceptance issues within the meat industry.

“It has nothing to do with food safety,” he says. “It has nothing to do with the quality of a product. It has everything to do with traceability.”

Sindelar doesn’t believe premiums will be received at any end for the extra labeling.

“I really think it’s a way to promote and sustain meat consumption,” he says. “It’s kind of another offshoot of something locally grown on a nation-wide scale.”

The seafood industry has been doing the origin labeling for a couple of years. While visiting with people in seafood industry, Sindelar says they say “it’s not too bad” and they are able to keep up with it.

“But they will be the first to say ‘it’s a lot of record keeping,’” he said. “It’s a lot of keeping track of where the product is coming from.”

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