Published: January 30, 2008 12:32 pm            

The Pork Professor: Time to begin preparations for COOL implementation

Originally published in the January 25, 2008, print edition.

On May 13, 2002, President Bush signed into law the 2002 farm bill that included a new requirement for country of origin labeling for beef, lamb, pork, fish, perishable ag commodities and peanuts.

Originally slated to be in effect by the end of September 2004, enacting of the COOL law has twice been delayed (with the exception of farm-raised and wild fish and shellfish) but is now due to be carried out beginning in October of 2008.

Unlike the last two rounds, initial indications are that COOL will not be delayed, and instead will become a reality come next fall. Up until this point, voluntary guidelines have been in effect, with participation not required for livestock, packing or retailing industries.

The COOL issue has been the topic of much debate. Concerns over foreign animal diseases, including avian flu, bovine spongiform encephalopathy and a variety of food safety issues with food products imported from China have really pushed the COOL issue into the spotlight.

Proponents argue that COOL is necessary to enhance the security of our nation’s food supply, and is needed to allow consumers to choose U.S. products if they so choose. Detractors feel that requiring COOL will greatly increase costs throughout the food chain and will ultimately weaken U.S. meat production and sales due to increased verification and paperwork requirements.

Under the current law, packers need to segregate commodities by country of origin throughout the entire production chain and document as such. A verifiable audit trail for country of origin must be maintained, with audit results being provided to retailers. All products must be labeled with country of origin.

In turn, packing plants may require producers to verify via a third party showing where animals were born and raised, provide an affidavit from producers with each stating where animals were born and raised, and/or allow access to producer records for random audits.

The U.S. Department of Agriculture has indicated that producers will need to verify ownership and origin of animals and has suggested that supporting records include birth records, shipping/receiving/ transportation records, purchase records, animal identification system, sales receipts, feeding records and bills, animal inventory records, performance records and health records.

Regardless of whether livestock producers are for or against COOL, they should begin making preparations for its implementation this upcoming fall. Individuals should begin communicating with their packers to determine if the packers will have any requirements or if there will be any contract ramifications.

There are three distinct product labeling requirements in COOL: U.S-only origin, foreign-only origin and mixed origin. In the case of imported products, the food label will have to indicate where it started, was grown or raised and processed.

For example, a meat label for pork might read, “From hogs born in Canada, raised and slaughtered in the United States.” Therefore, producers considering purchasing isoweans from Canada need to ensure first and foremost that their packer will be willing to take them once they reach market weight. Even if you are purchasing isoweans or other age/size pigs that are U.S.-born, you should begin insisting on records or receipts from the seller of the pigs that will then serve as proof of origin.

Keep abreast to what is going on at the House and Senate level concerning ratification and/or implementation of COOL, and ensure you are prepared should the proposed law become a reality, which it appears it will.

        

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