USDA is asking for comments about the 2003 proposed rule for M-COOL. The following are suggestions that you may want to include in your comments to USDA.

Comments can be sent through www.regulations.gov or by fax to 202-720-1112

USCA’s official comments will be posted at www.uscattlemen.org as soon as possible.

1. Mention how import markings are used now to identify country of origin and how each segment of the beef industry could rely on them to verify the country of origin of cattle as they move through the changes in ownership. Mention any segregation techniques that you have seen used successfully for other programs.
2. An exemption of cattle from the Treasury Department ‘J-List’ is a permanent solution for the industry and is helpful for tracking imported animals for disease purposes. Let them know this is something you or your organization supports.
3. Record-keeping requirements were reduced substantially in the interim final rule for fish and sea food. Mention how minimizing the record keeping requirements for down stream segments of the beef industry will help the program be successful.
4. The amendment to COOL included in the 2007 House Ag. Committee clarifies for USDA the labeling requirements. You can talk about how these changes will make implementation easier.
5. Make a recommendation on a ‘grandfather’ date that USDA can use to allow for any cattle already in the supply chain. You may point out that a phase in period may not be needed if import markings are used at the point of slaughter as a verifiable means of determining origin. Essentially those of us in the industry know what cattle are not of US origin let them know that.
6. Mention that of 45 comments received on the agencies interim final rule for fish and shell fish, only one negative comment was received. Commend them for doing a good job of working with the fish industry to make the program work.