USDA can immediately implement COOL for beef by:
*Allowing packers to indicate beef has come from imported animals without having to specify each further production step that may have occurred in the United States.;
*Allowing packers to label blended products with a list of the countries of origin that may be contained in the product, rather than a definitive list of each country;
*Allowing retailers to rely on pre-labeled products for origin claims;
*Allowing meat packers to rely on country markings that already are applied to cattle imports in order to determine origin;
*Eliminating unnecessary and duplicative record-keeping requirements regarding chain of custody and separate tracking during the production process to allow packers and retailers to rely on documents they already keep in the ordinary course of business;
*Reducing the record retention requirement from two years to one year; and
*Specifying that producers and retailers do not need to demand affidavits or third party verification audits of suppliers in order to adequately substantiate origin claims.
Now these things make sense. Some of the requirements the Government dreamed up for COOL were really stupid and I feel designed to make COOL fail. These recommendations by R-Calf kill most of the problems the USDA dreamed up for COOL and Congress needs to implement them. This would really save the program and reduce the expense of the program to a manageable level. I heartily support them.
Don't get me wrong, I don't think COOL will be a major factor in the beef markets in the long run since beef is a commodity item, but it is the right thing to do. Almost everything else gets to bo labeled as to where it comes from, why isn't beef allowed this luxury?
The really good idea is always traceable back quite a long way, often to a not very good idea which sparked off another idea that was only slightly better, which somebody else misunderstood in such a way that they then said something which was really rather interesting. John Cleese
