Why Resistance to COOL

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For those of you who don't know John Munsell- he is a former slaughter and meat plant operator from Miles City Montana that has worked with the USDA and Multinational Packers for years and has first hand knowledge and insight to the beef industry....
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Why resistance to COOL



John W. Munsell

Manager, Foundation for Accountability in Regulatory Enforcement

Opinion

July 12, 2006

Miles City, Montana

US



I agree with Tom Buis' statements in his article entitled "USDA needs to keep pressure on Japan" in the 7-11-06 Livestock Brief. He referred to Country of Origin Labeling, to which I'd like to refer.



USDA spokesman Ed Loyd recently stated "South Korea does not want to receive Canadian beef mixed in with U.S. imports, which he described as a "pretty minor" issue that can be easily remedied" [BNA -- Delay in U.S. Beef Exports to South Korea Will Be Resolved 'Within Weeks,' USDA Says -- By Derrick Cain]. Mr. Loyd merely stated a fact well known by the USDA and packers, and that is that product separation and distinction between Canadian meat and American meat can be easily remedied. Admittedly, packer production costs would be minimally increased, which will automatically be passed on to the consumer, with no deleterious impact on packer profits. So, why does USDA downplay COOL and claim that billions will be required to implement it, and why do the major packers and their associations oppose COOL?



The answer is directly tied to Secretary Johanns' mandate last week that our foreign trading partners must agree to an "All or Nothing" trade agreement, which prevents our global customers from delisting individual noncompliant American plants. The ultimate goal is to create a global, seamless production/marketing meat scheme in which any meat plant in any country which has implemented HACCP will be allowed to export meat globally, with no fear of being delisted in spite of recurring noncompliance's with OIE "science based" trade protocol.



Are consumers safe in assuming that all plants on this globe (or even in America?) will permanently comply with safe food production practices? Even FSIS admits that plants don't always comply with their HACCP plans. In an article authored by Bernard Shire in Meat & Poultry on June 1, 2006, Dr. Daniel Engeljohn, FSIS deputy assistant administrator for policy analysis and formulation made some startling (and true) statements. The article states..."Last year, for the first time, Salmonella rates rose in the beef and pork side of the industry. The agency doesn't really know why it has increased, according to Engeljohn". Dr. Engeljohn is quoted as saying "We suspect that the HACCP plans being used both in the meat and poultry industries are designed to deal with Salmonella, but that some plants, for whatever reasons, aren't doing it". The article also stated "Plans are being carried out with carelessness, he (Engeljohn) adds. Just because there's something in the [HACCP] plan doesn't mean it always happens".



Why doesn't FSIS aggressively implement enforcement actions against American plants which the agency knows are not doing what their HACCP plans require? Frankly, because the agency doesn't know about these noncompliance's. Why? Because the agency's stance under the HACCP environment (by its own admission) is "Hands Off", while the agency from its remote position blithely instructs the plants to police themselves. 100 years ago the Federal Meat Inspection Act was written because plants were NOT policing themselves. In less than 100 years, USDA turned about face and now trusts plants to police themselves, while Dr. Engeljohn's statements constitute an official agency admission that self-policing is not working as theoretically envisioned.



Our trading partners know that this conundrum exists in America, which is one reason why they impose purchase specifications which are greater than OIE's trade protocol.



The large multinational meat conglomerates understandably prefer an indistinct, amorphous, global soup of non-distinguishable meat which cannot be traced to its origin. If one country experiences a shortage of livestock, and livestock prices increase, a multinational corporation merely increases production at one of its other plants across the globe to fill the supply void with cheaper livestock. In the absence of COOL, consumers everywhere have no idea where their meat originated.



Congress has passed COOL, but now refuses to fund the law, having buckled under pressure from the large packers and a recalcitrant USDA. If Congress had provided necessary funding, and if USDA had allowed enterprising packers such as Creekstone Farms and Gateway Beef Cooperative to perform voluntary 100% BSE testing (although it's not scientifically justified), American producers and packers would have been shipping beef products to the Pacific Rim for years.



For the sake of producers, consumers and our balance of trade, it's time for USDA to heartily endorse COOL, 100% BSE testing and other customer requirements. Packer profits will not suffer, because all costs will be automatically passed on to consumers, which is how it must be.



Countries have the sovereign right to establish their own purchase requirements, even though they may exceed the minimum standards (and definitions of "science") established by OIE and WTO. If we desire to sell beef to Japan, South Korea et al, all we must do is simply meet their requirements, which our flexible free enterprise system has always been able to accomplish, previously. Artificial constraints imposed by USDA have removed the flexibility America needs to fulfill foreign demands.



Tom Buis' concluding sentence is right on the money when he stated "I truly hope the USDA does everything possible to meet with Japanese demands, as U.S. producers are ready to export our high-quality product to them". Producers are not only capable, but also willing to segregate their livestock, provide animal ID, even produce natural, hormone free or certified grass fed animals in order to meet a wide variety of non-standardized consumer desires. The OIE and WTO cannot dictate which consumer demands are science-based, because consumers base their purchases on personal preferences, oftentimes totally disassociated from scientific underpinnings. You prefer a Ford, I prefer a Dodge. You demand one color, I another. You prefer a steak cut 3/4", I prefer 1 1/4". You prefer Angus or Hereford, I prefer Piedmontese.



The sale of organic meats surged 55% last year, in spite of its higher cost. Wal-Mart recently announced its intention to market organic foods, in spite of its higher cost. Japanese have expressed their willingness to pay a higher price for beef which has undergone 100% BSE testing. When domestic and foreign consumers are willing to pay a premium price for products they PERCEIVE to be superior, USDA has no business imposing artificial restraints to trade and hide behind OIE's scientific skirt.



Producers are willing to provide products in demand, and consumers are willing to pay the going price. The only components dragging their feet are the USDA and the multinational packers. Markets can only be opened when seller and buyer come to an agreement, which is currently forbidden by biased USDA policies. Time for a change!
 
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