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AMS - Beefcarcassrevisions

From: John Stika <jstika@certifiedangusbeef.com>

Sent: Thursday, November 13, 2014 4:22 PM

To: AMS - Beefcarcassrevisions

Cc: Joanna Ruegsegger

Subject: Beef Carcass Grading Standard Comments - Certified Angus Beef

Attachments: CAB Beef Grading Standard Comments.pdf

Follow Up Flag: Follow up

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If possible, please respond to this email to confirm receipt of these attached comments.

Thanks you.

John F. Stika

John F. Stika

President

Certified Angus Beef LLC

206 Riffel Rd.

Wooster, OH 44691

Office: 330/345‐2333

Fax: 330/345‐0808

Mobile: 330/465‐6172

email: jstika@certifiedangusbeef.com

website: certifiedangusbeef.com
November 13, 2015 

Beef Carcass Revisions 

Standardization Branch 

LPS Program, AMS, USDA, 

1400 Independence Ave., SW., STOP 0258 

Washington, DC 20250 

Re: Docket ID No. AMS-LPS-14-0052, Notice: Request for Comments Regarding U.S. 

Standards for Grades of Carcass Beef 

Certified Angus Beef LLC (CAB) is a not-for-profit arm of the American Angus Association®

(Association) and the owner of the leading global consumer brand of fresh beef – the Certified 

Angus Beef ® brand. We are proud of our affiliation with USDA which began more than 36 years 

ago when members of the Association worked closely with USDA, AMS to create the beef 

carcass certification system. Since 1978, when CAB became the first USDA certified beef brand 

offered to consumers, the U.S. Standards for Grades of Carcass Beef along with the accuracy and 

precision with which they are applied have been integral to our efforts to establish consumer trust 

in our brand’s consistent quality and value proposition. They have also provided a framework for 

value-based marketing by which farmers and ranchers have been able to garner financial reward 

for cattle that meet our 10 science-based carcass specifications as well as other carcass targets 

established throughout the industry. As a result, we welcome the opportunity to provide 

comment as USDA seeks input on methods to improve beef carcass grading. 

Through our first-hand experience in working across the full beef supply and merchandising 

chain, we appreciate the importance of having a beef grading system that remains relevant to all 

stakeholders and enhances the consumer’s experience with beef. Therefore, we support the effort 

of USDA to explore potential methods that may more effectively characterize beef carcass 

composition and beef palatability. In doing so, it is imperative that discussions around any 

potential modifications to the beef grading system be led by a well-supported pool of scientific 

evidence suggesting that change is merited. 

CAB fully agrees that significant changes have taken place in the beef industry since the current 

grade standards were adopted. Perhaps most notably has been the increase in steer and heifer 

carcass weights which today are much heavier than those utilized to establish the current yield 

grade equation. As mentioned in the Notice, research suggests that application of the current 

yield grade equation introduces a ribeye area bias which penalizes heavier carcasses, thereby 

mischaracterizing their composition and skewing carcass value. It is our opinion that steps should 

be taken by USDA to address this inaccuracy, especially if carcass weights continue to increase. 

However, we question if sufficient research exists in the public domain to make a sound 

recommendation to improve the current equation. If USDA believes there is sufficient research 

available, we encourage USDA to further communicate that relevant research to provide the 

industry a broader understanding of how the existing equation and the associated metrics could 

be augmented to be more applicable to today’s carcass population. If the necessary pool of 

scientific evidence does not exist, we encourage USDA to identify the knowledge gaps and fund 

research that can effectively guide improvements in the accuracy of the current yield grade 

equation or identify more relevant methods, perhaps beyond yield grade, to more accurately 

characterize carcass beef composition and more directly reflect true retail product yield and value. 
Beef Carcass Revisions 

Standardization Branch 

LPS Program, AMS, USDA, 

Page Two 

November 13, 2014 

The beef carcass quality grade standards have served the beef community very well as a practical 

and effective system to delineate beef quality and predict consumer satisfaction. Any changes to 

the standards that could ultimately impact the eating experience consumers have with beef must 

be thoroughly reviewed before being proposed or implemented to avoid any potential detrimental 

impact on long-term beef demand. That being said, we are encouraged by the findings of recent 

research suggesting that dentition may be a more effective method to associate animal maturity 

with palatability rather than relying on bone ossification. It is our understanding that additional 

research is currently being conducted to further the foundation of knowledge in this area and we 

would be supportive of further dialogue and actions to transition toward a dentition-based 

assessment of maturity for beef carcasses if further supported by the results of research currently 

being conducted. At the same time, it is our understanding that the results generated thus far 

solely represent a grain-fed steer and heifer carcass population. We would encourage USDA to 

further investigate the repeatability of using dentition as a means to assess maturity across a grassfed population of steer and heifer carcasses to better understand the potential impact a 

modification to the carcass maturity standard could have on beef palatability across the various 

production systems currently utilized in the industry. 

Our network of licensed beef packers covers the complete spectrum regarding the 

implementation of instrument grading and we have observed the fact that both traditional human 

graders and instrument grading systems can perform effectively. Yet, we do believe that the 

objective nature of an instrument-based system allows for greater standardization of grading and 

certification throughout the industry. CAB would encourage USDA to follow the 

recommendations set forth in the AMSA report on instrument grading and, moreover, work 

closely with beef packers to identify the reasons why instrument grading has not been universally 

implemented and proactively engage any concerns to identify solutions that move the use of the 

technology forward. 

We certainly appreciate the current initiative of USDA to engage stakeholders in an effort to keep 

beef carcass grading relevant. We look forward to further discussions with USDA on these points 

and would be glad to visit directly in more detail to assist in clarifying an effective and practical 

path forward. 

Sincerely, 

John F. Stika, Ph.D. 

President 

Certified Angus Beef LLC