1 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

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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.comNovember 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 a rm of the American Angus Association ®
(Association) and the owner of the leading global co nsumer brand of fresh beef – the Certified Angus Beef ®

brand. We are proud of our affiliation with USDA whi ch began more than 36 years ago when members of the Association worked closely w ith 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 inte gral to our efforts to establish consumer trust in our brand’s consistent quality and value propositi on. They have also provided a framework for value-based marketing by which farmers and ranchers h ave been able to garner financial reward for cattle that meet our 10 science-based carcass sp ecifications as well as other carcass targets established throughout the industry. As a result, we welcome the opportunity to provide

comment as USD A

seeks input on methods to improve beef carcass gradi ng.

Through our first-hand experience in working across the full beef supply and merchandising chain, we appreciate the importance of having a bee f 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 e ffectively characterize beef carcass composition and beef palatability. In doing so, it i s 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 take n place in the beef industry since the current grade standards were adopted. Perhaps most notably has b een the increase in steer and heifer carcass weights which today are much heavier than th ose 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 whi ch penalizes heavier carcasses, thereby mischaracterizing their composition and skewing car cass value. It is our opinion that steps should be taken by USDA to address this inaccuracy, especial ly 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 U SDA 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 eq uation 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 USD A 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 b eyond yield grade, to more accurately characterize carcass beef composition and more direct ly 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 t he beef community very well as a practical and effective system to delineate beef quality and pre dict 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 imple mented 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 eff ective method to associate animal maturity with palatability rather than relying on bone ossif ication. 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 furthe r supported by the results of research currently being conducted. At the same time, it is our understa nding that the results generated thus far solely represent a grain-fed steer and heifer carca ss population. We would encourage USDA to further investigate the repeatability of using denti tion as a means to assess maturity across a grassfed population of steer and heifer carcasses to bette r understand the potential impact a modification to the carcass maturity standard could hav e on beef palatability across the various production systems currently utilized in the industry.

Our network of licensed beef packers covers the comp lete spectrum regarding the implementation of instrument grading and we have obse rved the fact that both traditional human graders and instrument grading systems can perform eff ectively. Yet, we do believe that the objective nature of an instrument-based system allow s for greater standardization of grading and certification throughout the industry. CAB would enco urage USDA to follow the recommendations set forth in the AMSA report on inst rument grading and, moreover, work closely with beef packers to identify the reasons wh y instrument grading has not been universally implemented and proactively engage any concerns to ide ntify solutions that move the use of the technology forward.

We certainly appreciate the current initiative of U SDA to engage stakeholders in an effort to keep beef carcass grading relevant. We look forward to fur ther discussions with USDA on these points and would be glad to visit directly in more detail to as sist in clarifying an effective and practical path forward.

Sincerely,

John F. Stika, Ph.D.

President Certified Angus Beef LLC