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AMS - Beefcarcassrevisions

From: Kristina Butts <kbutts@beef.org>

Sent: Thursday, November 13, 2014 4:40 PM

To: AMS - Beefcarcassrevisions

Subject: NCBA's Comments

Attachments: NCBA_AMS_Grade_Standards_11.13.pdf

Follow Up Flag: Follow up

Flag Status: Flagged

Please find the attached comments from NCBA and our working group.  Looking forward to work with AMS as you

continue to seek input.   

Thanks,  

Kristina  

Kristina Harris Butts

Executive Director of Legislative Affairs

National Cattlemen’s Beef Association

1301 Pennsylvania Ave NW, Suite 300

Washington, DC 20004

202‐879‐9106 direct  

kbutts@beef.org

www.beefusa.org  
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November 13, 2014 

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 U.S. Standards for Grades of 

Carcass Beef 

 The National Cattlemen’s Beef Association appreciates the opportunity to provide comments 

on the AMS notice for input on the current standards for grades of carcass beef. Established in 1898, 

NCBA is the oldest and largest national trade association representing America’s cattle industry. Our 

membership’s top priority is to produce the safest, highest quality, affordable beef in the world. This has 

been consistent throughout our industry’s history to continually improve our knowledge and ability to 

produce beef to meet consumer preferences. Research on consumer preferences suggests a direct link 

between the eating quality of beef and a consumer’s purchase behavior or willingness to pay 1,2. Beef 

palatability plays a critical role to consumers and their demand for beef products. Since 1965, beef 

quality and yield grade standards have been modified to reflect changes within the cattle industry. The 

collection of additional research continues to be important to lead the discussions around potential 

changes to the grade standards of beef. 

 Cattle producers have invested more than 10 million checkoff dollars since 1993 in research to 

better understand palatability and what characteristics drive consumer demand for beef products. 

NCBA’s membership remains very involved with research to improve the quality of our beef products for 

consumers. NCBA’s membership is committed to working with all sectors of the beef industry, academia 

and USDA to identify areas within the beef grade standards where relevant science leads the discussions 

around potential modifications to the standards. NCBA has created an industry working group 

representing the cow/calf, feeder and packing sectors of the cattle industry. Members of the working 

group have reviewed research specific to carcass maturity and various carcass attributes including carcass 

weights and the current yield grade equation. NCBA agrees with USDA that significant changes have 

occurred in the U.S. cattle industry since the most recent grade change in 1997. However, the discussions 

of potential modifications must be based on substantial scientific evidence to support any change to the 

current standards. 

 

 NCBA appreciates the Agency’s recognition of recent beef checkoff research 3,4 on carcasses 

from fed steers and heifers less than 30 months of age classified as ‘A’ maturity based on dentition rather 

than skeletal maturity. Currently, a second phase of this research is underway to compare maturity data 

collected on fed steers and heifers older than 30 months of age using dentition. This research will be 

shared with NCBA’s working group and with USDA to foster continued discussion and to pursue 

USDA’s consideration to shift to dentition-based assignment of carcass maturity for fed steers and 

heifers. This is an area where the industry would be very supportive of working with AMS to quickly 

implement the use of dentition to assess the maturity of beef carcasses. 

 

 
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 Additionally, NCBA recognizes that USDA is responding to certain industry segment questions 

related to how grade standards apply to grass-finished beef. Checkoff-funded market research shows that 

many consumers today do not necessarily understand USDA quality grades. A separate grading system 

for grass-fed beef likely would cause greater consumer confusion and could be implemented to the 

detriment of grain-finished beef, the overwhelming type of beef produced in the U.S. today. When 

considering the USDA Select quality grade research has shown that grain-finished beef does not have 

the same eating characteristics as grass-finished beef. Perhaps a marketing claim or certification program 

within the grass-finished beef supply would be a potential solution for USDA to consider to better 

differentiate these products. Any proposed changes should be grounded in sound science and should take 

the entire palatability equation into consideration. For example, if a grass-fed product were certified 

tender but did not deliver on flavor and/or juiciness, the consumer could have a negative eating 

experience that reflects poorly on all beef products. More research likely would need to be considered by 

USDA to help answer these questions. 

 NCBA’s membership encourages USDA to fund additional research specifically on the yield 

grade equation and how it is applicable to the current cattle supply. As stated in the Notice, carcasses 

today are heavier than the carcass weights utilized in the current yield grade equation. Our membership 

has identified 1.) the correlation of hot carcass weight to ribeye area (ribeye bias) and 2.) the correlation 

of the ribeye area to total lean as topics where additional data needs to be considered by AMS. Does the 

Agency believe there is sufficient research to define the correlation of hot carcass weight to ribeye area? 

If so, we encourage USDA to share the relevant research to provide the industry with a better 

understanding of this relationship. If sufficient research does not exist we encourage the Agency to 

identify the knowledge gaps and fund research to better answer these questions. NCBA also requests the 

Agency to evaluate all published research on beef carcass yield grades and identify if there are any data 

gaps that need to be further explored. As AMS reviews available research, does the Agency believe there 

is sufficient data on carcass yield grades without the need to complete a large research study? Cattle 

producers remain committed to working with USDA to review current research and identify areas where 

more knowledge needs to be collected to allow science to suggest possible modifications to the yield 

grade equation for beef carcasses. Additionally, NCBA’s membership suggests for USDA to evaluate the 

yield grade equation as a method to identify the retail value of beef products. The carcass’ cutability is 

measured by the yield grade and as relevant data is collected any modifications to the yield grade 

equation should reflect the retail beef value. 

 Specific to instrument grading, NCBA has been involved in this effort since day one and 

supports the widespread use of this technology to ensure USDA grades are being applied consistently 

across all packing and processing establishments. Standardization of yield and quality grades throughout 

the industry will have a direct impact on the consistency of our beef products with consumers. AMS 

should work with packers in the near future to identify the reasons why the implementation of instrument 

grading is lacking throughout the industry and work to address any concerns by re-evaluating things like 

the potential disparity between instrument and human graders, the application of existing technologies or 

the identification of new technologies. NCBA believes this is an area where USDA can work 

immediately to gather input from stakeholders and work to address any concerns preventing the industrywide implementation of instrument grading. At such a time when the industry implements instrument 

grading it will be imperative for AMS to continually monitor grade lines and the latest science being used 

with the instruments to maintain the relevance and applicability of these technologies. 

 
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In addition, the Agency should develop an aggressive outreach strategy to communicate potential 

changes to all sectors within the beef industry. We encourage USDA to attend industry meetings to share 

the AMS’ interest for input on any potential changes to the grade standards for beef. Industry meetings 

are a great opportunity for AMS to directly communicate with a variety of cattle producers and 

representatives from the packer, processor, food service and retail segments of the industry. We 

encourage USDA to also consider a series of webinars to ensure stakeholders have multiple opportunities 

to learn about USDA’s interest and provide feedback throughout the process. This will also provide an 

opportunity to discuss the timing of any potential changes and the expectations the Agency will have of 

the industry. 

 In closing, NCBA appreciates the opportunity to work with USDA as the Agency considers 

input on potential changes to the beef carcass grade standards. It is of the utmost importance for science 

to help determine any change that better represents today’s cattle industry. We respectfully ask AMS to 

conduct an extensive literature review on yield grades to clearly identify where knowledge gaps remain. 

As USDA funds future research, we encourage the USDA to allocate appropriate funds to answer some of 

the questions posed from industry. Any changes to the grade standards must be driven by sound-science 

and potential changes should be clearly communicated to all sectors of the beef industry. We look 

forward to working with USDA and as NCBA’s working group continues the discussions on potential 

modifications to the grade standards, we will be sure to communicate the information with AMS. Should 

you have any questions please contact Kristina Butts, NCBA’s executive director of legislative affairs at 

kbutts@beef.org. 

Sincerely, 

Bob McCan 

President 

(1) Platter W.J., Tatum, J.D., Belk, K.E., Koontz, S.R., and Chapman, P.L. 2005. Effects of marbling 

and shear force on consumer’s willingness to pay for beef strip loin steaks. J. Anim. Sci. 83:890-899. 

(2) Igo, J.L., VanOverbeke, D.L., Woerner, D.R., Tatum, J.D., Pendell, P.L., Vedrall, L.L., Mafi, G.G., 

Moore, M.C., McKeith, R.O., Gray, G.D., Griffin, D.B., Hale, D.S., Savell, J.W., and Belk, K.E. 2013. 

Phase I of the National Beef Quality Audit-2011: Quantifying willingness-to-pay, best-worst scaling, and 

current status of quality characteristics in different beef industry market sectors. J. Anim. Sci. 91:1907-

1919. 

(3) Acheson, R.J., Woerner, D.R. and Tatum, J.D. 2014. Effects of USDA carcass maturity on sensory 

attributes of beef produced by grain-finished steers and heifers classified as less than 30 months old using 

dentition. J. Anim. Sci. 92:1792-1799. 

(4) Tatum, J.D. 2001. White paper: Animal age, physiological maturity, and associated effects on beef 

tenderness. The Beef Checkoff. Accessed at: 

http://www.beefresearch.org/CMDocs/BeefResearch/PE_White_%20Papers/Animal_Age.pdf.