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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.org1 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 oppo rtunity 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 n ational trade association repre senting America’s cattle industry. Our membership’s top priority is to produce the safest, highest qua lity, affordable beef in the world. This has been consistent throughout our industry’s history to continuall y improve our knowledge and ability to produce beef to meet consumer pre ferences. Research on consume r preferences suggests a direct link between the eating quality of b eef and a consumer’s purchase be havior or willingness to pay 1,2 . Beef palatability plays a critical role to consumers and their deman d 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 d ollars since 1993 in research to better understand palatability and what characteristics drive c onsumer demand for beef products. NCBA’s membership remains very i nvolved with research to improv e 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 wher e relevant science leads the discussions around potential modifications to the standards. NCBA has crea ted an industry working group representing the cow/calf, feeder and packing sectors of the ca ttle industry. Members of the working group have reviewed research sp ecific to carcass maturity and v arious 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 industr y since the most recent grad e change in 1997. However, the discussions of potential modifications must be based on substantial scienti fic evidence to support any change to the

current standards.

NCBA appreciates the Agency’s recognition of recent beef check off research 3,4 on carcasses from fed steers and heifers less than 30 months of age classifi ed as ‘A’ maturity based on dentition rather than skeletal maturity. Curre ntly, a second phase of this res earch is underway to co mpare 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 contin ued 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 supp ortive of working with AMS to quickly implement the use of dentition to assess the maturity of beef c arcasses.2 Additionally, NCBA recognizes that USDA is responding to certa in industry segment questions related to how grade standards apply to grass-finished beef. C heckoff-funded market research shows that many consumers today do not n ecessarily understand USDA quality grades. A separate grading system for grass-fed beef likely would cause greater consumer confusio n 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 th at grain-finished beef does not have the same eating characteristics as grass-finished beef. Perhap s a marketing claim or certification program within the grass-finished beef supply would be a potential solu tion for USDA to consider to better differentiate these products. Any proposed changes should be g rounded in sound science and should take the entire palatability equation into consideration. For examp le, if a grass-fed product were certified

tender but did not deliver on fl avor and/or juiciness, the cons umer could have a negative eating experience that reflects poorly on all beef products. More res earch 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 app licable to the current cattle s upply. As stated in the Notice, carcasses today are heavier than the car cass weights utilized in the curr ent yield grade equation. Our membership has identified 1.) the correlation of hot carcass weight to rib eye area (ribeye bias) and 2.) the correlation of the ribeye area to total lean as topics where additional dat a needs to be considered by AMS. Does the Agency believe there is sufficien t research to define the corre lation of hot carcass weight to ribeye area? If so, we encourage USDA to share the relevant research to prov ide the industry with a better understanding of this relationship. If sufficient research doe s 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 publishe d research on beef carcass yield grades and identify if there are any data gaps that need to be further e xplored. As AMS reviews availabl e 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 wor king with USDA to review curre nt research and identify areas where more knowledge needs to be collected to allow science to sugges t possible modifications to the yield grade equation for beef carcass es. Additionally, NCBA’s member ship suggests for USDA to evaluate the yield grade equation as a method to identify the retail value o f beef products. The carcass’ cutability is measured by the yield grade and as relevant data is collected a ny 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 g rades are being applied consistently across all packing and processing establishments. Standardizat ion of yield and quality grades throughout the industry will have a direct i mpact on the consistency of ou r beef products with consumers. AMS should work with packers in the near future to identify the rea sons 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 i nstrument and human graders, t he 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 addre ss 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 gr ade lines and the latest science being used

with the instruments to mainta in the relevance and applicabilit y of these technologies.3 In addition, the Agenc y should develop an aggressive outreach s trategy 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 gra de standards for beef. Industry meetings are a great opportunity for AMS t o directly communicate with a variety of cattle producers and representatives from the packer , processor, food service and re tail 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 t he beef carcass grade standards. It is of the utmost importance for science to help determine any change that better represents today’s cat tle industry. We respectfully ask AMS to conduct an extensive literature review on yield grades to clear ly identify where knowledge gaps remain. As USDA funds future research, w e encourage the USDA to allocat e appropriate funds to answer some of the questions posed from industry. Any changes to the grade st andards must be driven by sound-science and potential changes should be clearly communicated to all sec tors of the beef industry. We look forward to working with USDA a nd as NCBA’s working group contin ues the discussions on potential modifications to the grade standa rds, we will be sure to commun icate the information with AMS. Should you have any questions please c ontact Kristina Butts, NCBA’s ex ecutive 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 Ch apman, 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., P endell, P.L., Vedrall, L.L., Mafi, G.G., Moore, M.C., McKeith, R.O., Gra y, G.D., Griffin, D.B., Hale, D. S., Savell, J.W., and Belk, K.E. 2013. Phase I of the National Beef Q uality Audit-2011: Quantifying wi llingness-to-pay, best-worst scaling, and current status of quality characteristics in different beef ind ustry market sectors. J. Anim. Sci. 91:1907-

1919. (3) Acheson, R.J., Woerner, D .R. and Tatum, J.D. 2014. Effect s of USDA carcass maturity on sensory attributes of beef produced by grain-finished steers and heifer s classified as less than 30 months old using

dentition. J. Anim. Sci. 92:1792-1799. (4) Tatum, J.D. 2001. White pap er: Animal age, physiological maturity, and associated effects on beef

tenderness. The Beef Checkoff. Accessed at: http://www.beefresearch.org/CMDo cs/BeefResearch/PE_White_%20Pap ers/Animal_Age.pdf.