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April 27, 2023

Dr. Willy Horne

AMS Livestock and Poultry Program

1400 Independence Avenue, S.W.

Washington, DC 20250

Willy.horne@usda.gov

RE: United States Department of Agriculture, Agricultural Marketing Service Proposes Revisions to 

the Procedures related to Red Meat Instrument Grading – January 4, 2023.

Dr. Horne:

Cargill Beef has used camera augmented grading with USDA since September 2, 2009. Camera 

technology has significantly improved the accuracy and consistency of grade application and 

certification of brands with numerous criteria. This is readily apparent between plants, between shifts, 

within shifts and across graders daily. Camera augmented grading systems have enhanced the 

feedback and consistency of information back to beef producers. Producers are now more confident in 

camera augmented data to make genetic and managerial production changes.

The proposed requirements for new technology approvals by USDA are harder to meet than the original 

requirements, especially for ribeye area. Is this necessary when compared to subjective evaluation - -

3 to 5 graders gridding ribeyes, measuring backfat, calling yield grade and marbling would not likely 

pass these proposed requirements?

Some of the proposed requirements are new and an addition to current USDA checks and balances for 

camera grading plants. Providing images and camera data for random monthly USDA checks is more 

onerous and disrupting to daily operations. Currently, USDA personnel are present in plants overseeing 

camera calibration at the start of each shift every day of operation. Will any of the existing checks (i.e., 

4 marbling cards run at the start of each shift) be replaced with these newly proposed requirements?

The newly proposed QAD 516 – Continual Monitoring Procedures – needs to be reevaluated, refined,

and simplified before implementation. Why do packers pay for 2 to 3 graders per shift if we have to 

provide this camera and grading information back to USDA daily, weekly, monthly, and annually? 

Today, packers pay for the cameras, the computers to run the cameras, the touch screens to display 

camera results, the USDA grader’s touch screen, an hourly employee to operate and place the camera, 

and another hourly employee to apply USDA grading and certification stamps. QAD 516 as proposed 

will take significantly more time, technical personnel and come at a substantial, additional cost to meet 

these requirements. QAD 516 reads like a research proposal; collect a bunch of data daily, weekly, 

monthly, and annually, eventually assess and then narrow down to only essential data, say quarterly. 

These proposed rule changes discourage the use of science-based technologies and encourage 

packers to revert to historical subjective grading and certification. Hence, QAD 516 needs to be tabled 

and further research is warranted before implementation of a more refined approach. 

It is concerning that we have used the same marbling algorithm for 14 years and now USDA grading 

supervision wants to adjust it downward and tighten the camera grading lines. The beef industry has 
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changed dramatically over these 14 years through improved genetics, longer time on finishing diets, 

more all natural cattle, heavier carcass weights and fatter carcasses. These industry changes are 

responsible for the increases in U.S. Prime, Premium Brands and U.S. Choice - - not a change in the 

camera grading technology. Moreover, these industry changes have propelled beef demand to another 

level over the last decade.

Using the gold standard committee marbling average of 3 to 5 supervisory graders has never worked 

to set a baseline for camera marbling. Camera grade recommendations need to mirror USDA line grader 

calls to provide a seamless transition from subjectively applied grading to camera augmented grading. 

This seamless transition for grading has been in place since the onset of camera augmented grading 

except for a two-week period in 2017 when USDA AMS adjusted camera marbling down and industry 

grading decreased approximately 10 percent disrupting supply and demand. Subsequently, USDA AMS 

changed camera marbling back to match the grade consist applied by USDA line graders.

We need to use more science and less subjectivity in setting grade lines and comparing technologies. 

USDA AMS should collect ether-extracted fat as a more science-based measure for marbling and 

setting a camera grading line. Dow et al., 2011 and Emerson et. al., 2013 reported high correlations 

between camera marbling and chemical fat. Chemical fat could also be used for line grader and gold 

standard committee comparisons. Furthermore, Vierck, 2017 reported marbling texture had minimal 

impact on eating quality; hence, coarse marbling should not be excluded from premium brands.

https://doi.org/10.2527/jas.2010-3382 https://doi.org/10.2527/jas.2012-5514

https://krex.k-state.edu/handle/2097/35777

These proposed rule changes for camera augmented grading and certification make it more onerous 

for camera grading and certification plants than for plants that still use historical subjective USDA 

grading and certification (i.e., non-camera plants). USDA should consider the following potential 

improvements to modernize the camera grading and certification process:

1. USDA has not changed the rules for regrading since the inception of camera augmented grading 

(2009). A grader’s call for marbling on-line must exceed the camera by 20 degrees or more to 

achieve the higher quality grade; on a regrade rail the rule is 40 degrees above the camera 

marbling to grade the higher quality grade. In USDA subjectively graded (non-camera 

augmented) plants, Small00 and Slightly Abundant00 qualify for U.S. Choice and U.S. Prime, 

respectively; there are no 20- or 40-degree rules for plants that choose to grade subjectively. 

When Cargill initially started camera augmented grading with USDA we were only holding 100

carcasses per week for regrade consideration. Currently, we are back to holding over 1,000 

carcasses per week in many plants for regrading, like when we were subjectively grading with 

USDA.

2. Seven laser camera heads should be approved to provide instant feedback on camera 

placement opportunities to camera operators. In testing, we normally see more variation in 

camera variables like marbling due to variation in operator placement of the camera than among 

cameras. We are operating the 7-Laser camera software in Canada and our operator warnings 

plus errors have gone from over 5.0% to 1.5% in a few short weeks.

3. One of the requirements to meet USDA’s QAD 515 rules is for the meat packing plants to ensure 

the camera lens is in focus. This is difficult to do visually. E+V has developed a sharpness card 

to check a camera lens for various defects (out of focus, miss-aligned, dirty, etc.). USDA should 
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approve this card as soon as possible as a best practice, even for GigE versions of E+V 

cameras.

4. One of the rules in QAD 515 allows for graders to disqualify a camera if they override and 

downgrade 10 percent or more carcasses during their turn online. This creates downtime in 

plants, disrupts productivity and may not be an issue with a camera. Workmanship opportunities 

like stray fat particles on the ribeye surface, poor ribbing, or camera placement issues are not 

appropriate reasons to disqualify a camera and take it down from operation. We recommend 

that the decision to disqualify a camera should be made by an experienced grader or supervisor 

(GS-9 or higher). New graders with limited experience should downgrade carcasses they feel 

do not meet the requirements, contact their supervisor, packers can hold the regrades and then 

hopefully with supervision’s involvement, we reach the correct decision regarding whether a 

camera is operating properly.

5. The rules for Instrument Enhanced Grading and Oversight should be revised to simplify, mirror 

current industry practices, and reduce subjectivity in USDA auditing. USDA Process Verified 

Procedures for beef grading and certification will be key in the future for USDA and the Beef 

Industry.

The quality of beef is at an all-time high in the U.S. due to improvements in the industry mentioned 

earlier and the backlog of cattle since March of 2020 due to COVID. Premiums for quality beef and 

branded beef programs have been record high as well. Customers and consumers are not complaining 

about insufficient marbling or the quality of beef. A majority of producers are marketing their cattle on 

carcass merit grids; hence, USDA grading decisions impact their bottom lines and their long-term

breeding and management decisions. USDA should maintain a “seamless transition” approach when 

approving and implementing any new technology for grading and certification purposes.

USDA beef grading and certification is a voluntary service paid for by the meat packing industry. USDA 

and industry should continue to work together to develop, approve and apply meaningful technology to 

improve the accuracy and consistency of grading and certification without disrupting markets.

Respectfully,

H. Glen Dolezal, Jr., Ph.D.

AVP, New Technology Applications