May 1, 2023 

Willy Horne, Ph.D.

Livestock and Poultry Program

Agricultural Marketing Service

U.S. Department of Agriculture

1400 Independence Ave SW

Washington, DC 20250

RE: NCBA Feedback Regarding Procedures Related to the Use of Instrument Technology in the 

Official Meat Grading Program

Submitted via email: willy.horne@usda.gov

Dear Dr. Horne: 

The National Cattlemen’s Beef Association (NCBA) appreciates the opportunity to submit feedback

regarding the Agricultural Marketing Service’s (“the Service”) proposed revisions to the procedures related 

to the use of instrument technology in the official meat grading program (collectively, the “Proposed 

Revisions”). NCBA is the oldest and largest national trade association representing the interests of the U.S. 

cattle industry, with over 25,000 direct members and approximately 178,000 represented through our 44 

state affiliate organizations. 

Statement of Concurrence

Certified Angus Beef (CAB) is a member and valued partner of NCBA. As the first U.S. Department of 

Agriculture (USDA) certified beef program, which relies heavily on beef Quality Grades, their team 

possesses an intricate and highly sophisticated knowledge of the minutia pertaining to beef carcass 

grading. NCBA wishes to associate ourselves with the feedback submitted by CAB pertaining to the 

Proposed Revisions and has committed to work closely with them on general beef carcass grading issues 

moving forward. 

Background

The USDA Quality Grades of Prime, Choice, and Select have a long history in the beef business and 

indicate quality of beef products. Their use and prominence have made the grade an inherent and critical 

component of marketing U.S. beef, both domestically and abroad. In fact, according to information reported 

in the Service’s Cattle Contracts Library pilot program, Quality Grade plays at least some role in 

determining the final net price for fed cattle in almost 90% of formula transactions. NCBA’s members, 

through our organization’s century-old, grassroots policymaking process, have repeatedly and 

enthusiastically stated their support for the Service’s beef carcass grading program, and have periodically 

provided recommendations for improvements over the years. 

NCBA was an early supporter of instrument grading tools when they were first introduced several years 

ago. Because of the high value associated with the different Quality Grades, we continue to support the use 
National Cattlemen’s Beef Association Agricultural Marketing Service

Page 2 Proposed Revisions: Instrument Grading Procedures

of instrument technology to reduce subjectivity in the federal grading process. While well-trained, 

experienced human graders are an essential component of the process, cameras and related technology 

have helped increase consistency in grading calls from plant to plant and region to region. As such, NCBA 

supports their continued use, provided the underlying software and usage protocols continue to produce 

results which are consistent with the latest scientific and industry standards.

Marbling Scores

Paramount to the integrity of the Service’s grading program is consistency and alignment between the Gold 

Standard Committee (GSC) metrics—against which current instruments are calibrated—and the subjective 

calls of field graders who have the authority to override a camera call. While the GSC remains an important 

calibration tool for grading instruments, the standards they posit are still based on a subjective, albeit 

sophisticated, interpretation of the specific carcass presented for analysis. As science has evolved, along 

with the industry’s understanding of intramuscular fat behavior, more objective means of grading have been 

suggested by subject matter experts and the academic community. The Service should carefully consider, 

in the interest of improved consistency, whether these quantitative measures can be adopted for ease of 

replication across USDA-approved instruments.

Increased Need for Instrument Grading Access

Other mission areas within USDA have allocated substantial resources to strategically increase meat and 

poultry processing capacity. Many of the facilities involved in these federal programs are very small, or 

small processors in various stages of construction or expansion. Several of these facilities have expressed 

an interest in accessing the Service’s beef carcass grading program. 

The grading instruments currently approved by the Service are incredibly expensive. NCBA is aware of 

many smaller, regional beef packing facilities that would implement a USDA Quality Grade program were 

the necessary technology less cost prohibitive. As such technology becomes available, the Service should 

ensure that these smaller facilities can fairly access grading services without compromising the integrity of 

the program. To the previous point regarding marbling scores, alignment with more objective means of 

grade determination is a crucial component in balancing the scales between access to grading and 

preservation of the reputation the Quality Grades enjoy with consumers. Consistency is key. 

Opportunities for Public-Private Collaboration 

NCBA and CAB are currently developing a loosely structured task force, representing various segments of 

the beef supply chain, to meet on a regular basis to discuss our continued support and potential 

suggestions for improvement regarding the federal beef carcass grading program. The mission of this 

group is to keep the industry apprised of the latest discussions pertaining to the federal beef carcass 

grading program and to maintain a resource for the Service should they seek industry input on a particular 

related topic. We would welcome USDA’s involvement through these open and transparent dialogues as 

we seek to uphold the integrity of the Quality Grades consumers across the globe have come to trust and 

appreciate. 
National Cattlemen’s Beef Association Agricultural Marketing Service

Page 3 Proposed Revisions: Instrument Grading Procedures

Conclusion

Thank you for allowing us to submit feedback on behalf of our members—America’s beef producers. 

Please do not hesitate to contact NCBA’s Center for Public Policy with any questions or concerns you may 

have. 

Respectfully Submitted,

Tanner J. Beymer

Senior Director, Government Affairs

National Cattlemen’s Beef Association