May 1, 2023 

Via email 

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:

The North American Meat Institute (NAMI or the Meat Institute) submits 

these comments to the U.S. Department of Agriculture’s (USDA) Agricultural 

Marketing Service (AMS or agency) regarding the above-referenced procedures

(procedures). The Meat Institute has a rich, century-long history and provides 

essential member services including legislative, regulatory, scientific, international, 

and public affairs representation. Together, the Meat Institute’s members produce 

the vast majority of U.S. beef, pork, lamb, and poultry, in addition to the 

equipment, ingredients, and services needed to produce the safest and highest 

quality meat products in the world. 

The Meat Institute appreciates the opportunity to comment on the proposed 

revisions to the procedures. The industry values the instrument grading program, 

the service AMS provides, and supports the agency’s goal of rigorous instrument 

grading approval and installation procedures. However, there are significant 

implementation challenges and uncertainty associated with the proposed

procedures and therefore they need to be reevaluated and redrafted before 

implemented. Importantly, NAMI believes industry and AMS can find practical and 

achievable solutions that ensure stakeholders’ confidence is maintained or 

enhanced.
May 1, 2023

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The agency should reassess the composition and mission of the “Gold 

Standard Team.”

The Gold Standard Team (GST or team) is responsible for establishing the

official quality and yield grading factors. The procedures proposed by AMS to 

reduce the GST to three people may have unintended negative consequences. 

Rather than shrink the GST, AMS should consider alternatives, including other 

approaches or utilizing outside experts as members. The GST should not include 

supervisors and direct reports in the same group. Teams that contain supervisors 

and direct reports have an increased chance of bias. Additionally, when the GST 

excludes data because someone deviates more than 30 degrees from the mean 

marbling call, it makes the GST look artificially more consistent than the plant 

versus USDA camera, leading to bias. The agency should ensure practices are 

limiting bias potential. These approaches will ensure the GST’s legitimacy and 

remain robust in its expertise. 

NAMI supports activities that increase the transparency of the GST in its process 

and allow related stakeholders (i.e., producers and packers) to observe and engage 

with the team. Decisions by the GST have been inconsistent with the camera and 

field grade, which has caused issues in valuing beef and undermines trust in the 

USDA grading system. For two years during COVID-19, the team did not travel. 

When the GST started traveling, the grading factors called differed greatly from the 

camera and field grade. It seemed the team thought there were too many cattle 

with higher marbling scores and arbitrarily adjusted scores down to “balance” the 

proportion of cattle grading prime or choice. However, a higher proportion of cattle 

grading prime or choice is likely explained by improvements in cattle genetics and 

increased time on feed. The agency’s and GST’s mission should be to ensure 

consistency in grading across the industry and establishments grading, not 

manipulate the proportions of each grade to maintain the status quo. The 

proportions have shifted over time and should be expected to continue to do so 

based on numerous factors. 

The process for evaluating cattle for carcass grading needs to be 

consistent, robust, and reflective of today’s cattle herd. 

It is critical that the agency, producers, packers, and consumers have confidence 

in USDA’s grading program and the industry supports the steps the agency takes to 

protect the grade mark. However, current grading variations (e.g., grader versus

grader or grader versus camera) result in unbalanced grading results from 

establishment to establishment. This lack of consistency is adversely affecting

producer and packer relations as grade lines have unexpectedly shifted from what is 

expected from historical data. This inconsistency has caused tension among 

industry, producers, and AMS staff. The grading inconsistency also undermines the 

confidence retailers, food service entities, and consumers have regarding beef. 
May 1, 2023

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Shifting grade lines from the current camera or field grade results in skepticism by

all stakeholders. AMS should continue engaging with industry stakeholders to 

maintain and enhance confidence in the grading system, including efforts to level 

the grade field. 

QAD 516 needs to be reevaluated and redrafted with producer and packer 

participation. 

The drafted QAD 516 has several significant problems that will be cumbersome 

for beef packers. The data submission requirement, variance report, and software 

validation requirements are overly burdensome and need clarification. QAD 516 

needs to be collaboratively reevaluated and redrafted with input from key industry 

stakeholders, including cattle producers and beef packers. As proposed, many of the

requirements cannot be universally employed without significant disruption to the 

establishment. The Meat Institute is confident that AMS and industry will be 

aligned on what needs to be done once more clarity is provided. 

The monthly side by side testing is the most challenging aspect of QAD 516 and 

will cause significant disruption to establishments on an ongoing basis. AMS and 

industry need to further discuss the burdensome nature of the testing and the 

timeframe for results. The challenges and additional burden placed on 

establishments need to be addressed by the agency adopting revised procedures or 

an alternative approach. It is inappropriate for the agency to expect plants to take 

on additional burdens without a reduction in the hourly rate charged.

The industry would benefit from AMS explaining the goal of this data collection. 

The data collection procedures outlined in QAD 516 require additional tasks for

establishments previously done by graders and would likely result in extra staffing 

needs. The data collection procedures and requirements will likely require internal 

plant systems to undergo a considerable overhaul to accommodate the changes. 

There is a risk of inaccurate data collection at some establishments because online

graders do not consistently use the touchscreens to enter data. The data collection 

procedures also need to clarify these questions.

• How will verbal overrides be captured? 

• What will happen if there are errors in the data? 

• What is the expected format for the data?

The variance report requirements need more context and explanation. Similar

to the data collection requirements, industry would benefit from a greater 

understanding of AMS’ goal in asking for and evaluating this weekly report. It is 

unclear why this variance report is needed in addition to the validation and 

verification systems already in place. Industry is also unsure how this information 
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should be presented. For example, should industry provide a percentage or a head 

count? Will AMS provide a standardized form? 

To be implemented successfully, the software validation system also needs 

clarity. In the software validation portion of QAD 516, “known images” and 

“predictive values” are referenced but not defined. How are “known images” and 

“predictive values” determined and agreed upon? Also, the agency does not explain

the expected format (e.g., physical or electronic) for the “known images” and 

“predictive values.” Regardless of the format, there will need to be significant 

changes to establishment processes. 

Instrument approval and installation should be rigorous but not overly 

burdensome. 

USDA needs a more rigorous, science-based process for instrument approval and 

installation. For instance, the procedures suggest that “80% of the images shall 

derive from one side.” Because camera placement error can differ between sides, 

the agency should amend the procedure to be 60% or 65% from the same sides. The 

industry also needs clarification on how the agency is defining “within 20 marbling 

units.” Does it mean plus or minus ten from the estimate, a total or 20 degrees, or 

plus or minus 20 from the estimate a total of 40 degrees, 20 on each side of the 

estimate? The agency should also clarify the calculation and procedure for 

determining official marbling score. The procedures state that if “any one of the

independent observations exceeds a range of three (3) times the root mean square” 

the observation will be thrown out, and that the root mean square error will be 

calculated on all of the data. The agency needs to clarify that these terms are 

accurate and used as intended. There is concern that, if used improperly, it will be 

harder to remove estimates with larger errors, which is the opposite of what should 

happen. 

Additionally, the procedures reference comparing the “ribeye area observation” 

to the “actual ribeye area.” How does the agency define and measure the “actual 

ribeye area” and determine the correct standard to compare other observations and 

estimates to? If three people all grid the same ribeye, they rarely get the same 

exact area measurement, they are often within 0.5 to 0.75 in2 from each other. The 

agency should not hold the camera to unrealistic standards that are challenging or 

not consistently possible for the GST to meet. Additionally, the volume of slightly 

abundant and moderately abundant or higher carcasses should be reevaluated. The 

genetic potential and management practices of today’s cattle lead to higher grading 

beef and as a result AMS should require more slightly abundant and moderately 

abundant or higher carcasses in the instrument approval and installation 

procedures. 

* * * * *
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The Meat Institute appreciates the opportunity to provide these comments and 

respectfully requests the agency not finalize these procedures without significant 

revision. While the industry supports rigorous instrument grading approval and 

installation procedures, there are too many implementation challenges and 

uncertainty associated with the proposed procedures. The proposed changes will be 

significantly more burdensome on establishments that use camera grading rather 

than those that use traditional grading, effectively disincentivizing establishments 

from using the camera and increasing the need for the already short supply of 

graders. The Meat Institute and its members welcome the opportunity to work with 

the agency to redraft procedures that are both science-based and realistic for 

packers to implement, while maintaining trust in grading from all stakeholders.

These procedures should be revised with greater industry stakeholder 

collaboration. Please contact me if you would like to discuss any aspect of these 

comments. 

Respectfully submitted, 

KatieRose McCullough, PhD, MPH

Director of Science and Public Health

cc: Julie Anna Potts

Mark Dopp