From: Jerry Wulf 

To: Horne, Willy - MRP-AMS 

Subject: [External Email]Comments on Instrument Grading and proposed changes 

Date: Saturday, April 29, 2023 10:22:41 AM 

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Dear Willie Horne and the USDA,

 We have a long history of beef cattle production now spanning over 3 generations in our 

family. We have fed and marketed cattle for over 3/4's of a century and have participated in 

the evolution of fed cattle marketing for a long time. We have always believed in being 

eraly adopters of new and better ways to market fed cattle. Since the late 1980's and early 

1990's we have sold our cattle on grids, taking the risk and reaping the rewards, of how our 

cattle have quality and yield graded.

 We are thankful that there is a grading system in place to identify quality, hopefully 

expressed in a better eating experience that benefits our ultimate customer, the consumer. And 

also can send that message back to the cattle producer to strive for continued improvement. 

Likewise as we sell carcass weight, we appreciate a yield grade system that can predict red 

meat yield, very important to all participants in the beef supply-chain. 

Given all that is at stake here for all participants, (including consumers) we have a very 

high level of interest in seeing that USDA grading is consistent and accurate. 

We were selling cattle on grids long before the assistance of instrument grading. What we 

have witnessed after instruments were incorporated, is much more consistency in grading from 

plant to plant and from lot to lot of cattle, regardless of where they were harvested. We are 

convinced that with instrument assistance grading has gotten much better. 

I have read the literature links on the website regarding grading and proposed changes. 

Observations I made in the comparison test done. Back in 2015 the grader and the instrument 

didn't agree 1% of the time. In the recent study, that number has jumped to 5%. I would have 

expected it to get better, not worse. Also , in the recent study, with the 5% discrepancy, 90% 

were downgraded and only 10% were upgraded.

 Regarding the proposed changes, specifically, 5.3.1.1 (pertaining to marbling) . With all due 

respect to the USDA Gold Standard team, our suggestion would be to incorporate some 3rd 

party, potentially meat science academy as part of the team to be involved in instrument 

approval.

 Another point mentioned in the literature is the discrepancy between the USDA grader and 

the instrument around larger flecks of marbling, that the instrument accounts for and the 

grader does not. Our question is, what equates to a better or lesser eating experience ? I see 

nothing in the literature about doing eating quality studies relative to grading discrepancies. Is 

there any way we can incorporate actual eating quality studies as part of the instrument 

approval process ? At the end of the day I believe a quality eating experience is what Quality 

grade was designed for, and is still responsible for today. 

Lastly, we would just like to reiterate that with the incorporation of instrument grading we 

saw vast improvements in the consistency of beef carcass grading from region to region, plant 

to plant, and year to year. We can only believe that instrument technology has gotten better, 

and will continue to improve. Hence we strongly encourage the USDA to more utilization of 

instrument grading with high level oversight by USDA ! 

Thanks for the opportunity to comment! 

Kind Regards, 
 

-- 

Jerry Wulf 

Jerry Wulf 

Wulf Cattle 

Morris, MN 56267 

www.wulfcattle.com 

320.392.5802 - Office 

320.491.1390 - Cell