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Follow on Google News | USDA-AMS brings COOL law to full tracebackThe Country of Origin Labeling law COOL effective on March 2009, and is enforced now. COOL covers: all meats from livestock, all fresh and frozen fruit and produce, chicken, fish, shellfish, ginseng, pecan, macadamia nuts, peanuts requires records.
By: ScoringAg.com The Country of Origin Labeling law (COOL) became effective on March 2009, and is being enforced now. All COOL covered commodities includes: all meats from livestock, all fresh and frozen fruit and produce, chicken, fish, shellfish, ginseng, pecan and macadamia nuts along with peanuts requires a means of traceability records for the USDA-AMS COOL Law. Retailers have to provide to consumers the Country of Origin, by a label on the package/placard or be fined $1000.00 per item (e.g. a box of tomatoes). Retailers can not afford to purchase products which are not in compliance with the COOL law. They will need the required records for the AMS audits to prove the accuracy of the labels and traceback throughout the supply chain to the producer/grower, distribution center or a packer-shipper. A link to the audit report of the USDA Office of Inspector General can be found on our website ScoringAg. You’ll find on page 16 the OIG Recommendation 7: “Develop and implement procedures to test additional commodities if errors are identified during record reviews and evaluate retailers’ recordkeeping systems.” as well as the Agency Response: “AMS officials stated that they have implemented procedures to assess the effectiveness of a retailer's recordkeeping system. In the event that a retailer meets the criteria for a followup review and had a recordkeeping finding in the initial review, additional records (a total of 8) will be reviewed during the followup review to verify the retailer is conveying accurate country of origin information and retaining complete records for 1 year. In a supplemental e-mail response dated June 29, 2011, AMS officials addressed an OIG concern about testing additional records during the initial review. They proposed that in the event that records are made available during the initial retail surveillance review and noncompliances are noted, an additional eight records for covered commodities will be requested and evaluated during the initial review. AMS plans to implement the revised recordkeeping evaluation procedures by August 2011.” Retailer reviews include two sections to verify COOL compliance for the approximately 300 covered commodities that retailers might carry. The easiest way to survive an audit of grown, raised, processed in the USA or another Country is to have records with automatically generated SSI-EID traceback codes starting at the production level. This code can be searched in ScoringAg’s database by wholesalers and retailers for origin proof in seconds. The ScoringAg traceback label, human and machine readable, will show the origin of the product. Good news for all producers, retailers, and consumers ScoringAg has the only system for complete Site-Specific Recordkeeping® The incoming ScoringAg barcodes carries all COOL required information and can be read into ScoringAg’s database with any 2-D barcode reader in just seconds and stored as long as needed. The searchable traceback codes comply with the FSMA and 2002 Bio Terrorism law as well. GTIN numbers only carry a brand name and the product code for some cash registers and have no information required by any law. Officials of both AMS and the Office of the General Counsel stated that, under the Act, all retail branches of a PACA-licensed corporation, regardless of whether the branches individually meet PACA licensing requirements, are required to adhere to COOL and they agreed to begin monitoring such retailers for compliance with COOL. AMS will make additional efforts to ensure that all retailers comply with COOL or be fined $1000 per violation. Retail PACA members have just learned of the immediate enforcement of the COOL law. The Act allows the Secretary to conduct an audit of any person who grows, raises, prepares, stores, handles, trucks or distributes a covered commodity for retail sale to verify compliance with Subtitle D of the Act. Subtitle D of the Act refers to COOL requirements, which includes defining a retailer based on PACA requirements. PACA defines a retailer as any “person” who is a “dealer” in the business of selling any perishable agricultural commodity at retail. PACA-licensed Retailers are stores that sell more than 2,000 pounds of perishable agricultural commodities in any given day, and also have annual invoice costs of perishable agricultural commodities totaling at least $230,000. The final rule requires retailers to label covered commodities with the Country of Origin(s) at the final point of sale and to maintain records supporting the origin reflected on the label for 1 year. All producers, handlers, processors, wholesalers, and other non-retail establishments will be affected by COOL as required traceback of commodities to ensure suppliers comply with COOL recordkeeping regulations and verification of the accuracy of method of production and that Country of Origin labeling information is accurate. AMS’s Meat, Grading, and Certification Branch officials will then contact the supplier of that product and all previous suppliers until the originating source of the product is identified. COOL regulations require suppliers to maintain records supporting COOL for one year. This means, that a ScoringAg SSI-EID code from the database system which is on the commodity label from the producer will be transferred to another coded SSI-EID label, through the entire food chain, to the retailer. COOL requires the producer to start maintaining records, immediately! ScoringAg has the low cost technology to implement the COOL law at every PACA operation site. Contact: William Kanitz President Site-Specific Recordkeeping® Point-to-Point Traceback™ www.ScoringAg.com + 941-792-6405 End
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