KCA Comments on FSIS Country of Origin Labeling Docket Petition

KCA recently commented in support for change to the food safety and inspection services standards and labeling policy book on “Product of U.S.A.”

The balance of regulatory oversight and pressure to meet market demands is often viewed as a constant swinging pendulum in the beef industry. Anytime imports arrive into the United States, the inspection and labeling of those meat products is integral to ensure food safety standards and consumer health and interest. Food Safety Inspection Service (FSIS) is authorized by the Federal Meat Inspection Act (FMIA) with the regulatory oversight that imported meats be held to the same standards as production within the United States. The act seeks to ensure, not only, the safety and quality of the meat, but also, account for the accurate labeling of origin in order to provide the proper scope of awareness for consumers at the product point of sale.

The reciprocity regulation FSIS, FDA and FMIA have in place on meat inspection, application of medicine(s) on animals prior to slaughter, and the concise language and demands upon US exported meats to foreign countries trigger further consideration. The USA demands reciprocity of standards for imported meats when foreign countries place restrictions and bans on specific medicines, vaccines, and inspection of U.S. exported meats. The notable definition of using scientifically-based, measurable standards and random sampling is imperative and necessary to ensure sufficient inspection and labeling of meat imports. The drive and desire of consumers to know where their meat comes from exists for numerous reasons, including: health, safety, and quality. FSIS must ensure accurate labeling of origin and inspection standards. Furthermore, the inspection and labeling process should be constantly reviewed and held to stringent standards to solidify the integrity of the labels. Reports in recent years of corruption among foreign governments and meat import and export inspection officials raised red flags in the U.S. Proper oversight and science-based standards must be enforced if COOL is to be taken seriously by, not only, U.S. consumers, but international consumers as well.

While consumers and U.S. cattle producers seek to bring COOL to higher ground by demanding more structured standards and practices of labeling and inspection, FSIS, FDA and FMIA must in turn continue to bring forward an improved system of regulatory oversight with consistent measures of science-based import safety and transparency in Country of Origin Labeling. A prime example is foreign government corruption. The Brazilian meat inspection case revealed authorities failed to establish procedures to prevent conflict of interest between inspectors and meat plants. Sanitation requirements in plants were inadequate which led to product contamination as well as inadequate post-mortem inspection procedures. The audit further revealed failure to meet FSIS requirements to ensure only “wholesome carcasses, free of contamination and defects” receive the mark of inspection. Further audit revelations uncovered a trend of abnormal container violations at U.S. point of entry. The abnormal container violation is a clear failure of random sampling on imports and scientific testing conducted on the samplings. With these egregious violations of FSIS policy and regulation, ensuring science-based standards and health requirements are met by foreign import countries of origin is more important than ever. KCA supports the conclusion of the petitioners that the current FSIS policy which allows foreign imported meat and meat products to be brought into the U.S., processed through a USDA inspected plant and labeled “Product of USA” is counter to the legal authority granted to FSIS in federal law and by its own regulations. The current policy is having the very adverse outcomes on farmers and consumers that Congress specifically stated were the outcomes it intended to prevent when enacting the FMIA. Based on the law and the evidence set out above, we respectfully request FSIS change its policy on labeling “Product of USA” as it is set out in the FSIS Policy Book to that recommended in this petition.

KCA urges everyone to comment in support of the petition at https://www.regulations.gov/docket?D=FSIS-2018-0024.