COOL – Good, Bad, Indifferent?

On September 30, 2004 the U.S. Department of Agriculture (USDA) issued an interim final rule for the mandatory Country of Origin Labeling (COOL) program for fish and shellfish as required by the 2002 Farm Bill. On November 10, 2005, President Bush signed Public Law 109-97, which delayed the implementation for all covered commodities except wild and farm-raised and shellfish until September 30, 2008.

Under the interim final rule, fish and shellfish covered commodities must be labeled at retail to indicate their country of origin and method of production (wild and/or farm raised). However, covered commodities are excluded from mandatory COOL if they are an ingredient in a processed food item.

Food service establishments, such as restaurants, lunchrooms, cafeterias, food stands, bars, lounges and similar enterprises are exempt from the mandatory COOL requirements.

Fast forward to August 2008, the USDA Agricultural Marketing Service (AMS) issued an interim final rule for mandatory Country of Origin Labeling of beef, pork, lamb, chicken, goat meat, perishable agricultural commodities, peanuts, pecans, ginseng, and macadamia nuts. The 2008 Farm Bill added chicken and goat; pecans, ginseng and macadamia nuts as covered commodities to what had been previously proposed. This interim final rule (IFR) will go into effect September 30, 2008.

First, let me say that I am flabbergasted that the twice delayed IFR implementation of the remaining COOL items actually came into being. Traceability is a major concern and I believe, one way of helping to manage food security and food safety issues. Call it a good first step. The real problems with COOL are that it doesn’t seem to be working and it doesn’t go far enough .

According to AMS records regarding its 2007 audits of retail stores,

  • 1,657 retail stores out of 1,662 assigned were audited in 2007 (99.7%).
  • 540 (32.6%) audits showed violations of Country of Origin Labeling requirements.
  • Within the 540 audits where violations occurred, there were 1,101 violations cited. This is an average of 2 violations per audit conducted.

32% is a great hitting percentage in baseball but “kind of sucks” for a program that concerns our safety, health and financial well being.

Now, I’m not a proponent of more government regulation but just knowing where commodities come from isn’t enough. Apparently, I;m not the only one. A survey, conducted by the Consumer Reports National Research Center, polled a nationally representative sample of 1,004 people on issues concerning food safety and labeling. Consumers indicated that they expect more from labels than the current standards.

I believe that we are not going to get more detailed information unless we ASK! Opponents of COOL legislation and implementation have long argued that COOL is far too expensive and unnecessary. But as a letter to congress from Americans for Country of Origin Labeling stated:

Recent cases of foodborne illness from imported food and the discovery of a case of mad cow disease in Washington State that was traced back to Canada only reinforce the need for consumers to be able to accurately identify the source of their food.

Per usual, it’s going to be up to us.

For example, the seafood and shellfish regulations don’t tell us:

  • If a product was farmed, was it raised with an appropriate vegetarian diet and according to environmentally sound methods?
  • If wild, where was it caught?
  • How was it caught?
  • Should it be caught, or protected because the species is threatened?
  • Does it have a high bycatch percentage that adversely impacts other marine animals?

Just imagine if we had true traceability. To quote a song by Bob Thiele (using the pseudonym George Douglas) and George David Weiss, “What a wonderful world it would be be.”

More on eco-labeling from the GO network:
Changing The Landscape Of Eco Labeling – Who Consumers Trust
“Natural” Means Nothing – FDA Declines to Define “Natural”
The Six Sins of Greenwash… and How to Repent
What is Sustainable Cuisine? – Part One
What is Sustainable Cuisine? – Part Two

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