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AMS Pressured to Enforce COOL Law Now

OIG audit shows need for improved rule enforcment.
Compiled by staff 
Published: Sep 12, 2011

USDA’s Office of the Inspector General wondered whatever happened to COOL and found out in an audit, the Agricultural Marketing Service has been slow to enforce the rule at the retail level since the final rule went into effect in March 2009.

The main findings of the OIG were:

  • Finding 1: AMS Needs to Improve the Retailer Selection Process
  • Finding 2: AMS Needs to Strengthen Retailer Review Procedures
  • Finding 3: AMS Needs to Improve the Timeliness of Its Evaluation of

                Retailer Review Documentation

  • Finding 4: AMS Needs to Improve Enforcement of COOL Regulations
  • Finding 5: AMS Needs to Improve Its Oversight of State Agencies
  • Finding 6: AMS Needs to Improve Communication with Retailers

The most significant statements of the OIG report can be found HERE.

Items covered by COOL Law, that needs traceback to the source, individual animal or repacked produce:

  • Muscle cuts of beef, veal, lamb, goat, chicken and pork;
  • ground meats including beef, lamb, chicken, goat, and pork.
  • Wild and farm-raised fish and shellfish.
  • Fresh and frozen fruits and vegetables of all kinds, including cherries in brine. www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5082566
  • Peanuts, Pecans, Macadamia Nuts
  • Ginseng

USDA-AMS has cooperative agreements with all 50 states to conduct reviews of PACA-licensed retailers to ensure they adhere to COOL regulations, including recordkeeping.

Retailer reviews include review the labels on all covered commodities to determine compliance with COOL labeling regulations, and review the records that support the country-of-origin and method of production labels for five covered commodities.

AMS also conducts tracebacks of covered commodities to ensure establishments that supply covered commodities to retailers meet COOL recordkeeping requirements. In addition, these tracebacks verify the accuracy of the method of production and country of origin labeling information.

AMS defined violations in policy document as either:

(1) failing to label a product;
(2) mislabeling a product;
(3) failing to maintain records.



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