*Producers mCOOLv represents the Producers Livestock Marketing Association (PLMA) approach to mandatory Country of Origin Labeling verification. Included in this web site are links to USDA and Federal Register information relating to mCOOL (government links are above).
On September 5, 2008 USDA deemed sufficient and accepted proposed affidavit language made by a consortium of 70 industry representatives. USDA accepted “continuous,” “single use” and “composite” affidavits, provided the language accepted is used and origin is traceable during an audit. This approval followed an industry and USDA meeting in Kansas City held August 26, 2008, sponsored by the National Meat Association (NMA), Livestock Marketing Association (LMA) and National Livestock Producers Association (NLPA). PLMA is a member of NLPA and was represented at the initial KC meeting and subsequent DC meeting. View the actual language approved by USDA here.
As an affidavit is deemed by USDA as an official record of Country of Origin, Producers Livestock Marketing Association (PLMA) attests through first-hand knowledge, normal business records, or producer affidavit(s) that all livestock referenced by PLMA affidavits or other communications specific to livestock transactions and transfers are of the origin listed in our affidavits to buyers.
PLMA has, and will maintain records of livestock origin for one year from the date of delivery of the livestock to the packer/buyer. We attest that these records reflecting specific transactions are available for inspection for the sole purpose of compliance with an audit as described by the country-of-origin labeling provisions contained in the Farm Security and Rural Investment Act of 2002 as amended. (P.L. 108-767, USCA section 1638a, 2003).
IMPORTANT PLMA NOTICES:
PLMA patrons must fill out an affidavit stating the country of origin of their hogs and where they are fed. This form must be signed by the producer, partner or company officer one time and is a “continuous” or “evergreen” affidavit. The document is available by clicking here. It will constitute a Continuing Representation or “evergreen affidavit” and the producer is responsible for informing PLMA of any change in origin of their pigs, and must confirm with PLMA the origin of each load or lot of pigs on every sale.
The original signed affidavit must be mailed, faxed or emailed to PLMA’s Sioux City, Iowa office (retain a copy for your file):
Producers Livestock, 4280 Sergeant Road/Suite 240, Sioux City, Iowa 51106-4634 -OR- Fax: 712-274-0741 or E-mail: email@example.com.
Livestock producers are not directly regulated by the COOL interim final rule as livestock are not considered covered commodities. However, documentation that verifies origin must be kept on file for one year. Records that may be used to assist in a verification audit include birth records, receiving records, purchase records, animal health papers, sales receipts, animal inventory documents, feeding records, APHIS VS forms, segregation plans, State Brand requirements, breeding stock information, Beef Quality Program papers, and other similar documents associated with the animals in the unique transaction. In addition, participation in USDA quality system verification programs that contain a source verification component could also be used to substantiate COOL claims. These examples are not inclusive of all documents and records that may be useful to verify compliance with COOL, but they should provide a strong basis to substantiate a claim during a supply chain audit.
PLMA will provide packers and buyers of hogs with composite affidavits (as approved by USDA) stating the origin on sales of hogs and will notate the country of origin by individual lot/patron number. PLMA will retain on file for one year producer affidavits to support a USDA audit trail for mCOOL verification for each group. Packers buying hogs from PLMA will need to retain the e-mails, fax sheets or hand written documents constituting PLMA’s affidavit which list patron ID’s and origin per lot of hogs, in the event of a USDA audit pertaining to origin.
The affidavits used by PLMA and those provided to buyers by PLMA, constitute “First Hand Knowledge” and are sufficient proof of origin, deemed so by USDA in KC August 26 and subsequently in DC on September 5. View a sample of the “composite affidavit” document by clicking here.