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concerning the provisions and requirements of this rule during<br />

the six month period following the effective date of the<br />

regulation, as was provided for in the 2008 interim rule and the<br />

2009 final rule. AMS has determined that this allocation of<br />

enforcement resources will ensure that the industry effectively<br />

and rationally implements this final rule. With regard to costs<br />

related to the elimination of commingling flexibility, the<br />

Agency has responded to these issues in a subsequent response<br />

below.<br />

Processors’ Cost of Segregation<br />

Summary of Comments: Numerous commenters provided<br />

statements on the costs of segregating livestock they believe<br />

will be necessitated by the proposed rule. These commenters<br />

explained how, in their opinion, the labeling changes will<br />

require additional livestock and meat segregation and record<br />

keeping that will increase costs to the industry that must be<br />

absorbed by livestock producers, feedlots, shippers, meat<br />

packers, processors, retailers and consumers.<br />

One commenter stated that the segregation of cattle and<br />

beef carcasses within the packing plant requires unique<br />

operational procedures. The commenter further contended that<br />

current packing plants were neither designed for nor constructed<br />

in a manner to allow for efficiency in the segregation of cattle<br />

and beef.<br />

32

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