I inquired today about the status of COOL reviews and audits with Billy Cox of the USDA AMS. Here is what Billy sent me today::

Country of Origin Labeling
Supply Chain Audit Overview
October 29, 2009

•    On January 15, 2009, the Department of Agriculture (USDA) published the COOL final rule, which became effective on March 16, 2009, for all covered commodities.

•    Approximately 12,000 in-store retail reviews and 400 audits of the retail supply chain are planned for the June 2009-May 2010 timeframe.

•    The supply chain audits will be performed by USDA personnel.

•    As of October 29, 2009, 26 supplier audits have been completed.  Ten are currently in progress.

The commodities with completed audits include: (if more than one of the commodity is audited, total number is in (x))

Fruits and Vegetables
Frozen Blueberries
Carrot Chips

Fish and Shellfish
Halibut (3)
Salmon (2)
Frozen Shrimp
Perch Fillets

NY Strip Steak
Boneless Beef Tenderloin
Ground Beef
Beef Rib Eye Steak, Lip On

Pork Roast, Boston Butt
Pork Tenderloin

Chicken drumsticks (3)
Chicken breast (2)
Chicken Thighs

Shelled Pecans
Pecan Halves

10 Supplier Audits are In-Progress as of 10/29/09:

Red Grapefruit
Rainier Cherries
Brussel Sprouts
Red Yukon Potatoes


Ground beef (2)

Pork Shoulder Butt

Chicken leg quarters


4 out of 26 completed audits identified the following findings:
•    Did not provide Method of Production
•    Failure to submit records within 5 business days
•    Incorrect origin information provided to retailer

TK: Check out this USDA pdf on Supplier Traceback Audit Training

It is obvious that USDA has a substantial enforcement effort planned for the next year, but there has been little buzz about this issue among suppliers or retailers so far. Any readers who have experience with these supplier audits or in-store reviews are encouraged to share with the rest us!