March 31, 2022
For the past two years, the role of smaller-scale meat processors has received significant attention because of supply chain disruptions and challenges resulting from the COVID-19 pandemic. While small and mid-sized meat processors are critical to building resilient regional food systems, they face limited access to capital for expansion, a complex regulatory environment, and a highly consolidated livestock sector.
Even before the pandemic, policymakers and advocates were focused on the needs of these important food system stakeholders. A section was included in the 2018 Farm Bill requesting that a university or college conduct a study on the US Department of Agriculture’s (USDA) Food Safety and Inspection Service’s (FSIS) guidance, tools, outreach, and responsiveness to small processors’ needs. The study was completed by Oregon State University’s Niche Meat Processor Assistance Network (NMPAN), a program of OSU’s Center for Small Farms and Community Food Systems, an NSAC member, in December 2020.
Upon the release of the report, USDA’s FSIS wasted no time in addressing some of the recommendations listed in this report. In February 2022, they announced that their Hazard Analysis Critical Control Points (HACCP) Validation webpage has been updated to include validation studies that can be used to support HACCP plans for fermented products, salt-cured products, and dried products. This change was made in direct response to the study’s recommendation that FSIS make peer-reviewed studies, required to be included in a small plant’s HACCP plan, more accessible for small processors.
The National Sustainable Agriculture Coalition (NSAC) helped convene and co-facilitate the small processor roundtables that brought nationwide producer and processor perspectives together to inform the study. The issue of access to HACCP validation studies then rose to the top of small processors’ concerns. NSAC applauds FSIS for acting quickly to ensure small processors have access to some of these resources, which are often a costly regulatory requirement. NSAC also advocated for these resources to be publicly accessible to regulated processing establishments in the Strengthening Local Processing Act and looks forward to working with both FSIS and Congress to increase the number of validation studies that processors have access to, in order to reduce the regulatory cost for small processors.
The 2018 Farm Bill Small Plant study reported that small processor stakeholders found the inclusion of HACCP plan validation studies to be a costly requirement. Small processors must include these scientific research studies in their required HACCP plans, and subsequently, plans and spent a lot of time and money trying to gather the studies, which hopefully FSIS inspection personnel then approve. Processors have to pay for access to these studies, which can cost a significant amount of money.
The study recommended that FSIS could improve upon their information tools available for small processors by creating a searchable archive of peer reviewed validation studies for various products. It also recommended that FSIS work with universities and cooperative extension to assist small processors with the requirements to include this peer reviewed research in their regulatory plans. These resources would reduce the regulatory burden small processors face with HACCP plan validation studies.
FSIS recently added additional resources to their website in response to the small processor HACCP validation study access request. Now, small processors have access to a longer list of FSIS supported HACCP validation studies and, for the first time, links to all publicly available studies for certain products. FSIS also included a list of university and extension contacts that can provide HACCP and HACCP validation assistance to small processors, which can be found here.
FSIS announced that these website changes were in response to both the study recommendations, and the National Advisory Committee for Meat and Poultry Inspection (NACMPI) Subcommittee on Validation of ready-to-eat (RTE) shelf-stable multi-hurdle lethality treatments recommendations. NSAC appreciates FSIS’s efforts to incorporate stakeholder feedback on this important topic.
The regulatory requirements for HACCP plans require processors to control identified risks to ensure the meat or poultry product is safe for human consumption. Validation studies are a required part of HACCP plans to confirm all hazards are adequately identified and that the controls in place are scientifically proven to reduce the risk. When they were initially required in the late 1990s, HACCP plans had a costly impact on small processors. Small processors struggled to support these new regulatory costs in their business plans, leading some to go out of business.
The updated FSIS web page is an important step towards ensuring small processors have the resources they need to support their HACCP plans and that they can continue providing safe, local and regional meat and poultry products for farmers, ranchers, and consumers.
NSAC looks forward to working with FSIS to continue to expand upon these important HACCP plan resources. The updated list of publicly available validation studies can continue to be improved upon and expanded. Not every study has a publicly accessible link, and FSIS can continue to provide these links for products to further reduce this regulatory cost. FSIS can also work with stakeholders to ensure this resource is organized in a way that makes sense to small processors and add additional studies to the list based on stakeholder input.
NSAC also urges Congress to consider including Section 2 of the Strengthening Local Processing Act in the upcoming Farm Bill. This would provide FSIS with the resources they need to create a more comprehensive and fully accessible list of validation studies for small processors.