April 21, 2022
Editor’s Note: This is a guest blog post written by Michael Graugnard, a second-year law student at the University of Arkansas School of Law and a Research and Writing Assistant for the Food and Agriculture Impact Project.
One positive thing to come out of the public health and economic challenges of the last two years is the increased attention that all levels of government are paying to strengthening local and regional food systems. As supply chain bottlenecks and shortages prove, any solution to food system concerns must involve our small-scale processors. To lend their support to these efforts, and in response to a Congressional mandate from the 2018 Farm Bill, the Niche Meat Processors Assistance Network (NMPAN), in cooperation with the National Sustainable Agriculture Coalition (NSAC), released a report to the Food Safety and Inspection Service (FSIS) in December of 2020. The report found that Small and Very Small (SVS) meat processors are underrepresented in the regulatory and policy making process and experience a disproportionately higher number of regulatory sanctions than large processors. In response, the report outlined several recommendations aimed at improving the food safety and inspection system for SVS processors.
Since the release of this report, FSIS has made considerable changes to service resources and programming. However, several areas highlighted by NSAC and NMPAN remain either unaddressed or partially addressed. FSIS has made significant improvements, for example, in producing and revising model HACCPs and enhancing website resources. At the same time, other areas of FSIS policy, such as SVS guidance on compliance with Salmonella and Campylobacter performance protocols, have not been addressed as clearly.
The 2020 report’s recommendations centered around three general areas in which FSIS could improve practices across the entire spectrum of service functions:
The study also focused on increasing the inclusion of SVS processor voices in the policy making process. Some of the recommendations include:
The report also included a humane handling study which found that the overwhelming majority of suspensions relating to humane handling violations occur at SVS plants, and that the duration of suspensions for SVS plants are significantly longer than their larger counterparts. Recommendations for correcting suspension inconsistencies centered on increasing the clarity of regulations outlining these handling violations. At the time of the report, the effects of the 2020 revisions to humane handling evaluations were unclear. The FSIS FY2021 Humane Handling Report indicated that while the overall proportion of SVS plant suspensions remained high (94% of total suspensions) the total number of suspensions decreased significantly (56).
Overall, FSIS has demonstrated its willingness to take these recommendations into consideration since the report’s release. Although not every key recommendation has been addressed, the constituent updates show a consistent stream of improvements since publication of the 2020 report. The bulk of FSIS communications to its processors come through the weekly constituent updates which are meant to inform the public on recent service activities. These updates are an important tool for determining how and when FSIS’ has responded to NMPAN 2020 report.
FSIS’s response has included several next steps, as well as inactions, including the following:
Ultimately, FSIS has been following a positive trajectory for enhancing the experience of SVS producers, as evidenced by the consistent stream of improvements, even throughout the COVID-19 pandemic. The 2020 NMPAN report was a significant driver of this recent progress. Although much has been done to improve the quality and quantity of resources available to SVS producers, more progress can be made, particularly in regards to increasing SVS stakeholder representation and improving how field outreach is conducted by FSIS personnel. As the USDA and other organizations continue to recognize the importance of small and local processors, more progress is necessary to ensure a competitive marketplace and strengthen the resiliency of processors of all sizes.