August 16, 2019
The rising demand for local, niche meat and poultry over the past decade has led to ever-increasing reliance on the country’s few small-scale independent processing plants that operate outside of the broader commodity meat sector. When one of these small plants is shutdown or suspended, therefore, the impact can be resounding. The National Sustainable Agriculture Coalition (NSAC) has been working closely with our allies (the Niche Meat Processors Assistance Network (NMPAN), the American Grassfed Association (AGA)) and the United States Department of Agriculture’s Food Safety Inspection Service (FSIS) to ensure that FSIS’ regulatory approach is right-sized for small and very small meat processing plants.
FSIS leadership has to date supported and co-sponsored seven regional stakeholder roundtables for small and very small meat processing plants in partnership with AGA, NMPAN, and NSAC. These convenings created the opportunity for open dialogue, wherein niche producers and processors were able to directly address meat and poultry food safety, as well as the negative impacts of a one-size-fits-all regulatory framework.
In 2016, NSAC’s conversations with FSIS on addressing the challenges and barriers to the growth of the local and sustainable meat sector moved out of the office and into the field. NSAC and FSIS partnered with NMPAN to launch five regional roundtables, taking place between 2016-2018. The regional meetings were held at locations across the country, and each included representatives from small and very small plants, top FSIS officials, farmers and ranchers, key industry and support organizations, and other relevant stakeholders.
For many stakeholders, the meetings were a first-time opportunity to have a direct dialogue with high-ranking FSIS officials from district and federal offices. At the meetings, participants discussed with FSIS how the agency could better support small and very small plants’ needs.
“It is critical that small meat processors not only understand the regulatory framework in which they operate, but also how to engage with it and have a voice,” says Rebecca Thistlethwaite, Director of NMPAN, which is part of the Center for Small Farms & Community Food Systems at Oregon State University, a NSAC member organization.
The regional roundtables were held in Indiana, Arkansas, Maine, Oregon, and Pennsylvania. Local hosts included: Gunthorp Farm, Heifer International, Grassroots Farmers Cooperative, Dirigo Food Safety, NMPAN, and the American Association of Meat Processors. Each meeting included a processing plant tour, as well as a tour of a livestock farm focused on local and regional meat sales.
This year, NMPAN, AGA, and NSAC partnered together to host two additional roundtables with FSIS: in Denver, Colorado and La Grange, Kentucky. The meetings were hosted at the National Western Stock Show and Ashbourne Farms, respectively.
The 2019 roundtables expanded on common issues and themes from past meetings, including: inspector training and retaliation, animal raising claims on product labels, and humane handling guidance and outreach.
Plant owners and FSIS discussed paths forward to improve inspector training and find realistic options for addressing issues with inspectors. There were, however, still concerns that certain inspectors might act out of retaliation when plant owners bring issues to top officials at FSIS. Small plant owners asked FSIS for increased support around addressing problems within the inspection workforce and create a more uniform playing field of inspection across all regions and plant sizes.
Meat labels were another frequently discussed topic. Specifically of interest to attendees were label approvals for certain claims, for example, “grassfed” or “product of the USA”. Participants voiced concern that certain animal raising claims are oftentimes fraudulent and misbranded, and that frequently enter the market due to a lack of enforcement by FSIS and/or a lack of clarity in the regulations.
“We would like to see more transparency and documentation for animal raising claims,” said Carrie Balkcom, Executive Director of AGA. “FSIS has yet to comment on the “product of the USA” petition AGA and the Organization for Competitive Markets filed over a year ago. It needs to move forward with resolution to bring clarity to the claim that “product of the USA” is indeed born and raised in the USA.”
One possible solution to this problem, which was discussed at several roundtables, would be for USDA to pursue cooperative or interagency agreements to provide for on-farm verification of disputed claims. According to Balkcom, using certification as a tool to verify these claims, which can bring producers a premium in the market place, would be a step in the right direction. NSAC hopes FSIS will address some of the stakeholder concerns in the soon to be released final version of the Animal Raising Claims Guidance. NSAC submitted comments on the proposed guidance. We encourage FSIS to ensure the guidance upholds integrity, accuracy, and transparency for certain label claims.
Small plant stakeholders also voiced concerns about the humane handling requirements and the length of time small and very small plants are suspended (from inspection) as a result of humane handling violations. Participants encouraged FSIS to provide more scale-appropriate humane handling guidance and consistent enforcement with respect to second stuns (when a second shot or stun is needed to render an animal senseless) while also maintaining animal welfare.
“The United States has probably the strictest laws on earth for the humane handling of livestock and poultry, and for good reason,” said Thistlethwaite. “However, the strict interpretation of the humane handling rules does not allow for any tolerance of operator errors and creates an antagonistic environment for small, multi-species plants to operate in. We need to provide common sense options while upholding excellent animal care.”
Other topics of note included: potential changes to federal law that could address barriers to expanding the local and sustainable meat and poultry sector, funding for expanded meat science research, and grant programs to improve access to high-quality meat processing infrastructure.
Additionally, NSAC was pleased that FSIS decided to establish a small working group and develop additional guidance documents after hearing stakeholders’ concerns with two regulatory documents:
At the Kentucky roundtable, NSAC and other stakeholders were disappointed that FSIS chose to include representatives from the large commodity meat sector. However, we are hopeful that FSIS will continue to ensure the roundtables are a place for discussion focused on the very small scale, local meat sector. There is a need for the meetings to remain focused on real dialogue and problem solving, which requires a smaller group of participants to ensure that each attendee has a voice.
“We will continue to advocate for small-scale plant owners and the farmers they serve to be the primary participants at these meetings,” said Balkcom.
Before the fifth meeting, NMPAN and NSAC surveyed approximately 45 past roundtable participants on what they saw as the impacts and potential outcomes of the meetings. A majority of those surveyed indicated that the meetings were key in connecting small plant stakeholders with top FSIS officials, and that they provided a great networking opportunity for all. Participants also requested that future meetings discuss topics that can only be addressed by FSIS or Congress amending policy.
The local, niche meat sector has the opportunity to continue enhancing the industry’s contributions to climate change adaptation and mitigation by improving soil health and carbon sequestration through well-managed pasture-based livestock production. They are also contributing to improved human health by expanding the availability of high-quality, nutrient-dense meat and animal products to consumers. These small and very small meat processing plants are also key contributors to rural and food producing economies, providing living wage jobs to their communities. In order to meet rising demand for their products and continue contributing positively to American agriculture and rural communities, the industry must be able to work collaboratively with FSIS. NSAC and our partners look forward to continuing the dialogue between FSIS (and other USDA agencies) and small and very small meat and poultry processing stakeholders.