Will USDA doom locally produced meat?

The U.S. Department of Agriculture's Food Safety Inspection Service recently proposed a set of new regulations that will require all meat processors to submit their products to a new series of tests, a procedure that can cost hundreds of thousands of dollars for even a modestly scaled operation, enough to cripple many small processors.

What worries fans of small farms and locally produced food is that the closing of small processors will mean the closing of small farms. Slaughter and processing is the biggest challenge for small-scale meat; they're operations simply too costly and complex for farms to handle themselves. As it is, farmers have few options for meat processing without selling their animals to massive feedlot-meat operations, and without that piece of the puzzle, many farmers may quit.

Why is the USDA considering the new testing regime? Some producers wonder if the machinations of Big Food are in play. The rest of this piece can be found at the following link:

http://www.salon.com/food/feature/2010/04/26/usda_testing_end_local_meat/

Steve: this sounds very much like Monsanto's intent to corner the market on all seeds, making it impossible for small growers to use their own.

If you would like to respond to the USDA, here is your recourse:

THE DEADLINE for COMMENTS is June 19, 2010

What YOU can do NOW:

OPTION 1: Contact FSIS via email at:

DraftValidationGuideComments@fsis.usda.gov

Cut and paste the following letter (making sure to fill in the highlighted areas and edit as you see/feel fit)

OPTION 2: Make your changes and send off the hard copy of the following letter to the address at the top

Docket Clerk, FSIS

Room 2-2127

5601 Sunnyside Avenue

Beltsville, MD 20705

Re: Comments – Draft Guidance on HACCP System Validation


Dear Mr. Almanza:

I respectfully submit these comments regarding the Draft Guidance on HACCP System Validation that were publically released on March 19, 2010.

As a consumer of livestock products who depends upon local, small independent meat processors, my concern regarding the process validation in inspected establishments HACCP programs has prompted me to submit these comments. I am not an industry big-wig; I am only one person who is concerned with the damage that I foresee these new validation requirements causing my local, independent meat processors. When HACCP was implemented, the meat industry saw a decrease in establishments. This initiative and new interpretation has the potential to decimate the remaining very small to small establishments, upon which so many Americans, including myself, depend. There is nothing wrong with the current HACCP system, whereas independent, small processors are concerned – nor is there any reason to believe the extraneous requirements would produce a safer end product. It has been estimated that the potential cost to validate a processors entire food safety system could easily run upward of $500,000 initially and over $100,000 for ongoing validation. No food safety problem has been identified to require this shift in agency interpretation of validation; I don’t understand why this is necessary when there is a system in place that is working. All I see this shift in interpretation accomplishing is:

Devastating the remaining small meat processors (hinders commerce)
Large decrease in the variety of products available
Discouraging the introduction of new products, therefore reducing the number of employees (increased unemployment)
Increasing the cost of production, therefore increasing what I have to pay

None of these sound like they would be for the good of the American consumer. I know, believe in and trust my local meat processors; therefore, I respectfully request that the Draft Guidance on HACCP System Validation be revised to clearly state that no in-plant microbial testing is required when an establishment is following the long-standing, safe processes of HACCP.

I appreciate the chance to comment on the Draft Guidance on HACCP System Validation. Thank you for your time and consideration.

Sincerely,

(Name and Address)

cc: [Your State Legislators- Congressmen and Senators]