P1080934 by jessicareeder, on Flickr

Food safety is much in the news, and rightly so. As the nation has moved from small farms producing meat for their local community to larger and larger processors, food safety has suffered. According to Food, Inc., in 1970 the top 5 beef packers controlled about 25% of the market. Now, the top 4 packers control more than 80% of the market. Every time there has been a massive recall of tainted meat, the meat has come from huge producers and processors, not small, local facilities.

A pending regulation threatens to push even more meat in to the industrial food system by forcing smaller, local processors out of business. FSIS (Food Safety and Inspection Service, part of the USDA) has revised their guidelines to require “micro testing,” a new and expensive method that attempts to prove that the safety measures of a meat processing facility are effective. Unfortunately, this micro testing has not been shown to improve food safety.

The system in place since 1996 requires that the HACCP plan (Hazard Analysis and Critical Control Points) actually works in each specific establishment. Old, tried and true methods of providing a safe environment for processing have not required these micro tests. Only new processes not established and proven have required them. This process has worked well for the last decade, especially for small processors who rely on the safe processing methods that have been in use for a long time.

Requiring micro testing data of every step of every process within every establishment, even those using proven methods of safety validation, places too heavy a burden on smaller processors providing local, safe food. How much of a burden? One small processor did the math. The initial costs for the micro tests will cost $455,592, followed by an annual ongoing series of tests tallying $140,182.

Another small plant owner says, “The thing that’s going to affect us is the cost of the testing.” The revised rules for a small plant like his would require 13 samples of every product to be sent for testing before processing, and another 13 samples after processing. “When you add all those products and tests, it racks up a super amount of money. Right now we’re sitting at about $500,000 for the initial validation tests, just for the first year. We wouldn’t be able to do it. It would just really devastate our business.”

There is no evidence that micro validation will result in any improvement to the system of food safety protocols already in place. Because of the tremendous expense involved, these new guidelines will drive smaller processors out of business, putting more meat in the hands of fewer processors—something we already know has a negative effect on food safety. Dustin VandeHoer of the Iowa Department of Agriculture and Land Stewardship agrees. “We haven’t had problems with food safety, especially with the smaller plants,” he says. “We should never become complacent, but I think we can reach a point where [small meat processors] can still be allowed to operate and food can be safe. I don’t know that we need to be taking this path that’s going to put small plants out of business.”

These new guidelines could spell the end of locally produced, small-batch processed meats. To those of us seeking the freshest, safest food, these new guidelines could mean we no longer can choose to opt out of the industrial food system. To your local farmers, they could represent the loss of livelihood.

If safe, local meats available from farmers you know and trust is important to you, please take a moment and write a note to the FSIS right away voicing your opposition to this new regulation. Let’s support our farmers by adding our voice to theirs. The original comment period for these recommendations has passed, but there are requests to extend the comment period, and late comments are read and considered. Please do not let this opportunity to stand up for what you believe in pass you by. Take just a moment right now and be heard!

Please submit your comments to:
Docket Clerk, USDA, FSIS
Room 2-2127
5601 Sunnyside Avenue
Beltsville MD 20705

Or email your comments to:
DraftValidationGuideComments@fsis.usda.gov

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