Published on September 28, 2021

The USDA Advisory Committee on Meat & Poultry began meeting on Monday, Sept. 27, to respond to the USDA’s request to consider proposing new rules for custom slaughterhouses. Specifically, the committee was asked about whether to limit the number of people who can be co-owners of an animal (and thus able to get meat processed in custom operations) and whether to impose new requirements on the slaughterhouses. These changes would have major impacts on many small farmers providing meat for their local communities. (Read more background here.) FARFA’s Judith McGeary testified to the Committee on Tuesday, Sept. 28; the following are her official comments.

My name is Judith McGeary, and I represent the Farm and Ranch Freedom Alliance, a nonprofit that advocates for small-scale farmers.  I served on the Secretary’s Advisory Committee for Animal Health for 6 years, so I understand and appreciate the time you all have committed to this work. 

FARFA did a Freedom of Information Act request to USDA last year asking about any illnesses linked to custom slaughterhouses since 2012, and the response was – none. 

We also asked the Texas Health Department the same question and got back documentation on a single alleged incident related to spoiled meat.

While the lack of reports doesn’t rule out that there may have been a few unreported problems, we need to base government regulation on data. Even if there were a problem, the meat is no more safe or risky based on how many people own it.

At yesterday’s subcommittee discussion [Monday, Sept. 27, 2021], there seemed to be a sense that until recently, it was just the farmer taking in his own cow for his own family. But animal shares have been happening for a long time. Almost 20 years, as a consumer, I was part of a group that split up animals into 1/16^th shares. 

As a legal concept, ownership doesn’t require that people raise the animal nor that they have what you might consider a “significant” share.

The subcommittee expressed interest in limiting the number of individual owners, but allowing groups — based on the idea that groups could be subject to rules to ensure people know what they’re doing.

But you can make informed consent a requirement WITHOUT limiting the number of individuals

Nebraska and Colorado have both passed laws that recognize that people can own basically whatever amount of an animal they want – down to 1 percent. Both include provisions for informing the co-owners that the meat is not being processed under inspection. Records of the names & contacts of the co-owners are also required.

And neither law requires the processor to keep records of who gets what, as proposed under question C [of the USDA’s request for guidance].

Doing so would not improve food safety. 

How does it make any difference for the custom processor to know that Joe Smith is getting 50 lbs. of ground, Jane Doe is getting 30 lbs. of ground and the chuck roasts, Steve Whatshisface is getting 20 lbs. of ground and the brisket.

Once the meat is fully processed and packaged, it is just as safe for the co-owners to do their own divisions of who gets which cuts. As long as the farmer keeps records, there is still traceability.

Custom slaughterhouses are small-scale businesses. Almost no processor we know will deal with dividing the animal into more than 4 equal shares. 

So, if the agency moves forward with rulemaking placing that requirement on the processor, rather than the farmer or co-owners, you are effectively limiting animal shares to just 4 equal co-owners. And many people have neither the money nor the space nor the desire to obtain that much meat at one time.

Given the ample evidence that we need more small-scale, decentralized meat production, the last thing this committee should do is make it harder for people to choose for themselves whether they want to work with a farmer they know, to get meat that was processed in an uninspected slaughterhouse.

Thank for you for considering my comments.