Tell USDA not to impose even more burdens on small-scale poultry processors!
The USDA's Food Safety and Inspection Service (FSIS) has proposed a new framework to address salmonella in poultry processing. Unfortunately, this proposal is based on a flawed approach to addressing foodborne illnesses and is likely to drive small-scale poultry processors out of business.
Small- to mid-sized poultry farmers across the country rely on these local processors to prepare their products for sale and consumption. Yes, foodborne illness does need to be addressed. But we don’t help consumers by creating burdens on small farmers and small-scale processors, of which we already have too few.
Can you help us take action before the Friday, December 16th deadline? If we don’t speak up, they will never know the harmful impact this change could have.
You can read more about the details of the proposal below, but the basic problem is that while salmonella is ubiquitous, only a few strains cause illness in humans, and only a small handful of those pose the threat of antibiotic-resistant illness.
USDA has been doing “performance standard” testing for salmonella for a decade. The result has been a lower incidence of salmonella in the processing plants – and yet there is no apparent decrease in human illnesses from salmonella. The lack of connection is most likely due to multiple factors, including the many non-poultry sources of salmonella, the differences among salmonella strains, the flaws in the USDA testing methods for salmonella, and the chemicals used to reduce the bacterial levels.
USDA’s approach to salmonella has created a culture of chemical dependency, in which processors are incentivized to use more and harsher chemicals in an effort to produce a sterile final product (an impossible goal for a raw product).
Whatever the reasons, real-life experience shows that USDA should be changing how it approaches salmonella, not doubling down on its approach, as this new proposal would do!
While most likely not providing significant benefits, this new proposal will harm the small processors who serve as a vital link in the local food chain. Some parts of the new proposal – such as the requirement that every incoming flock be tested – are blatantly more burdensome for small processors who work with hundreds of small farmers as opposed to a huge corporate operation processing birds from its own flocks.
Even those requirements that appear to be scale-neutral are likely to adversely impact small processors, in part because the agency disproportionately targets small processors for investigations and enforcement – after all, small businesses don’t have powerful political connections and teams of lawyers and consultants to protect them, unlike the big meatpackers.
The end result? Small processors driven out of business, less access to locally raised poultry for consumers, and most likely little to no difference in actual health outcomes for consumers.
TAKE ACTION
Please submit your comments to USDA, urging the agency not to proceed with this framework unless it is significantly modified! You can submit comments online. The deadline is Friday, December 16.
Your comments can be short and simple. Please include:
- Why you care about this (Are you a consumer of locally raised poultry? Are you a poultry farmer who has struggled to find a processing facility for your birds and/or who would be burdened by the new testing requirements? Are you a processor or considering trying to become a poultry processor?)
- Three key things that FSIS should do:
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- Remove Component 1, which effectively imposes testing requirements on poultry farmers for each flock that is brought to a slaughter facility. FSIS should not use its authority over processors to create new burdens on farmers. This provision is blatantly prejudicial to small-scale farmers and homesteaders and the independent small processors who process for them.
- Remove Component 3 until and unless the agency provides a clear statement of what levels and what strains of salmonella would be involved. The component currently provides that FSIS will declare salmonella an adulterant in raw poultry based on a certain enumerated level AND/OR the detection of particular strains of concern. In other words, as currently proposed, the agency might declare that infectious levels of the 4-5 strains most likely to cause serious illness are adulterants, which would be reasonable. Or the agency might declare that any levels of any strain of salmonella are adulterants, which would be a completely unreasonable position. Until the agency provides some sort of specificity, stakeholders have no way to meaningfully comment.
- Conduct a full analysis of the impact of any new regulations on small plants. Costs imposed on small plants should be considered not only an issue from the perspective of harming small businesses, but an issue for food safety. Small processors are an integral part of a decentralized, localized food system, which provides a safer and more secure food supply for consumers. Thus, regulations that harm small processors reduce the overall safety and security of our food supply. Simply proposing to give small plants longer to comply isn’t a solution when the proposed regulations unduly burden small plants. In the absence of evidence or data showing that these small processors are the source of significant outbreaks, it is inappropriate to blindly impose the same requirements on them as on large processors.
Please add your thoughts to flesh out these recommendations and add your own!
And please share a copy of your comments with us! You can email them to Judith@FarmAndRanchFreedom.org. We’ll use material from your comments to help develop our materials as we continue discussions with the agency.
MORE INFORMATION
You can read USDA’s proposal at Proposed Regulatory Framework to Reduce Salmonella Illnesses Attributable to Poultry | Food Safety and Inspection Service (usda.gov).
The first step of the proposal is deeply problematic, and it will directly impact not only processors but the farmers and even homesteaders! The USDA seeks to require that every flock have a bird tested before entering the processing facility. This is relatively easy for large processors, where the flock owner and the processor are the same entity (e.g., Tyson). But for small-scale processors that are used by small farmers, the result is new testing requirements for every small poultry farmer and homesteader that needs processing for their birds!
The agency doesn’t explain how the testing will be conducted, or how small farmers are supposed to access or pay for official lab tests.
And if that one bird that was tested from the farmers’ flock tests positive for salmonella, the farmer may have no other option other than to euthanize all the birds they intended to take in for processing – even if the contamination is minor, of strains that don’t cause human illness, or could be addressed with cooking.
Why would the farmer have to kill their own birds? If the processor allows a flock that has tested positive for salmonella to enter their plant, the final product will have to be remediated to remove 100% of the salmonella – which is extremely difficult, absent irradiation or fully cooking the product at the plant (something large processors are set up to do, but small processors are not). So small plants may decide to refuse to take birds that have tested positive, leaving the farmer without options for processing.
The proposal also requires that product samples be tested after processing. It’s unclear if the meat will have to be held until the test results are available. Currently, sample results take approximately 6 days to be returned from the USDA – and that time is likely to get even longer under this new proposal, because USDA will be doing so much more testing! Large establishments can easily hold the poultry products in the freezer until it receives good test results; and if the product fails the new standard, large establishments can shuffle the “adulterated” product to another wing of their facilities to be turned into cooked product, without suffering any loss. This option is not possible for very small establishments that do not have the freezer space to hold product until it receives test results, or facilities to send the “failed” product to be further processed, meaning that the chickens would be destroyed if they test positive (even if the consumer would be glad to take them and cook them themselves).
The problems for small plants continue. USDA also directs processors to use “statistical process control” to interpret the pre-harvest data gathered by the plants. For statistical process control to be a useful tool for data interpretation the production process must be free of sources of variability. Since small processors take in birds raised by dozens of different farmers under extremely different conditions, this statistical analysis is not valid.
In addition, the very small slaughter plants may need expensive remodels to meet the new requirements or will face disruptions in their processing. For example, the agency is proposing to pull birds out in the middle of processing to test them, then return them to the line to finish the processing. For small plants, this would mean physically disrupting the entire process because they only have one line of operation, unlike the large operations with multiple lines.
We agree that foodborne illness is a problem, but this proposal is not a step toward a solution. Rather, it will negatively impact farmers AND consumers. USDA needs to take a smarter approach to addressing foodborne illness, including reducing the line speeds at the big processors and providing truth-in-labeling that empowers consumers to choose birds that are raised under healthier conditions.
