Published June 1, 2021

Do you have thoughts you’d like to share about how food gets from farm to plate? USDA is gathering public comments on “Supply Chains for the Production of Agricultural Commodities and Food Products.” The deadline is June 21.

President Biden directed the agency to submit a report within one year that assesses the supply chains for the production of agricultural commodities and food products.

USDA plans to use the public comments it receives to help prepare the report. The agency will also consider the comments in its spending of stimulus funds, since it has been directed to increase durability and resilience within the U.S. food supply.

This is an important opportunity to talk about the significance of localized, decentralized food systems – and to give the agency specific action steps that would help move us to those systems!

The most useful comments will be those with: (1) specific examples of the challenges farmers and other food producers face in raising, processing, and marketing their products; and (2) action items that would help small-scale and diversified producers, so as to build resilient, diversified systems.

Below are some suggestions to help you craft your comments. We are drafting our own comments and will share those once they are ready, so if you simply want to add your voice to support those, there will be that option … but if you have your own examples and action items, this is a great opportunity to help shape what USDA considers doing!

Topics to consider:

1. What went wrong and what your vision is for the future

Don’t assume that everyone agrees that the current system is a problem! Big Ag and Big Food will undoubtedly submit comments to claim that the COVID pandemic somehow shows that everything is okay as it is – that although there were problems, they were quickly solved and there’s no need to change. Whether you are a farmer or a consumer, share your story on what went wrong and any continuing impacts that you’ve observed. The problem is the “just in time” food system that prioritizes profits of a handful of mega-corporations at the expense of all else – so after pointing out what went wrong, talk about what needs to change.

2. Meat processing

This is one of the most obvious areas for improvement for supply chain resilience. We need many more small- and mid-sized operations rather than the terribly consolidated system that exists now.

Please share your own story about meat processing. Farmers: Were you able to provide meat during the meatpacker shutdowns last spring? Or have you been unable to because of a lack of processing? Consumers: What did you see during the pandemic? From whom did you get meat?

As a small farmer or processor, what changes do you think are needed? Remember that USDA can’t change statutes, but it can change regulations and policies, as well as direct relief funding for financial support.

Be specific about your geographic region and the size slaughterhouse you work with (or need access to). In conversations with senior USDA staff, they indicated that meat processing is already on their radar, and they are looking for information to help set their priorities.

Consider expressing support for these policy changes that FARFA will be recommending:

• Revise USDA’s policy governing multiple owners of animals that are processed in custom-exempt slaughterhouses. The USDA currently requires that the custom slaughterhouse record each owner and do the division of the meat, which makes it impractical for more than four people to co-own an animal. But the statute and regulations merely provide that the meat must be for the personal or household use of the owners. If USDA modified its policy, then “animal shares” could be far more flexible, allowing farmers and consumers to agree to use custom processors. In effect, we could implement the Wyoming herd share law without the need for new state statutes if USDA makes a simple policy change.
• Reform the scale-prejudicial regulations and policies on small-scale slaughterhouses, including: (1) prioritize inspector availability for small-scale processors and provide training specific to small-scale processors; (2) revise the pathogen testing and process-control testing to ensure that small plants are tested proportionally to large plants; (3) reduce the difficulty and expense in developing HACCPs by providing model HACCPs, posting applicable peer-reviewed research, and identifying the control points for different types of products.

3. Regulatory-driven consolidation

It makes no sense to provide grant funds and specialty niche programs to promote diversification if the agency simultaneously adopts regulations and policies that unduly burden small-scale, diversified producers or closes off markets to them. For example, electronic animal ID is extremely scale-prejudicial, and the benefits flow to the large, consolidated industries.

Share your concerns about electronic ID, both its impact on you and on others in the industry. Do you run your animals in pasture conditions where they are more likely to lose tags, increasing the time and monetary expense? Does your local sale barn have infrastructure for running all electronic ID or would it be forced to spend tens of thousands of dollars to install it? Would your veterinarian have to buy new equipment to deal with an electronic system?

Broadly, we urge that all new regulations and policies should be reviewed to identify whether they are scale-prejudicial and will promote consolidation.

4. Other areas of needed infrastructure

Whether physical (such as commercial kitchens and storage) or logistical (support for food hubs, farmers markets, etc.), what do you see as needed to build resilient, vibrant local food systems? Again, this can involve changing regulations, policy and guidance documents, or providing funding through USDA programs.

In our meeting with USDA staff, they indicated they are interested in suggestions related to how the agency can better support diverse markets, such as organics and value-added.

The staff also indicated that they are looking at consolidation issues at every step of the food chain, from seeds to processing to retail.

The goal should be to support diversification by individual producers and throughout the system to build a web of supply and distribution chains of differing sizes and types.

You can submit your comment online.

DEADLINE: Monday, June 21