Food Safety Regs are a Blow to Locavores, Small Farmers

Do you buy local chicken or local steak? Do you support beef and poultry farmers who sell at your local farmers markets? Like to order a nice grass-fed burger from a neighborhood joint?

Then I need your full attention and swift action, Fair Food Fighters.

A new approach to an old program is being floated by the USDA’s Food Safety Inspection Service (FSIS) that could deal a very harsh blow to your local farmers by imposing strict requirements on small butchers and meat processors — so harsh, it could put many of them out of business. And that could spell disaster for small farmers in your region.

BACKGROUND

Expanding an existing program, the FSIS wants to shore up food safety requirements by fully implementing and enforcing its 14 year old HACCP program. What is HACCP? From Wikipedia:http://en.wikipedia.org/wiki/Hazard_Analysis_and_Critical_Control_Points

“HACCP is used in the food industry to identify potential food safety hazards, so that key actions, known as Critical Control Points (CCPs) can be taken to reduce or eliminate the risk of the hazards being realized.”

This is a good idea, right? A HACCP plan describes the places in a meat processing plant or a butcher shop where food could be contaminated, and it describes what daily and hourly routine steps are taken to prevent that from happening. Cleanings, pathogen tests, pH tests, temperatures, water activity, and other food safety practices are documented by workers and managers to insure that the HACCP plan is being followed. Poultry, eggs, seafood, and juice all require HACCP programs. (Most other FDA products do not.) 

HACCP went into effect over a decade ago, but one aspect that was never fully realized was “Verification,” that is, proving that a business is following its own HACCP plan, and that’s part of what these new FSIS regulations address. The new approach to Verification seeks to “verify” that meat processors are testing for pathogens (among other food safety practices) and documenting those tests in order to prove that their HACCP plan is working.

THE PROBLEM

Local butchers and small meat operations are going to get steamrolled by these requirements.

As just one example, small meat processors will need to collect microbial data for at least one product from each HACCP category that they process (beef, pork, chicken, lamb, etc), under the new Validation program.  These products can be grouped (chicken breasts, chicken thighs, chicken sausage), but the similarities and differences in species, process, product public health risk, and food safety hazards might require further testing. If your butcher’s meats vary even slightly (various sausages can be significantly different in how they’re made from one recipe to another), they may be required to “verify” all their products in each and every category.

This is exasperating and frightening to many meat shops and small- to medium-sized processors. Even small operations offer a wide variety of foods, after all (think about all the cuts and various types of meat you see in your local butcher shop or at a farmers market). But these tests are expensive, so the more cuts and varieties of meats that an operation offers, the more it will cost that butcher to keep selling those various cuts. The obvious solution won’t be to invest more money for further testing, but to raise prices, reduce the variety of their product mix, and offer only what sells very well.

Or close up shop.

Right now, small, local shops are where many eaters buy meats that aren’t offered in big grocery stores. Lamb for example, or even more hard to find meats like rabbit, pheasant, buffalo, venison, or squab. If these foods get dropped by small operations, it’s hard to imagine bigger processors picking them up, since there just isn’t a big enough market for these specialty meats to be profitable.

Will we watch those items disappear and become completely unavailable thanks to food safety questions? Will processed squab be tomorrow’s raw milk – dangerous and forbidden?

Estimates show that this new enforcement regimen could cost some small processors $352 more per head of beef, alone. Yet, according to Amy Sipes who runs John’s Custom Meats  a small USDA-inspected butcher shop in Smiths Grove, Kentucky, she receives only $300 per head now. These regulations will make life very difficult for her and her family-run shop.

Furthermore, if these processors do go out of business, that means small meat producers and small farmers will have to pay to ship their product further to be processed. Adding “food miles” to meat is not a good idea. Stress from transportation can ruin the taste profile and the market advantage that local, artisan meats enjoy. Plus, without local processing, farmers wouldn’t be able to sell their meat at farmers markets or to local restaurants.

WHAT CAN YOU DO?

If you purchase chicken at local farmers markets or small-farmer beef from your local restaurant, I strongly urge you to take a minute and draft a letter to FSIS Administrator Al Almanza. In your email or letter, ask him to:

1) SLOW DOWN. Many small farmers who rely on local processors probably don’t even know about this proposal. Since it will affect them dramatically, small meat producers need to be solicited for comment.

2) ANALYZE IMPACT. USDA Deputy Secretary Kathleen Merrigan has said that she doesn’t think added costs from these FSIS regulations will be burdensome to small processors and/or farmers. But does she know for sure? Has an economic impact analysis been conducted for these FSIS regulations? Shouldn’t we do that first before proceeding?

3) CREATE MORE EXEMPTIONS FOR SMALL AND MEDIUM-SIZED PROCESSORS. The BEST way to create a safer food system is to protect and propagate small- and medium-sized processors, not to make them less profitable. After all, a decentralized food system is an insurance system against big outbreaks. Small processors can’t produce enough meat to necessitate a 20 million-pound national recall of hamburger, so we should  strengthen our small, local food systems, not undermine them.

PLEASE submit your comments to DraftValidationGuideComments@fsis.usda.gov or to the Docket Clerk, USDA, FSIS, Room 2-2127, 5601 Sunnyside Avenue, Beltsville, MD 20705. Comments should be submitted by June 19, 2010. After June 19th, FSIS will begin its review on the comments it receives and its process of deciding how it will proceed with respect to the validation of HACCP systems.

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For more info

Join the Facebook page No Butchers, No Meat

If you really want more specific information about these regulations, and you aren’t afraid of getting down in the muck of this issue, I recommend reading the blog Meat is Neat by Dr. Chris Raines, who is with the Penn State Department of Dairy & Animal Science Program in Meat Science.  In particular, read Do you feel validated? Very thorough and intelligent piece.