Act to Support Local Meat: Comments on HAACP System Validation

In response to a blog post on Beginning Farmers on April 27th regarding a Salon article entitled 'Will the USDA doom locally produced meat?' (see the link below), our friend Karen Dill-Wilson has done a great job researching the issue, and has presented us with an overview of the situation, and the options for action, including a letter writing campaign which people can join in support of locally produced meat. Here is Karen's well researched response: OVERVIEW ARTICLE: https://www.salon.com/food/feature/2010/04/26/usda_testing_end_local_meat/ Personal note: Hi! After reading the above article I started looking around for the letter writing campaign referenced in the last paragraph.  I was disappointed to find nothing easily assessable and nothing really geared toward consumers, it was all for the industry folks.  So I did my homework on the AAMP (American Assoc of Meat Processors - https://aamp.com/Validation.php) and after much reading and talking directly with one of their members, put together a letter for consumers.  My initial strong feelings were to slant the letter toward the evils of large, corporate processers vs. small, local, independent processors…but that’s NOT what this fight is about.  It’s about making sure that our small, local, independent processors are still standing and in business at the end of this!  If not for them, where will we take our local, well-cared for, grass-fed livestock to be processed?!  THANK YOU for your efforts to help save your local processors. DEADLINE for COMMENTS: June 19, 2010 Definition of terms: HACCP – (Hazard Analysis and Critical Control Points) is a management system in which food safety is addressed through the analysis and control of biological, chemical, and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product. (SOURCE: ADA.org) FSIS – Food Safety and Inspection Service What YOU can do NOW: OPTION 1:  Contact FSIS via email at: DraftValidationGuideComments@fsis.usda.gov Cut and paste the letter (making sure to fill in the highlighted areas and edit as you see/feel fit) OPTION 2:  Make your changes and send off the hard copy letter to the address at the top

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Docket Clerk, FSIS

Room 2-2127

5601 Sunnyside Avenue

Beltsville, MD  20705

Re: Comments – Draft Guidance on HACCP System Validation

Dear Mr. Almanza:

I respectfully submit these comments regarding the Draft Guidance on HACCP System Validation that were publically released on March 19, 2010.

As a consumer of livestock products who depends upon local, small independent meat processors, my concern regarding the process validation in inspected establishments HACCP programs has prompted me to submit these comments.  I am not an industry big-wig; I am only one person who is concerned with the damage that I foresee these new validation requirements causing my local, independent meat processors.  When HACCP was implemented, the meat industry saw a decrease in establishments.  This initiative and new interpretation has the potential to decimate the remaining very small to small establishments, upon which so many Americans, including myself, depend.  There is nothing wrong with the current HACCP system, whereas independent, small processors are concerned – nor is there any reason to believe the extraneous requirements would produce a safer end product.  It has been estimated that the potential cost to validate a processors entire food safety system could easily run upward of $500,000 initially and over $100,000 for ongoing validation.  No food safety problem has been identified to require this shift in agency interpretation of validation; I don’t understand why this is necessary when there is a system in place that is working.  All I see this shift in interpretation accomplishing is:

• Devastating the remaining small meat processors (hinders commerce)
• Large decrease in the variety of products available
• Discouraging the introduction of new products, therefore reducing the number of employees (increased unemployment)
• Increasing the cost of production, therefore increasing what I have to pay

None of these sound like they would be for the good of the American consumer.  I know, believe in and trust my local meat processors; therefore,   I respectfully request that the Draft Guidance on HACCP System Validation be revised to clearly state that no in-plant microbial testing is required when an establishment is following the long-standing, safe processes of HACCP.

I appreciate the chance to comment on the Draft Guidance on HACCP System Validation.  Thank you for your time and consideration.

Sincerely,

(Name and Address)

cc: [Your State Legislators- Congressmen and Senators]

[The Small Business Administration]

[Your State Farm Bureau]

[Your State Beef and Pork Council]

——————————————————————————————————————-

Find your Representative:

https://writerep.house.gov/writerep/welcome.shtml

Find your Senator:

https://www.senate.gov/general/contact_information/senators_cfm.cfm

Find your State Farm Bureau:

https://www.fb.org/index.php?fuseaction=newsroom.statefbs

Find your State Beef Council:

https://www.beefusa.org/affiFederationofStateBeefCouncils.aspx

Find your State Pork Council:

https://www.nppc.org/aboutus/stateassociations.htm

FURTHER ACTION YOU CAN TAKE:

Please also contact the Small Business Administration Ombudsman, which offers the opportunity to submit online comments on regulatory unfairness for small business. The website is:

https://web.sba.gov/nocms/client/dsp_welcome.cfm

Instructions:  (unblock pop-ups)

Organization Type: SELECT “Small Business”

Federal Agency Name: USDA

Agency Contact person:  Mr. Almanza

Agency Office/Division:  FSIS

Click “No”

ENTER:  AAMP

COMMENT:

I am writing re: HACCP System Validation for Meat Processors. When HACCP was implemented, the meat industry saw a decrease in establishments. The current initiative and new interpretation has the potential to decimate the remaining very small to small meat processing establishments. If the interpretation goes through as it is currently structured, it will most definitely be a hindrance to commerce, will decrease the variety of products available and discourage introduction of new products. This will in turn, reduce the number of employees needed and increase unemployment. It will also increase the cost of production, therefore increasing the cost I will have to pay. All of these factors alone represent unfairness toward small processors, when adding the financial burden (initially upwards of $500,000 and $150,000+ for ongoing verification) it surely must be regulatory unfairness for small businesses.  Thank you for your time and attention to this important matter.

OR you can send them a copy of your letter to FSIS/Mr. Almanza via regular mail at:

U.S. Small Business Administration

409 3rd Street, SW

Washington, DC 20416