Next Slaughterhouse Extinction Wave

This should be the slowest time of the year for butchering, but T&E Meats is booked months in advance, like the other small meat processing plants in my area. We’re all working at almost full capacity to bring locally grown, pasture-raised, and humanely slaughtered quality meats to market. The local food movement and the bad economy have motivated people to return to their roots, but the infrastructure to support such a movement is threatened with extinction, and there’s a chance that the USDA will seal the deal if we don’t act now.

Picture an hourglass and you’ll understand the local, sustainable meat crisis: there are plenty of willing consumers out there looking for humanely raised, quality local meats, and there are more and more farmers looking to “meat” that consumer demand (sorry – couldn’t help myself!), but the real bottle neck is processing capacity.  Small, community-based meat processing plants have become an endangered species in America, done in by an ocean of super-cheap industrial meat and the challenge of meeting the Byzantine demands of USDA regulation requirements without a Ph.D. in microbiology.

Although species go extinct on earth on a regular basis, every so often there is a major event that comes along and wipes out 40 or 50 percent of all species.   The same happens in the small business world.  A few businesses fold every year due to retirement, poor management, and changes in the market, and that is quite normal.  But then every so often a catastrophic event comes along that causes a wholesale wipeout, such as the recent global credit crunch.

In the small meat businesses in America, catastrophic events result from changes high up in the regulatory food chain that make it very difficult for small plants to adapt. The most recent extinction event occurred at the turn of the millennium when Small and Very Small USDA-inspected slaughter and processing plants were required to adopt the HACCP Plan system.  It has been estimated that over 20%, perhaps more, of existing small plants went out of business at that time. Now, proposed changes to HACCP for Small and Very Small USDA-inspected plants threaten to take down many of the remaining local plants, making the availability of healthy, local meats a rare commodity.

HACCP is a food safety plan approach that stands for Hazard Analysis and Critical Control Point Plan, and the intent of HACCP is to prevent contamination of meat by harmful pathogens. Plant HACCP plans are approved and overseen by the Food Safety and Inspection Service (FSIS), the inspection arm of the US Department of Agriculture.  On March 19, 2010, the FSIS published a Draft Guidance on HACCP System Validation, outlining new rules which would institute regular, year-round validation testing of all meats, whether or not a problem has been identified.  The problem is that these rules do not identify the hazard that they are attempting to address.  It is testing for testing’s sake, and it will cost small plants tens of thousands of dollars, perhaps even hundreds of thousands, every year. The financial burden appears great enough that this will destroy much of the remaining community-based meat processing industry, which is enjoying a renaissance and creating jobs.

Small, local meat processors have always supported food safety. At our plant, we have had a functioning HACCP Plan since 1999, and it works.  We undergo extensive E.Coli testing every year, with zero (0) positive results, ever.  The purpose of HACCP is to employ well-recognized, established processes and process control parameters to produce safe meat products – processes and parameters recognized and published by the USDA itself.  Now, for some reason, the USDA is attempting to test safety into the system and requiring excessive end-product microbiological testing, rather than allowing us to depend on these well-recognized process controls.  Perhaps a large plant slaughtering 5,000 animals per day can afford its own lab and microbiology staff, and can pass the cost along to the consumer, but most small plants can’t.  And perhaps they should – those are the plants where a massive beef recall can involve millions of pounds.

In my opinion, the USDA needs to recognize that “One Size Fits All” inspection no longer fits current industry practice and consumer demand. These new HACCP Validation requirements are going to cause a train wreck in a portion of the industry that is growing due to consumer demand for the first time in years, and then the USDA is going to have a serious embarrassment on its hands. Someone needs to take a clear-eyed look at this situation and find a way to split the agri-business mega-plants from the community-based localized plants within the regulatory structure. This does NOT mean that small plants are not serious about food safety. It is because consumers are serious about food safety (and food security) that they are coming to us, and we need to keep local infrastructure alive in this country.  We need an inspection system which recognizes that the small plants do not put either the economic food system or millions of people at risk in case of a food safety event.

If any individuals are interested in providing comments to the USDA on this matter, I urge you to do it by the new deadline of June 19th, 2010. The original deadline was April 19, but it has been extended due to the great interest and concern that has been generated around this issue.  You can learn more at the Association of American Meat Processors web site or the Niche Meat Processors Assistance Network.

Please submit a comment if you care about community-based meat processing and humanely produced meats.  Your comments really do matter. Submit your comments to the email address [email protected] or to the Docket Clerk, USDA, FSIS, Room 2-2127, 5601 Sunnyside Avenue, Beltsville, MD 20705.