One essential aspect of local food systems is the local meat processor. Without such facilities, there will be no market for local meats. Here in Oklahoma, local processors are inspected either by the USDA or the Oklahoma Department of Agriculture. There has never been a food illness outbreak in Oklahoma that resulted from a problem at a facility inspected by the ODA.
Comes now the federal Food Safety and Inspection Service, proposing significant changes to the regulation of small meat processors that will certainly put many, if not most, such facilities out of business. Processors are required to develop HAACP plans, which are analyses of the risks of food contamination and their plans for handling such potential problems and keeping the food they process safe. Processors prepare these plans and file them. FSIS however is now proposing that these plans be validated by outside experts. We are told that the costs of these validations could range from $5K to $50K/year, depending on the products handled by the processor. This is a prohibitive cost for a small local processor. It will do nothing to increase food safety, it is a response to a problem that doesn't exist in the small meat processing market, and it will destroy jobs.
There can be no doubt that the hand of major meat industry players is behind this move. They see the handwriting on the wall in terms of the challenge the local artisanal meat producers to their industrial hegemony over the nation's meat supply. $50K is nothing when you are doing millions of dollars of business every year. The easiest way to destroy the growing local food systems is to destroy them with regulations.
Below is my email, sent in April while I was still president of the Oklahoma Food Cooperative, regarding this issue. I encourage everyone to send comments to the address in my copy (which is published in full below) ASAP. The only thing necessary for evil to triumph is for good men and women to do nothing. Don't stand by while evil triumphs, speak out loudly to defend your right to purchase locally grown meats and to defend the rights of your neighbors to produce locally grown meats.
If you are a member of the Oklahoma Farm Bureau (or another state's Farm Bureau) or the Oklahoma Farmers Union, be sure to bring this to the attention of these organizations' legislative departments.
Begin copy. . .
Docket Clerk, FSIS
5601 Sunnyside Avenue
Beltsville, MD 20705
Sent via email to firstname.lastname@example.org
To whom it may concern:
I respectfully submit these comments regarding the Draft Guidance on HACCP System Validation that were publically released on March 19, 2010.
I am president of the Oklahoma Food Cooperative. We make it easy for people in cities in Oklahoma to buy meat directly from Oklahoma farmers. All of the meat products they sell are processed in locally owned processing plants inspected by the USDA or the Oklahoma Department of Agriculture.
It is our understanding that FSIS is proposing to require that meat processors do a series of expensive tests to validate their HAACP plans. Our local processors indicate that the costs to them would run between $5,000 and $50,000/year, depending on the number of their products. This is a prohibitive cost for small locally oriented meat processors, and if this guideline is enacted as a regulation, it will virtually destroy the small processor market. This would put our meat producers out of business, and would destroy our cooperative's business, since over half of our sales are meats.
I am not aware of any problems in food safety caused by local meat processors in Oklahoma. When I read of meat recalls, they aren't coming from small processors, they are coming from giant multi-state processing operations. Laying this new regulatory burden on small meat processors is not called for by the facts on the table. It would cause the destruction of important heritage businesses, that operate in sustainable ways. It would damage the economies of rural areas and destroy jobs in an era when job destruction is already a real problem. It would cause our urban customers to lose access to locally grown, locally processed meats.
For all these reasons, I strongly 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.
President, Oklahoma Food Cooperative