Posted April 15, 2010
New draft guidance being proposed by USDA’s Food Safety and Inspection Service is creating concerns for meat lockers and processors and has prompted Iowa Secretary of Agriculture Bill Northey to send a letter to U.S. Secretary of Agriculture Tom Vilsack this week.
Northey expressed concern that proposed new guidance by FSIS on HACCP and prerequisite program verification could hurt small meat processors financially without improving food safety. HACCP was designed to prevent, reduce or eliminate food safety hazards at critical control points and requires processors to document their food safety procedures.
"I worry that the new cost associated with the extensive testing required by this new proposal could hurt our small meat lockers in the state and, unfortunately, potentially drive more concentration in the meat processing industry," Northey wrote.
He said his concern is that that the proposed reinterpretation of the requirements “will add substantial new cost that will have a disparate impact on the small and very small meat plants located in and serve our rural communities.” He noted these plants typically slaughter more than one species of livestock and often produce a wide variety of products under several different HACCP systems.
"It is also unclear to me the food safety benefits that would result from the substantial new costs for these plants," Northey wrote.
He also expressed concern about FSIS’s proposed requirement that all prerequisite programs — such as plant sanitation, cooler temperature monitoring and pest control programs — be validated under the same protocols outlined in the draft guidance. "These programs are numerous and validating these will also add substantial new costs."
Northey questioned the validity of FSIS issuing the draft guidance as a re-interpretation and not a new rule, as that does not follow the same rule making process or allow for the same scrutiny as typical regulatory changes. In particular, he noted, there is no opportunity to have this new interpretation reviewed by the Small Business Administration to determine the financial impact on small businesses.
The Iowa Ag secretary wrote that small and very small meat plants are vital to many rural communities in the state and to the rural economy and he has “serious concerns” that this re-interpretation will impact their ability to stay in business and continue serving as a vital link between farmers and consumers.
Finally, Northey questioned the consistency of the FSIS proposals with other USDA initiatives.
"I commend your efforts through the "Know your Farmer, Know your Food" initiative to support small, local food producers, but I worry that these proposed guidelines could significantly setback the goals of that initiative."
The Iowa Pork Producers Association has been working with both the state and federal departments of agriculture on this issue. USDA has already agreed to extend the comment period on the proposed changes.
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