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 if we don't act now there's a chance the USDA will seal the deal.
Picture an hourglass and you'll understand the sustainable meat crisis: there are plenty of willing consumers out there, and there are more and more farmers looking to "meat" that consumer demand (sorry—couldn't help myself!), but the real bottleneck is processing capacity. Small, community-based meat processing plants have become an endangered species, done in by an ocean of super-cheap industrial meat and the challenge of meeting the Byzantine demands of USDA regulations 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 them. The same thing 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 catastrophe comes along and causes a wholesale wipeout.
For 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 costly Hazard Analysis and Critical Control Point (HACCP) food safety plan. It has been estimated that 20 percent of existing small plants, and perhaps more, 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 ones that remain, making healthy, local meats a rare commodity.
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 U.S. Department of Agriculture. On March 19, 2010, the FSIS published a draft guidance document on HACCP system validation, outlining new rules which would institute regular, year-round testing of all meats, whether or not problems have been identified. The proposal recommends 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, and we have never had a positive result—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 wants to test the system and require excessive end-product microbiological testing, rather than allowing us to depend on these well-recognized procedures. 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 large plants should open labs—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 requirements are going to cause a train wreck in a portion of the industry that is growing 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 agribusiness 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 that they are coming to us, and we need to keep local infrastructure alive in this country. We need an inspection system that recognizes that the small plants do not put either the food economy or millions of people at risk in case of a food safety event.
If you are interested in providing comments to the USDA on this matter, I urge you to do so by June 19. 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 Web sites of the Association of American Meat Processors and 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.
You can submit comments by emailing DraftValidationGuideComments@fsis.usda.gov or by mailing them to the following address: Docket Clerk, USDA, FSIS, Room 2-2127, 5601 Sunnyside Avenue, Beltsville, MD 20705.