Small to mid size poultry growers and small-scale poultry processors are on the firing line with the USDA’s Food Safety and Inspection Service’s (FSIS), proposed new framework to address salmonella in poultry processing. The proposal as it stands now could have an adverse effect on small to mid size poultry producers and will likely drive many out of business as added costs per bird and interruption in line processing (not to mention paperwork) become prohibiting. At a time when we need to support our smaller local growers and processors, this new proposal could be devastating. Public comment ends today!
Please take Action
We are gratefully sharing this action alert from Farm and Ranch Freedom Alliance Please visit them for more information regarding the proposed new poultry testing regulations.
You can read USDA’s proposal at Proposed Regulatory Framework to Reduce Salmonella Illnesses Attributable to Poultry | Food Safety and Inspection Service (usda.gov) TAKE ACTION TODAY!
Please submit your comments to USDA, urging the agency not to proceed with this framework unless it is significantly modified! You can submit comments online. The deadline is Friday, December 16.
Your comments can be short and simple. Please include:
Why you care about this (Are you a consumer of locally raised poultry? Are you a poultry farmer who has struggled to find a processing facility for your birds and/or who would be burdened by the new testing requirements? Are you a processor or considering trying to become a poultry processor?)
Three key things that FSIS should do:
Remove Component 1, which effectively imposes testing requirements on poultry farmers for each flock that is brought to a slaughter facility. FSIS should not use its authority over processors to create new burdens on farmers. This provision is blatantly prejudicial to small-scale farmers and homesteaders and the independent small processors who process for them.
Remove Component 3 until and unless the agency provides a clear statement of what levels and what strains of salmonella would be involved. The component currently provides that FSIS will declare salmonella an adulterant in raw poultry based on a certain enumerated level AND/OR the detection of particular strains of concern. In other words, as currently proposed, the agency might declare that infectious levels of the 4-5 strains most likely to cause serious illness are adulterants, which would be reasonable. Or the agency might declare that any levels of any strain of salmonella are adulterants, which would be a completely unreasonable position. Until the agency provides some sort of specificity, stakeholders have no way to meaningfully comment.
Conduct a full analysis of the impact of any new regulations on small plants. Costs imposed on small plants should be considered not only an issue from the perspective of harming small businesses, but an issue for food safety. Small processors are an integral part of a decentralized, localized food system, which provides a safer and more secure food supply for consumers. Thus, regulations that harm small processors reduce the overall safety and security of our food supply. Simply proposing to give small plants longer to comply isn’t a solution when the proposed regulations unduly burden small plants. In the absence of evidence or data showing that these small processors are the source of significant outbreaks, it is inappropriate to blindly impose the same requirements on them as on large processors.
Please add your thoughts to flesh out these recommendations and add your own!
And please share a copy of your comments with us! You can email them to Judith@FarmAndRanchFreedom.org. We’ll use material from your comments to help develop our materials as we continue discussions with the agency.