🖨️ Print post
Submit Your Comment by Friday, January 17, 2025
The USDA has proposed regulations governing Salmonella in raw poultry that threaten to drive the few remaining small-scale poultry processors out of business. While Salmonella needs to be taken seriously, the biggest problems occur at large-scale operations, and yet these rules will disproportionately impact the small processors. Many of our farmers depend on the few small-scale poultry operations who will process their animals as a fee-for-service — there are only about thirty (30) of these fee-for-service small processors left in the whole country! Without them, many of these farmers will be unable to supply poultry products for their local communities.
The deadline for commenting is January 17, 2025.
Read USDA’s proposed rule here.
Oddly, USDA acknowledges that the levels and frequency of Salmonella have been significantly reduced already by testing and control programs in the last few years, yet there has been no corresponding decrease in human illnesses from Salmonella. In other words, there’s a disconnect between the testing and the real-world outcomes. Yet instead of addressing that, the agency is doubling down with more testing and regulation.
Your comments CAN make a difference! USDA published an initial proposal in 2022 that included testing for Salmonella levels on every single incoming flock of birds entering the processor, and multiple groups pushed for zero tolerance of any strain of Salmonella. This new proposal, as bad as it is, backed away from testing every flock, and looks at only the few strains known to cause illness on finished poultry products. That change is because farmers and consumers spoke up during the first round of this fight!
We need you to speak up again and help us head off the continued bad portions of the proposal! If you have personal experience as a small farmer or homesteader who uses small processors, please be sure to share that!
ACTION TO TAKESend USDA your comments asking them to amend their proposed regulations by reducing the burden on small-scale poultry processors.
Submit your comments online at regulations.gov for Docket ID FSIS-2023-0028-0007, “Salmonella Framework for Raw Poultry Products”; attach documents and/or write your message directly at
https://www.regulations.gov/commenton/FSIS-2023-0028-0007
Your comments can be short and simple. The most important thing is to write a few sentences about why this issue is important to you and the impact it will have on you — whether you are a small processor, a farmer who relies on a small processor, or a consumer who buys your poultry locally from farmers you trust. You can use the Talking Points below for ideas of things that you may want to highlight in addition to your personal story.
TALKING POINTS
(Remember to first write why this matters to you, and then add a few of these if you want – don’t just copy and paste all of them):
1. The proposed framework is a strange, confusing mix of legally binding requirements and vague guidance. This sets the stage for inconsistent and unfair application; throughout it, the proposal fails to address issues in a scale-sensitive manner.
2. The proposed rule requires lot testing, but doesn’t set the frequency based on the size of the operation – so small processors will end up testing a much higher percentage of their birds than large processors. A more accurate and fair approach would require sampling based on the pounds produced at the plant, so that testing is proportional to the amount of chicken processed at the plant. In other words, a plant that processes 1,000,000 lbs of chicken a week should test 100 times more often than a plant that processes only 10,000 lbs of chicken a week – that would result in the same amount of testing per pound.
3. The proposed rule requires the same testing for both large integrated operations that get all their birds from growers who are under contract to them, and for small plants that may have hundreds or even thousands of small independent customers ranging from small farmers to backyard homesteaders. It fails to recognize the difference between the two situations in both risk levels and private property rights. USDA should develop rules appropriate to small fee-for-service processors.
4. The proposed rule allows processors to take birds with actionable levels or strains of Salmonella and simply “divert” them to be processed by cooking. That works great for the large operations, which have cooked product operations. But small processors don’t. So the “adulterated” birds from Big Ag operations will simply get cooked and sold in the grocery stores, while the small farmers’ birds will be trashed. USDA needs to provide options for small processors to use off-site facilities and other options for addressing birds with Salmonella.
5. The framework is written to provide USDA the ability to periodically change the level of contamination or strain of Salmonella on finished raw products that it considers adulterated, without going through a formal rule change. This leaves way too much discretion in the hands of USDA to institute a change in the requirements with almost no notice. USDA needs to commit to conducting the full administrative rule-making process before changing what constitutes “adulteration”.
6. The proposed regulation could prevent individuals from being able to get their own birds back even for their own consumption! USDA should allow individuals to choose to retrieve their own birds after disclosure of the test results.
7. Increased production costs for the approximately 30 remaining small-scale fee-for-service slaughter facilities in the U.S. could result in an estimated 40% of facilities closing. If farmers don’t have access to an inspected processor, they likely will have to discontinue their own poultry production for their customers as these facilities are few and far between.
8. Processors that do continue operations after this rule is enacted will definitely have increased costs due to increased testing by FSIS, holding of product, and product potentially being condemned that doesn’t pass the rigorous testing. These costs will, of course, be passed on down to consumers.
LINKS
USDA proposed rule –
USDA comment page –
https://www.regulations.gov/commenton/FSIS-2023-0028-0007
2022 rule proposal action alert –
This bill could harm the small-scale processors. They are not the problem.
Indeed small scale processors are not the problem! Do the right thing.