By DOUG SCHMITZ
Iowa Correspondent

DES MOINES, Iowa — Iowa Agriculture Secretary Bill Northey is still waiting to hear back from USDA Secretary Tom Vilsack a month after expressing serious concerns in a letter over newly-proposed meat inspection guidelines Northey said could possibly force America’s small meat lockers out of business for good.

“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 told Vilsack in his April 13 letter.

“The USDA has already agreed to extend the comment period, and I hope they will use that time to work with the small and very small processors across the nation to find a compromise,” he added.
Issued on March 19, the proposed rules – called Draft Guidance: Hazard Analysis Critical Control Points (HACCP) Systems Validations – were released by the USDA’s Food Safety and Inspection Service (FSIS), which Northey said is reinterpreting current food safety laws already in place.

Under the new guidelines, U.S. meat processors would be required to begin testing up to 13 samples of meat before and after the products have been washed with acid and heated, along with implementing other food safety methods, each time before they process to ensure all harmful bacteria are eradicated.

Northey said these proposed rules would significantly saddle small, rural meat processors with exorbitant testing costs, as well as have little, if any, benefits to food safety because of their redundancy of currently-enforced laws. “HACCP was designed to prevent, reduce or eliminate food safety hazards at Critical Control Points, and requires processors to document their food safety procedures,” he said. “These processes have already proven that the implementation of HACCP is effective in making our meat supply the safest in the world.”

If enacted, the new federal guidelines would impact any processor who sells meat to the general public in its store, to restaurants or to grocery stores, Northey said. But the rules won’t affect custom butchers who slaughter and process for their customers.

In addition to these costly new requirements, Northey said the FSIS has also indicated that it would require that all pre-requisite programs, such as plant sanitation, cooler-temperature monitoring and pest control programs to be validated under the same protocols outlined in the draft guidance. “These programs are numerous and validating these will also add substantial new costs,” he said. “The manner in which this major regulatory re-interpretation was undertaken is also a cause of concern.”

The American Assoc. of Meat Processors (AAMP), who represents the nation’s small meat lockers, estimated that the initial cost for extensive testing could run as high as $12,000 per product line and subsequently $3,600 a year – especially since small meat lockers frequently process a variety of items from different types of meat.
Since the draft guidance is considered a re-interpretation and not a new rule, Northey said it doesn’t follow the same rule-making process, nor does it allow for the same scrutiny as typical regulatory changes.

“In particular, there is no opportunity to have this new interpretation reviewed by the Small Business Administration to determine the financial impact on small businesses,” he said.
Northey said because small meat plants are a vital part of many rural communities and their economies, this re-interpretation would impact their respective abilities to stay in business and continue serving as a vital link between farmers and consumers.
“I commend your efforts through the “Know Your Farmer, Know Your Food” initiative to support small, local food producers,” Northey told Vilsack, “but I worry that these proposed guidelines could significantly set back the goals of that initiative.”

To date, 71 small meat lockers in Iowa would be affected by the new testing requirements, according to the Iowa Department of Agriculture and Land Stewardship.

The AAMP said the comment period has been extended to June 19 – 60 days from the original date of April 19.

After June 19, the FSIS will begin its required review on the comments received and its process of deciding how it will proceed with validating HACCP systems.