Small Meat Processors & Regulatory Burden – NMPAN Evaluates The Impact of Federal Agency Oversight

Author: Rebecca Thistlethwaite Director, Niche Meat Processor Assistance Network, Oregon State University 

Publication: Fall 2021

The Niche Meat Processor Assistance Network, a project of the Center for Small Farms, was contracted to write an external evaluation of how USDA Food Safety and Inspection Services (FSIS) provides support and oversight for the small and very small meat processing establishments that they inspect. NMPAN submitted the final report to FSIS in December 2020 and FSIS published it to their website ( publications/2020-report-guidance-and-outreach- small-and-very-small-meat-processors) in June of 2021.

This report (https://www.fsis. media_file/2021-06/2020 Report on Small-Very Small Processor Outreach.pdf ), was authorized by Congress in the 2018 Farm Bill. Its purpose was to assess the USDA Food Safety and Inspection Service’s (FSIS) interactions with small and very small meat processors in three main areas: outreach, information tools, and responsiveness. Small and very small meat processors are very different from large processors in fundamental ways, not just their scale of operation. These differences have implications for the effectiveness of FSIS communication with SVS plants.

According to the Meat and Poultry Inspection Directory, of all inspected meat slaughter and processing establishments, 6.5% are large-scale with over 500 employees, 39% are small-scale with 10-499 employees, and 55% are very small in scale with less than 10 employees. Thus, the vast majority of establishments that FSIS inspects are considered small or very small (SVS) processors.

FSIS has released some new demographic datasets that help illustrate the vast differences in slaughter and processing volumes at plants of various sizes (Tables 1-2). Most SVS plants fall into the lowest three volume brackets for slaughter and processing. For slaughter, 66% of the 1,091 of plants that slaughter livestock or poultry are in the lowest three volume brackets of animal slaughter establishments. For processing, 73% of 5,465 plants are in the
lowest three volume brackets of meat processing establishments. Once again, the majority of meat processing plants that FSIS inspects are small volume establishments. As their main constituency, it is important that they are responsive to their needs. That is the main impetus for the NMPAN report.

Assessments of outreach, information tools, and responsiveness were conducted by compiling feedback from SVS processors about their experiences with the FSIS and comparing those experiences to FSIS policy and its recent efforts in the relevant topic areas. Processor feedback was collected via round table discussions, surveys, interviews, and key informant reviews of early versions of this report.

One interesting part of the report was the special case study regarding humane handling violations in small facilities. It is an area that small plants struggle with, particularly around the issue of mis-stuns (not rendering the animal senseless on the first knock or shot). Through research, NMPAN found out that 98.2% of all humane handling violations were received by SVS plants, even though they make up 93.5% of inspected establishments. Small plants were also more likely to be shut down for more days than large plants, with a median number of 3 days as compared to 1 day for large plants. This is disparity is a frequent area of concern for SVS plants and one that this report highlighted extensively.

Key recommendations from the report include:

  • Continuing to find ways for small and very small processors to interact and share experiences directly with high- level FSIS leadership.
  • Standardizing the information provided by FSIS across plat forms, documents, and personnel to eliminate conflicting or confusing information.
  • Studying inspection decisions and enforcement actions across circuits, districts, and inspectors to identify potential inconsistencies or biases.
  • Frequently updating information sources to eliminate out -of -date information.
  • Upgrading information access tools.
  • Providing explicit benchmarks and procedural guidance for meeting regulatory requirements with the time and financial constraints of SVS plants in mind.
  • Closely examining humane handling regulatory procedures for small and very small plants.

According to the FSIS website, they have made an effort in recent years to collect small and very small processor feedback through roundtable listening sessions, something that NMPAN has been a lead organizer of (along with the National Sustainable Agriculture Coalition). Also, in the last 8 months of 2021, FSIS has made new guidance documents and webinar resources targeted to issues those small plants face. These efforts are appreciated, and we at NMPAN (along with our members) hope that they represent a renewed effort by FSIS to connect with their small and very small plant stakeholders that will continue well into the future.

To download the full report, please go here: https:// file/2021-06/2020%20Report%20on%20Small- Very%20Small%20Processor%20Outreach.pdf