Here is Karen’s well researched response:

OVERVIEW ARTICLE:

http://www.salon.com/food/feature/2010/04/26/usda_testing_end_local_meat/

Personal note: Hi! After reading the above article I started looking around for the letter writing campaign referenced in the last paragraph.  I was disappointed to find nothing easily assessable and nothing really geared toward consumers, it was all for the industry folks.  So I did my homework on the AAMP (American Assoc of Meat Processors – http://aamp.com/Validation.php) and after much reading and talking directly with one of their members, put together a letter for consumers.  My initial strong feelings were to slant the letter toward the evils of large, corporate processers vs. small, local, independent processors…but that’s NOT what this fight is about.  It’s about making sure that our small, local, independent processors are still standing and in business at the end of this!  If not for them, where will we take our local, well-cared for, grass-fed livestock to be processed?!  THANK YOU for your efforts to help save your local processors.

DEADLINE for COMMENTS: June 19, 2010

Definition of terms:

HACCP – (Hazard Analysis and Critical Control Points) is a management system in which food safety is addressed through the analysis and control of biological, chemical, and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product. (SOURCE: ADA.org)

FSIS – Food Safety and Inspection Service

What YOU can do NOW:

OPTION 1:  Contact FSIS via email at:

DraftValidationGuideComments@fsis.usda.gov

Cut and paste the letter (making sure to fill in the highlighted areas and edit as you see/feel fit)

OPTION 2:  Make your changes and send off the hard copy letter to the address at the top

Docket Clerk, FSIS

Room 2-2127

5601 Sunnyside Avenue

Beltsville, MD  20705

Re: Comments – Draft Guidance on HACCP System Validation

Dear Mr. Almanza:

I respectfully submit these comments regarding the Draft Guidance on HACCP System Validation that were publically released on March 19, 2010.

As a consumer of livestock products who depends upon local, small independent meat processors, my concern regarding the process validation in inspected establishments HACCP programs has prompted me to submit these comments.  I am not an industry big-wig; I am only one person who is concerned with the damage that I foresee these new validation requirements causing my local, independent meat processors.  When HACCP was implemented, the meat industry saw a decrease in establishments.  This initiative and new interpretation has the potential to decimate the remaining very small to small establishments, upon which so many Americans, including myself, depend.  There is nothing wrong with the current HACCP system, whereas independent, small processors are concerned – nor is there any reason to believe the extraneous requirements would produce a safer end product.  It has been estimated that the potential cost to validate a processors entire food safety system could easily run upward of $500,000 initially and over $100,000 for ongoing validation.  No food safety problem has been identified to require this shift in agency interpretation of validation; I don’t understand why this is necessary when there is a system in place that is working.  All I see this shift in interpretation accomplishing is:

• Devastating the remaining small meat processors (hinders commerce)
• Large decrease in the variety of products available
• Discouraging the introduction of new products, therefore reducing the number of employees (increased unemployment)
• Increasing the cost of production, therefore increasing what I have to pay

None of these sound like they would be for the good of the American consumer.  I know, believe in and trust my local meat processors; therefore,   I respectfully request that the Draft Guidance on HACCP System Validation be revised to clearly state that no in-plant microbial testing is required when an establishment is following the long-standing, safe processes of HACCP.

I appreciate the chance to comment on the Draft Guidance on HACCP System Validation.  Thank you for your time and consideration.

Sincerely,

(Name and Address)

cc: [Your State Legislators- Congressmen and Senators]

[The Small Business Administration]

[Your State Farm Bureau]

[Your State Beef and Pork Council]

——————————————————————————————————————-

Find your Representative:

https://writerep.house.gov/writerep/welcome.shtml

Find your Senator:

http://www.senate.gov/general/contact_information/senators_cfm.cfm

Find your State Farm Bureau:

http://www.fb.org/index.php?fuseaction=newsroom.statefbs

Find your State Beef Council:

http://www.beefusa.org/affiFederationofStateBeefCouncils.aspx

Find your State Pork Council:

http://www.nppc.org/aboutus/stateassociations.htm

FURTHER ACTION YOU CAN TAKE:

Please also contact the Small Business Administration Ombudsman, which offers the opportunity to submit online comments on regulatory unfairness for small business. The website is:

http://web.sba.gov/nocms/client/dsp_welcome.cfm

Instructions:  (unblock pop-ups)

Organization Type: SELECT “Small Business”

Federal Agency Name: USDA

Agency Contact person:  Mr. Almanza

Agency Office/Division:  FSIS

Click “No”

ENTER:  AAMP

COMMENT:

I am writing re: HACCP System Validation for Meat Processors. When HACCP was implemented, the meat industry saw a decrease in establishments. The current initiative and new interpretation has the potential to decimate the remaining very small to small meat processing establishments. If the interpretation goes through as it is currently structured, it will most definitely be a hindrance to commerce, will decrease the variety of products available and discourage introduction of new products. This will in turn, reduce the number of employees needed and increase unemployment. It will also increase the cost of production, therefore increasing the cost I will have to pay. All of these factors alone represent unfairness toward small processors, when adding the financial burden (initially upwards of $500,000 and $150,000+ for ongoing verification) it surely must be regulatory unfairness for small businesses.  Thank you for your time and attention to this important matter.

OR you can send them a copy of your letter to FSIS/Mr. Almanza via regular mail at:

U.S. Small Business Administration

409 3rd Street, SW

Washington, DC 20416

5/7/10 - Opportunity to Give Input on AFRI RFA: The USDA’s National Institute of Food and Agriculture (NIFA) is accepting public comments on its Agriculture and Food Research Initiative

(AFRI) to help guide the development of the 2011 Requests for Applications (RFAs).

5/5/10 – USDA Seeking Public Input on Animal Disease Traceability: The USDA Animal and Plant Health Inspection Service (APHIS) announced the first three of a series of public meetings where stakeholders can offer input on the framework for a new APHIS rule on animal disease traceability.

Congressional News

5/7/10 – Food Safety Bill Still Pending in the Senate: S. 510, the Food Safety Modernization Act, is expected to be considered by the Senate right after the Memorial Day recess, according to Senate staff.   The bill is the first significant effort to increase food safety in decades and gives the Food and Drug Administration (FDA) new enforcement authority over industry and will also have a significant impact on farmers.

5/5/10 – Organizations Urge Congress to Fund Farm to School: This Monday, May 3, NSAC and 40 other national agriculture, health, and food business organizations delivered a letter to House and Senate Congressional leaders urging them to include $50 million in mandatory funding for programs linking farmers with local schools as part of the 2010 Child Nutrition Act reauthorization.

The Maine Farm Business Loan Fund 

The Carrot Project is pleased to announce a collaboration with Coastal Enterprises, Inc., The Maine Farm Business Loan Fund is for small and midsized farms using sustainable or organic practices and serving markets within Maine or in nearby states. Funds can be used for working capital or capital needs for production or value-added enterprises. On-farm, value-added enterprises will be given preference. Loans will be for amounts up to $35,000 and for terms of 1–5 years. Learn more.

Strolling of the Heifers Microloan Fund Expanded to Eastern Massachusetts

In partnership with MassDevelopment, we have launched the MassDevelopment/Strolling of the Heifers Small Farm Loan Fund.This expansion allows us to offer the microloan fund to all farmers in Massachusetts. MassDevelopment will provide loans secured by  donations from Green Mountain Coffee Roasters and proceeds from a 5% Day from the Whole Foods Markets in Cambridge. Thank you to our Boston-area volunteers for your help with the 5% Day and to our other valued supporters of this work.  Learn more.

Brown Bag Conference Call: Small Farms in a Changing Credit Landscape

John Moukad, an expert in community development finance and now a member of The Carrot Project Advisory Board, recently completed a report describing the changes in the credit market in recent years, and how these changes have negatively impacted small farmers. It also describes the capacity of small farmers as borrowers and makes recommendations. The Carrot Project will host a Brown Bag Conference to discuss the report on Friday, May 14th at 12:15 pm. If you would like to participate, please register or learn more under Reports on our program page.

The Carrot Project Works Because of You

The Carrot Project works collaboratively to help close financing gaps for small and midsized farms. Our work would be impossible without our partners — donors, investors, lenders, other non-profit organizations, and volunteers. If you haven’t  already, please consider joining this group of dedicated people who make our work possible, by making a tax-deductible donation. Thank you! Make a donation.

The FRFA sign-on letter in support of these amendments now has 114 signatories, and  continue adding until the bill goes to the floor.  If your organization wants to sign on, please email Judith McGeary, FARFA, at jmcgeary@att.net or Margie MacDonald, WORC, at mmacdonald@worc.org

State, Federal Officials Seek Insight on Fresh Produce Processing, Handling

HARRISBURG, Pa., April 27 /PRNewswire-USNewswire/ — Pennsylvania produce growers and food processors are invited to share their input on the U.S. Food and Drug Administration’s new produce handling rule at a May 13 listening session in Harrisburg, Agriculture Secretary Russell C. Redding said today.

The session will be held from 9 a.m. – noon at the Pennsylvania Farm Show Complex & Expo Center.

“As leaders in producing a variety of agricultural products, Pennsylvania produce growers and food processors are in position to offer valuable insight in national food safety discussions,” said Redding. “It is important that our industry take advantage of the opportunity to help shape federal policy regarding production and processing activities.

“By hosting this listening session, Pennsylvania continues to be a leader in the production of a safe, abundant food supply.”

Redding, state Health Secretary Everette James and FDA Deputy Commissioner for Foods Michael R. Taylor will attend to hear concerns and answer questions. The listening session will also feature presentations by produce industry professionals.

The listening session is intended to ensure Pennsylvania’s agriculture and food production sectors and public health partners keep pace with changing federal regulations.

“Locally grown produce is an essential component of a healthy diet, but outbreaks have shown it can also be a source for food borne illness,” said James. “It’s important for Pennsylvania farmers to provide the FDA with input to ensure that new food safety regulations protect their businesses and the public health.”

Redding and James co-chair the Governor’s Food Safety Council, a unique group of agriculture, health and emergency management professionals convened by Governor Rendell in 2009. The council advises the Governor on developing and implementing food safety, defense protocols and best practices in the state.

The listening session is open to the public and registration is requested. To register, contact Jared Grissinger at 717-705-9513 or jgrissinge@state.pa.us

Media contacts:

Nicole L. C. Bucher, Agriculture; 717-787-5085; Claudine Battisti, Health; 717-787-1783

http://www.agriculture.state.pa.us

This Wednesday’s hearing in the House Agriculture Committee marked the two year countdown to the next Farm Bill.  On the House side, the next step will be field hearings scheduled over the next few months, a hiatus during election season, then formal hearings in May 2011.

It’s not too early to start thinking about how you can help advocate for a better Farm Bill in 2012.  If you’re a farmer, consider checking out our new Farmer and Rancher Resources for the Media (FARM) Toolkit where you can find tools to tell your farm story, or sign up for the FARM database where we can connect you with media inquiries relevant to your operation.  Your voice is important in shaping policy.

USDA News

4/23/10 – Conservation Stewardship Program Update

This post provides some basic updates on the status of the nearly completed 2009 sign-up as well as the upcoming 2010 version of the Conservation Stewardship Program (CSP).

4/23/10 – Cooperative Conservation Partnership Initiative Applications Open

USDA’s Natural Resources Conservation Service (NRCS) is taking applications for the Cooperative Conservation Partnership Initiative (CCPI) until May 27, 2010.  The full Request for Proposals can be found here.

4/23/10 – Call for Nominations to Minority Farmer Advisory Committee

Yesterday’s Federal Register announced the call for nominations to the Minority Farmer Advisory Committee, organized by the Office of Advocacy and Outreach at the USDA.

4/20/10 – Proposed Rule Defines Geographic Preference Option for Child Nutrition

In an important step forward for local purchasing by federal nutrition programs, the USDA today released a proposed rule on a geographic preference option that would allow institutions who receive federal Child Nutrition funds to give extra points to unprocessed locally grown or raised products in the procurement process.

4/20/10 – Research Grants Drilldown: Organic Research within AFRI

Adapted from the SCOAR (Scientific Congress on Organic Agricultural Research) Bulletin. Read the original Bulletin here. The word “organic” appears only twice within the hundreds of pages of the AFRI RFA; however, opportunities may exist for organic researchers to compete for these funds. Several program areas offer multi-million dollar funding for projects of up to five years.

Congressional News

4/23/10 – And We’re Off: Farm Bill 2012

Ranking Member Frank Lucas (R-OK) described Wednesday’s House Agriculture Committee Hearing on the Farm Bill as “two-and-a-half hours to kick off two-and-a-half years.” The hearing was the first of Committee Chairman Collin Peterson’s (D-MN) meetings to get a head start on planning for the next Farm Bill, scheduled for completion in 2012.

Other News and Resources

4/23/10 – Choices Magazine Unpacks Local Food

The latest issue of Choices Magazine, a publication of the Agricultural and Applied Economics Association, features seven articles centered around perspectives, prospects, and policy involved with local food systems.

4/21/10 – NSAC Announces Farm and Agriculture Resources for the Media (FARM)

We’re excited to announce the launch of FARM (Farm & Agriculture Resources for Media), a NSAC project that champions the voice of sustainable agriculture by providing media training and tools for farmers.  FARM includes a new three-part NSAC toolkit that helps  farmers share their personal and authentic story and strengthen their media connections.

4/20/10 – Anti-CAFO Activist Wins Goldman Environmental Prize

NSAC offers heartfelt congratulations to Lynn Henning, a southern Michigan farmer who has been awarded the 2010 Goldman Environmental Prize for U.S. grassroots environmental activism.  The Prize is recognition of Lynn’s unstinting work in exposing the impacts of pollution from large-scale concentrated animal feeding operations (CAFOs), especially mega-dairies, in her southern Michigan community and across the upper Midwest.

With Congress back in session, wheels began turning on the Senate food safety bill, S510. On Wednesday, we reported on a number of important improvements that have been added to the manager’s amendment that will support small and mid-scale farmers, local and regional food systems, conservation, and organic farming. Though the timing of the bill has been pushed back to make way for a debate on finance reform, NSAC intends to continue to maintain these improvements throughout the process. Thank you to all who flew in for a visit or made a call — your voice has been heard!

As always, to access the full articles and leave comments, visit our “Something to Crow About” Blog.

USDA News

4/13/10 - Research Grants Drilldown: Conventional Breeding and Climate Adaptation

The overarching goal of the RFA is to reduce use of energy, nitrogen, fertilizer, and water by ten percent and increase carbon sequestration by fifteen percent by the year 2030.  While this goal focuses on mitigation, most of the programs in the RFA focus on strategies for climate change adaptation.

Congressional News

4/16/10 – Senators Chide Administration on “Actively Engaged”

A bi-partisan group of Senators sent a letter to President Obama on Tuesday criticizing the Administration’s loose interpretation of “active personal management” in the United States Department of Agriculture’s (USDA) final rule on farm program payment limitations, released on January 7, 2010.

4/14/10 - Senate Food Safety Bill Includes Improvements That Support Farmers

In most areas of the legislation, sustainable agriculture and family farm groups think the Senate bill is a very significant improvement over the companion bill passed by the House of Representatives (HR 2749) last year.   If the Senate passes the bill next week or soon thereafter, it will head to a conference committee to work out differences between the two bills.

Contact: Office of Communications (202) 720-4623

WASHINGTON, April 16, 2010 – Agriculture Secretary Tom Vilsack today invited public comment on several proposed rules designed to increase the production of advanced biofuels and the development of biorefineries. The programs are authorized under the Food, Conservation and Energy Act of 2008 (The Farm Bill).

“We view these proposed rules as part of the strategy to help meet President Obama’s goal to accelerate the commercial production of advanced biofuels and create a viable alternative fuels industry,” Vilsack said.

The proposed rules affect the following three renewable energy programs administered by USDA Rural Development:

Biorefinery Assistance Program – The proposed rule will establish guaranteed loan regulations to develop and construct commercial-scale biorefineries and to retrofit existing facilities using an eligible technology to develop advanced biofuels. Under the proposed rule, USDA Rural Development proposes a rolling application process for the consideration of loan guarantee requests. The Agency will consider a technology that is being adopted in a viable commercial-scale operation that produces advanced biofuels.

Under the proposed rule, the maximum loan amount will be $250 million; there is no minimum amount. The amount of a loan guarantee for a project will not exceed 80 percent of the total eligible project costs.

Repowering Assistance Payments – USDA is proposing to make payments to eligible biorefineries to install new systems that encourage renewable biomass energy use and replace fossil fuels. Under the proposed rule, USDA Rural Development will propose procedures for eligible biorefineries to receive a payment equal to 50 percent of the cost of installing eligible systems, up to $5 million, whichever is less. There is no minimum payment amount. The initial payment would be a percentage of the cost of installing eligible systems. The remaining payment would be based on the amount of energy produced from renewable biomass.

Bioenergy Program for Advanced Biofuels – USDA Rural Development is proposing to establish a payment program for eligible producers of advanced biofuels. To be eligible for payments, advanced biofuels must be produced from renewable biomass, excluding corn kernel starch. USDA would enter into contracts with advanced biofuels producers to support and ensure an expanding production of advanced biofuels.

Additional information on the proposed rules and instructions on how the public can offer comments are available in the April 16, 2010 Federal Register: http://www.access.gpo.gov/su_docs/aces/fr-cont.html#Rural%20Business-Cooperative%20Service

USDA, through its Rural Development mission area, administers and manages more than 40 housing, business and community infrastructure and facility programs through a network of 6,100 employees located in 500 national, state and local offices. These programs are designed to improve the economic stability of rural communities, businesses, residents, farmers and ranchers and improve the quality of life in rural America. Rural Development has an existing portfolio of more than $132 billion in loans and loan guarantees.

Contact: Andre Kok (202) 720-9733; Andre.Kok@wdc.usda.gov

WASHINGTON, April 15, 2010 – USDA announced today that it will accept applications for the Emergency Assistance for Livestock, Honeybees and Farm-Raised Fish Program (ELAP) for losses that took place in calendar years 2008 and 2009. ELAP sign-up ended on Dec.10, 2009, for 2008 losses and on Feb. 1, 2010, for 2009 losses. However, because of changes to program eligibility provisions, the Farm Service Agency (FSA) is accepting late-filed applications for 2008 and 2009 livestock, honeybees, and/or farm-raised fish losses through May 5, 2010.

ELAP, authorized in the 2008 Farm Bill, provides emergency assistance to eligible producers of livestock, honeybees and farm-raised fish that have losses due to disease, adverse weather or other conditions, including losses due to blizzards and wildfires. ELAP assistance is for losses not covered under other Supplemental Agricultural Disaster Assistance programs established by the 2008 Farm Bill, specifically the Livestock Forage Disaster Program, the Livestock Indemnity Program and the Supplemental Revenue Assistance Payments Program. ELAP is being implemented to fill in the gap and provide assistance under other conditions determined to be appropriate.

ELAP eligibility provisions have been amended for both honeybee and farm-raised fish producers. The modifications include allowing honeybee and farm-raised fish producers who did not replace their honeybees or fish that were lost due to a natural disaster to be eligible for ELAP payments based on the fair market value of the honeybees or fish that were lost. In addition, the requirements to document losses for honeybee producers who suffered losses due to Colony Collapse Disorder (CCD) were modified to allow documentation by an independent third party for losses in 2010 through Sept. 31, 2011. Producers can self certify losses due to CCD for 2008 and 2009.

For more information or to apply for ELAP and other USDA Farm Service Agency disaster assistance programs, please visit your FSA county office or www.fsa.usda.gov.

Visit NEFOOD! at: http://www.nefood.org/?xg_source=msg_mes_network