Thank you for taking the time to stay informed about important proposed legislation that will affect all small farms and consumers interested in having access to local foods. Here’s what’s happening…

The longer explanation…

The FSIS (Food Safety Inspection Service) is one of the federal governing agencies for meat processing in the United States, and they are REALLY good at coming up with rules that harm small-scale processors, in a rather misguided attempt to regulate industrial-scale processors, but often these new rules don’t improve food safety at all. They’ve done it again, and we need your help to persuade them that they are barking up the wrong tree with this new proposed rule.

They put the MOST WEIGHT on consumers’ comments, so that’s why I’m asking you to take a bit of time to understand this issue, and if you agree, please comment on our behalf.

According to my sources, there are only 30 privately-owned processing facilities in the entire country that will process individual farms’ chickens for sale. The rest are owned by companies like Tyson, Pilgrims, and Purdue. This proposed rule may cause insurance and operating costs to rise so much for the privately owned processors, that as many as 40% may close as a direct result. This is a terrifying prospect considering that the big bottleneck in the direct-sales pastured-poultry world (that’s what we do) is finding a processor so farmers can sell their poultry legally. All consumers who enjoy pastured poultry raised by small farms are at risk of losing access to this nourishing, wholesome, and delicious food.

Low volume processors are not the issue when it comes to food safety. They have an incredible track record for safety and quality, and their products are inherently more traceable than industrially-produced chicken, and they need our help to be protected from heavy regulations that will stifle them.

In fact, within the past five years, there has been an initiative to reduce salmonella numbers in raw poultry, which was wildly successful and reduced presence of salmonella in raw poultry by as much as 50% on a national scale. However, during the same time, the frequency of foodborne illness caused by salmonella from poultry was not reduced AT ALL. This strongly suggests that reducing salmonella numbers more in raw poultry would simply not have the desired effect, and yet it would produce a tremendous cost burden on small-scale farmers and processors that could be detrimental to their existence. We need diversity and resiliance, not more meaningless testing, in our food system. 

Here is what’s happening so you understand the issues:

Someone else has to cook your chicken for it to be safe?

FSIS wants to declare certain levels and/or serotypes of Salmonella detected on raw poultry as adulterants (they are currently considered pathogens which are destroyed during typical cooking). We have all grown up knowing that you have to fully cook raw poultry in order to destroy pathogens.

Under the new rule, “Adulterated” poultry could not be sold to consumers without first being turned into cooked products by the processors, even though thorough cooking by consumers would render them harmless. If cooking at the processing facility is not possible, the poultry must be destroyed. FSIS is basically saying that you, as a consumer, are not capable of safely cooking your own chicken should a certain serotype of salmonella, even in most minute amounts, show up during testing.

Jerica’s additional thoughts… There are (at least) two faulty assumptions here: 1. It is assumed that if a processor could manage to cook this adulterated chicken, that the cooked chicken couldn’t get contaminated somehow. But don’t we hear about recalls ALL THE TIME of pre-cooked meats, peanut butter, etc? This won’t eliminate foodborne illness at all. It will only make local food cost more. And 2. One must ask… how are we testing? Are we testing all individual chickens processed in one day? That would be extremely costly and time-consuming. But if we are only testing a randomly selected individual chicken, it’s possible that if contamination has occurred, it could just be from that single chicken. So are we condemning the whole batch over a single chicken because it’s impractical to test every single chicken? And yet not a single one of those chickens is going to be consumed raw. So where is the threat?

Increased cost of processing

Even if a processor never has detectable salmonella show up during testing, the cost burden in order to conduct tests, hold product while awaiting test results, and possibly dispose of condemned product, will increase the retail price of poultry.

Property Rights Infringement

Very small fee-for-service processors that do not have access to cooking facilities would be left to condemn the “adulterated” poultry, regardless of ownership. This is true even of a homesteader’s own birds produced only for home consumption, should a homesteader decide to hire out processing.

Or perhaps a farmer grows birds to sell, but if they fail this new highly rigorous testing, they cannot bring them home to use for personal consumption. They are simply required to be destroyed. This could ruin many small farms forever.

Reduced Access to Chemical-Free Poultry

In order to meet the requirements set forth in the Proposed Testing program, plants will need to add multiple chemical intervention steps to reduce and eliminate the natural biological bacteria load on the poultry carcasses. Many of OUR customers would prefer to simply cook their poultry thoroughly to prevent foodborne illness, rather than douse them with toxic chemicals in order to remove the same bacterial load that would be as effectively removed by simple cooking. 

Threat to Local Food and National Food Security

Loss of both farms and processors will undoubtedly occur with the enactment of this Proposed Rule which is not in the benefit of our national security. Just five years ago, every American realized how vitally important every local farmer and processor was. They feed our nation every day, but especially in times of crises. 

Here is what we are asking you to do:

You are not required to submit an email address when commenting. You can even submit anonymously if desired. Please consider submitting a comment similar to the following. Unique comments are most effective, so feel free to add your own thoughts or use ours as a framework:

As a consumer of locally-raised and slaughtered poultry, I am against the Proposed Salmonella Framework on Raw Poultry. This proposed solution is not effective at addressing the concerns of consumers for safe or clean poultry. Reducing salmonella numbers in raw poultry has not been shown to be an effective strategy for reducing foodborne illness. Additionally, increasing testing requirements will disproportionately burden small-scale processors and put farmers and consumers at risk of losing access to wholesome poultry purchased directly from the farmer, which has an excellent safety track record. Small-scale processing operations should be exempt from new testing and chemical sanitation rules, as the existing regulations are effective and not unduly burdensome, and consumers are generally aware that by fully cooking poultry products and observing good food handling practices in the home kitchen, poultry products are rendered safe and wholesome for consumption. 

https://www.regulations.gov/document/FSIS-2023-0028-0007

Simply click the blue “Comment” button near the top left of the page and complete the form, then click “Submit Comment.”