Is your plant custom-exempt, but lately has seen more of USDA or your state inspection program than you'd like to?  Are inspectors asking you about issues that you thought you'd left behind when you dropped your inspection, and became either custom or retail?  What's the government up to?

In conversations with AAMP members and the FSIS Office of Field Operations in Washington, it seems that right now, more attention is being paid to custom plants.  One reason for this is the ban that's been placed on slaughter of non-ambulatory injured animals -- "downers" -- as a result of the cow with BSE that was found in the US last year.  Under the Meat Inspection Act, adulterated product can't be sold as human food, and downed cattle are considered adulterated.  Under the law, USDA does have the authority to come into custom plants and make sure that basic sanitation is being followed.  They can also see if plants are keeping records of names of the customers for whom they are slaughtering or processing meat.  AAMP has heard that in some locations, inspectors are asking custom operators to notify their customers if inspectors raise any concerns about sanitation in the plant.

It seems that one reason USDA is raising concerns about custom plants is because of the ban on non-ambulatory cattle.  Another is that in some locations, FSIS is visiting those plants less frequently than it used to.  Instead of coming to the plants on a quarterly basis, they may only be coming every two or three years, and now is trying to play "catch up" while overreacting at the same time.  AAMP's Meat Inspection and Governmental Affairs Committee is raising the issue with BIll Smith, in charge of the FSIS Office of Field Operations during its meeting at the AAMP National Convention this month.

Retail Exemption Is a Can of Worms

Another issue that's been a challenge for USDA is retail exemption.  USDA doesn't like to approach the issue because of opposition from the large supermarket chains.  Big packers don't like to get involved because the big supermarkets are their largest customers.  And AAMP has had to treat the issue carefully because many of our members have retail "fronts" or sections to their operations.  Yet many AAMP members operate under tough inspection rules, while their competitors, small retail stores, make the same products and don't face these same regulations that are hard to live with.

The situation is compounded by the fact that "retail exemption" also allows retailers to sell single ingredient meat and poultry products to wholesale accounts, as long as the product was under inspection before the retailer bought it.  The total is about $100,000 per year for meat and poultry products.  The exemption was opened even wider several years ago when USDA said retail stores could sell an unlimited amount  of "pass-through" meat and poultry products containing more than one ingredient, but not further processed.  In fact, USDA can't even decide if breaking down a master container into smaller packages is "pass-through" or "processing."  That's a no-brainer!

Several years ago, the large retail clubs like Costco, BJ's or Sam's Club started selling wholesale, but without inspection.  Anyone else would have been shut down by USDA!  AAMP pressured the government to do something about the situation, but USDA soon stopped inspection, and said that it would investigate complaints lodged by other companies, but the Agency hasn't done anything.  For a long time, AAMP has asked USDA to decide who needs inspection, and how much is needed, then go to Congress and make recommendations.  Because of the great regulatory pressures from USDA, small plants give up inspection, then turn around and do many of the same operations on a retail basis.  Is that making our food safer?