By Chris Young, Executive Director
A team of AAMP representatives traveled to Washington D.C. on Tuesday, October 24 to meet with the leadership of the USDA Food Safety and Inspection Service (FSIS) for face-to-face discussion on issues that are important to our members — issues like Humane Handling enforcement; Revised Appendix A & B; Labeling; interventions and testing; and the relationships between inspection personnel and small plants.
It was a highly anticipated day that has been in the planning stages for some time. For the first time in many years, AAMP championed in Washington independently, rather than part of other industry meetings.
The trip began as AAMP’s Outreach Specialist Nelson Gaydos and I traveled to our hotel near the Baltimore Washington International Airport to meet up with the rest of the team who were all flying in that Monday to prepare. The team consisted of three members of the Executive Committee, two industry professionals (both former FSIS employees), Nelson, and myself. Tuesday morning came quickly and we headed for Washington, first by car and then by train into the downtown area. We arrived by Metro train at the Smithsonian station, which was right across the street from the USDA building. As we emerged from the station, we stood with the Washington Monument to our right and the U.S. Capitol to our left.
The first meeting of the day began at 11:00 a.m. with acting FSIS Administrator Paul Kiecker and his leadership team. After brief introductions and a short review of our organization, we began to discuss our concerns and how we could partner with FSIS on some of the issues to ensure the long-term business success of small processors. The priority for our meeting was to let FSIS know that we were willing to partner with them to both educate processors on regulatory requirements and to help facilitate regulatory change that will benefit small processors. We also wanted them to know that AAMP was willing to use our resources to protect our members from the actions of any regulatory agency that we feel targets small processors, either individually or collectively.
Dynamic discussion was had on a number of topics and the hour-long meeting turned into an hour and forty minutes. We were unable to cover everything, but we touched on some really important issues. These issues included:
- Labeling approvals: We discussed the length of time it takes for approvals, as well as the inconsistency in interpreting the regulation between different reviewers. FSIS said they are working on hiring and training of new reviewers. We were given some ideas on label submissions that we will be sharing with all of you that may help in speeding up approvals. We will also work with FSIS on a document that will make it easier to understand the online submission of labels, as well as what is needed to avoid labels being returned for more information.
- PHIS and easier access for small plants: Having each plant on PHIS, which is what FSIS uses to record all inspection duties and information on the plant, would make it easier for plants to appeal NRs and other actions. Everything would be electronic and would eliminate the paper trail and the chance of items getting lost. All information would be able available and everyone would know how long an appeal would take to get response.
- Using imported bison and venison with voluntary inspection: There has been confusion on whether we can use it or not. Before he retired, Deputy Assistant Administrator Dan Englejohn told us that those who were using it could continue until FSIS figured it out due to the lack of domestic meat available. Since he retired, others have not agreed with his decision and we are left with confusion on its use. FSIS will inform us shortly with a clear direction on this matter.
- Humane Handling: We addressed the over enforcement of the regulation and the inconsistency in what happens with a miss-stun. Why would a miss-stun be classified as an egregious act? We spoke of the number of plants discontinuing their slaughter operations and the negative effect that is having on small farmers and how that is a result of the frustration plants have with the regulatory process. FSIS realizes there is a problem and will look at ways to correct it through their district offices.
- Revised Appendix A & B: We informed FSIS about our struggle to understand the need for the revision and the basis for it. We questioned the science behind the new revisions and also the number of sample required for a challenge and then ongoing support. Deputy Assistant Administrator for Field Operations Roberta Wagner says she has been reading the comments and is aware of the concerns. I will be talking with her about our concerns in greater detail. There is no timeline yet as to when FSIS will finalize the guidelines in response to comments. I told FSIS that I have instructed our members to not make changes to their HACCP plans to meet the revised appendix until it is finalized due to the work it takes to validate the changes.
- Relationship between FSIS, inspectors and plants: The last area of discussion was touchy at best. We mentioned perceived intimidation, bullying and retaliation from inspectors. FSIS wants to know the details. We need to provide them with information on situations as they happen and that is why it is important for you to document when an incident takes place and list witnesses to it. I need to present these issues to the district manager and to Washington. We must show them we are serious and we have to hold them accountable. I want small processors to step forward and speak; trust us to have your back.
During this time, we also spoke about the lack of response in some places to appeals. Again, I need specifics on appeals and how long they take. I also addressed the issue of members wanting to either get a grant of inspection or increasing their hours and being told no for various reasons. We were told that FSIS had enough employees and that there should be no reason for a plant to be told they can’t get a grant of inspection. If you are in this process and are having trouble, please let me know.
After our meeting with FSIS, we headed for Capitol Hill where we spent the afternoon between three Congressional offices. Our first meeting was at the office of Congresswoman Vicki Hartzler of Missouri. We have been working with the Congresswoman and her staff on a number of initiatives for a while now and she has been a very helpful member of the House Agriculture Committee. Our second meeting on the Hill was at the office of Congressman Mike Conaway of Texas, chairman of the House Agriculture Committee. We discussed our morning meeting with FSIS and the issues that our members have. Our last meeting of the day was with Congressman Glenn Thompson of Pennsylvania, vice chairman of the House Agriculture Committee. We spent time reviewing our meeting with FSIS and the needs of small processors.
I am pleased with how our meetings went and I think we set a good foundation for future conversations. We must remain active now in reaching out to FSIS, as well as the members of Congress and continue to expand AAMP’s circle of influence inside the beltway.