Last Thursday I had a chance to hear about red meat mobile slaughter units (MSU) firsthand from USDA officials — some represented FSIS and others were more from the economic development side of things. Having them together for one presentation was fantastic because I could ask a variety of questions. Admittedly, I did not plan to attend this meeting; however, I was on a trip to Texas recently and used BWI — I returned to Baltimore the evening before the meeting, so I stuck around MD and went to this meeting the next day.
This is my take on the meeting. Keep in mind, I’m thinking of all of the small processors I deal with as I write this. And that this is for red meat, not poultry. I, for one, think the idea of a mobile poultry unit is a fabulous idea – because there are poultry inspection exemptions. No-go among red meat species, though.
There are many opportunities for farmers to ramp up their profits by selling directly to consumers or restaurants or whomever. Most of this is done for fruits and vegetables, and eggs and poultry to some extent due to a few handy regulatory exemptions. Meat is not as easy to sell directly, especially when there is not a processor in your area. Enter MSU’s and the [potential] economic boon they may be. In some areas they are undoubtedly integral to the success of smaller (and larger!) farms. It certainly spurs rural economic development in many areas, but I have to ask: In all parts of the country? Maybe not? Do we know? Until then, I’ll continue asking questions. There are feasibility studies from Idaho and Nevada available — yet, both are locations where there are virtually zero inspected processors and thus, no competition. Yet, now we have folks interested in mobile units in locations where processors with foundations under their kill floors actually exist (like parts of PA and MD). That needs to be taken into consideration when determining market (market being the farms you are serving) opportunity. There are currently 9 inspected units operating among thousands of other processors nationwide (remember, state inspection standards must equal or exceed federal inspection standards — that’s a point often forgotten). My sincere hope is that we don’t place all of our efforts behind the mobile issue while the stationary establishments who’ve managed to survive get overlooked.
Of course, mobile units are subject to the exact same regulatory requirements as stationary establishments (and for now, I’m sticking only with FSIS-ish stuff — I’m leaving environmental regulations and how some MSU’s are skirting them until later). Meeting the same standards makes complete sense to me yet I bet it doesn’t make sense to others. The incoming inquiries at the info session illustrate exactly why I separate the meat industry from the livestock industry – two different sets of rules and psyches among their members. Some producers in the audience inquired as to whether or not they’d need to test for E. coli. Oh, my – need to read up on food safety regs. Another producer was convinced that putting an animal in a stun box, even for only 5 seconds, would always result in chewy, low quality meat (so, he wants to start a unit and I am guessing he has never been to a plant?) Oh my – need to read up on humane handling regs. Now, realizing that we had some very enthusiastic people about MSU’s at this meeting, I remained true to form and asked a few questions about regulations, including (1) Mobile units will be require to validate their plans? (A: of course … once we know what in-plant validation will entail), (2) What are the implications for the inspected cut and wrap? (A: see below, kinda), and (3) How does one write a Food Defense plan for a MSU? (A: __________, ramblings below). Adding to the confusion, I left with the impression that some of the producers felt they would have to purchase a copy of the CFR every year – that it is the only place where regulatory updates can be found. Oh my, oh me oh my.
The cut and wrap
Sometimes I think MSU’s are to slaughterhouses as temporary classrooms are to schoolhouses (shorthand = MSU : slaughterhouse as FEMA trailer : schoolhouse). Ideally, the MSU’s could be a temporary fix for a bigger problem until the limited local slaughter infrastructure (in some locations) is rectified. After all, MSU’s only accomplish one job: slaughter. What are the implications for a cut and wrap facility? Will there be a new CCP for carcasses incoming from a MSU? Chances are, yes — especially if the carcass ever goes outside. Transferring from the MSU to the stationary facility should involve the reapplication of antimicrobial intervention upon entering the plant. Easy enough, but what about their Food Defense plan? If (rather, when) Food Defense becomes mandatory, might a stationary establishment choose to reject MSU-slaughtered product given then challenges they may face regarding Food Defense? Here’s what I mean…
Last year, FSIS distributed general Food Defense plans and they (bravo!) hope to get as many small and very small establishments in line as possible. Most small and very small plants are doing a stellar job with this. Food Defense really is a big deal. We may not think of it as such … because we’ve not had too many problems with it … yet. (Aside – ever read or seen Midnight In the Garden of Good and Evil? Remember the crazy dude with the fly on a string who said he could wipe out all of Savannah via the water supply? Well, that can be done with food, too.)
Anyway, moving on with the general Food Defense plan that’s been distributed to small and very small plants and work through a few points. Here are some highlights from the document:
- 1.1.a – Plant boundaries are clear and secure to prevent unauthorized entry (for example, fences installed, no trespassing signs posted). Tough for an temporary site on a farm.
- 1.1.c. – Plant perimeter is periodically monitored … What’s the perimeter?
- 2.2.a. – Access to live animals […] is restricted. So, we restrict access to the barn serving as a holding pen?
- 2.2.b – Access to animal handling areas and/or carcass coolers is controlled. Portable corrals, perhaps?
- 2.4.b. – Access to lines that transfer water or ingredients are examined and restricted. Will a farm need a designated water source that’s padlocked when the unit is not there?
- 3.2.c – Non-employees are chaperoned on-site. Would a farmer need to be chaperoned on his own farm when the unit is there? Maybe not if he/she is a co-op member/owner?
- 3.2.d. – Non-employees are restricted to appropriate areas. Ah, the non-employee issue could be resolved if owned by a co-op?
- Attachment A.1. – Given the options outlined, might then it be feasible for a farm to have a designated slaughter location, secured when the MSU is not there?
Back to the stationary cut-and-wrap… If a mobile unit cannot do this, does that violate their supplier (the MSU) might not have an acceptable Food Defense plan?
This is what the existing plants deal with more and more. Why should a MSU be an exception? I am very interested and excited to be involved with this as the situation unfolds and evolves. It’s going to be a challenge!
We’re only at the tip of the iceberg, I think.