
Act Now to Protect Your Access to Pastured Poultry: Tell USDA to Stop Hurting Small Processors
Here’s What is Happening:
What does this mean for you? Let’s break it down:
THIS IS THE TIME TO ACT.
Here's What to Do:
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P.S. This is my comment on the rule proposal:
Dear USDA FSIS Review Team,
I am writing to express my opposition to the proposed rule regarding Salmonella in raw poultry products. While food safety is a critical goal, this rule represents an unnecessary regulatory overreach that fails to address the root causes of Salmonella-related illnesses and unfairly burdens small-scale poultry processors and the farmers who depend on them. This proposal does not provide clear evidence that the measures it mandates will improve public health outcomes, yet it poses significant risks to the viability of small processors and local food systems.
Addressing Salmonella Without Overregulation
USDA’s own data acknowledges a significant reduction in the prevalence of Salmonella in poultry products due to existing testing and control programs. Despite these reductions, human illnesses from Salmonella have not decreased. This disconnect indicates that the problem lies elsewhere—possibly with consumer handling and preparation practices—not with poultry processing itself. Introducing stricter testing and regulation, especially in the form of unenforceable or vague guidance, is unlikely to address this disconnect effectively.
Instead of imposing additional regulations, USDA should focus on public education and outreach to improve safe handling and cooking practices. Better consumer education would achieve meaningful reductions in Salmonella illnesses without penalizing processors or farmers who already implement rigorous food safety measures.
Impact on Small Processors and Local Food Systems
The proposed rule’s uniform application across all processors fails to account for the realities of small-scale operations. Unlike industrial processors, small processors serve diverse, independent farmers and typically process significantly smaller volumes of poultry. Imposing lot testing requirements without scaling them to production levels would force small processors to test a disproportionately high percentage of their product, creating an unfair and unnecessary financial burden.
This burden could drive the remaining small processors out of business, leaving small farmers without access to essential processing services. Without these processors, farmers like me will lose the ability to provide safe, locally sourced poultry to our communities. Local food systems, which are a cornerstone of food security and sustainability, would suffer as a result.
Flawed Approach to Adulteration
Declaring certain strains or levels of Salmonella as “adulterants” in raw poultry products ignores the nature of raw food products and the well-established role of proper cooking in eliminating pathogens. This approach penalizes processors for conditions beyond their control, while allowing large-scale operations to divert products for cooking. Small processors, who lack access to such facilities, would have no viable recourse.
Lack of Justification and Overreach
This rule gives USDA broad authority to adjust contamination thresholds and strains of concern without undergoing a formal rulemaking process. Such discretion introduces uncertainty for small processors and undermines their ability to plan for compliance. The lack of clear scientific evidence that these measures will reduce illnesses further underscores the unnecessary nature of this rule.
A Better Path Forward
Instead of creating unnecessary regulations, USDA should:
1. Focus on public education about safe handling and cooking of poultry products.
2. Support small processors by scaling testing requirements to production levels.
3. Ensure that any future changes to Salmonella standards go through formal rulemaking.
4. Provide non-regulatory support for pre-harvest interventions, which are better suited to reducing contamination.
This proposed rule, as it stands, is not only unnecessary but counterproductive. It threatens small processors and farmers while failing to address the root causes of Salmonella illnesses. I urge USDA to reconsider this rule and focus on strategies that genuinely improve public health without jeopardizing the future of small-scale poultry processing and local food systems.
Thank you for your time and attention to this critical issue.
Sincerely,
Jennifer Bajema
3 comments
Does the 20,000-bird exemption which is part of the Poultry Products Inspection Act (Public Law 90-492) which allows producers to slaughter and process up to 20,000 birds per year on their own premises without Federal inspection apply to your operation. Or, do you exceed the 20,000 bird exemption?
“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. Please go back and listen to the stakeholder comments to draft a new solution that allows consumers to maintain private ownership of their poultry and ensures access to non-chemically sterilized poultry if desired”
I oppose the USDA’s Proposed Salmonella Framework on Raw Poultry because it unfairly burdens small processors while failing to address the root causes of illnesses. USDA data shows Salmonella levels in poultry have decreased, yet illnesses remain unchanged. Instead, USDA should focus on consumer education, pre-harvest improvements, and scale-appropriate solutions to protect small processors and local food systems.