Act Now to Protect Your Access to Pastured Poultry: Tell USDA to Stop Hurting Small Processors - Rebel Pastures

Act Now to Protect Your Access to Pastured Poultry: Tell USDA to Stop Hurting Small Processors

I’m reaching out today with an urgent message that directly impacts your access to pastured poultry. Because we are members of the American Pastured Poultry Producers Association (APPPA), we have been made aware of a new rule making it's way down the pipeline. The USDA’s Food Safety Inspection Service (FSIS) has proposed a new Salmonella Framework for raw poultry that could have far-reaching, unintentional (or intentional🤔) consequences for small-scale farmers, processors, and consumers like you.
 

Here’s What is Happening: 

FSIS is considering declaring certain levels or types of Salmonella in raw poultry as “adulterants.” Poultry labeled as such couldn’t be sold to consumers without first being cooked by processors—even though cooking at home would make it safe. This rule would disproportionately hurt small-scale fee-for-service processors who don’t have access to cooking facilities, leaving them to condemn “adulterated” poultry entirely.
 
 

What does this mean for you? Let’s break it down:

👎 Loss of Local Access: Up to 40% of small USDA-certified processing facilities could close due to increased costs, leaving farmers without a way to process their birds. Without processors, many farmers would have to stop raising poultry altogether.
 
👎 Higher Prices: For the processors that manage to stay open, costs will skyrocket due to additional testing and product holds. These expenses will inevitably trickle down to consumers.
 
👎 Loss of Food Sovereignty: The USDA would gain authority to condemn birds, even if they’re privately owned and meant only for home consumption.
 
👎 Chemical-Heavy Processing: Meeting the new testing requirements would force plants to use more chemical interventions, reducing access to clean, un-sprayed poultry.
 
👎 Weakened Food Security: Fewer farms and processors means a less resilient food system. As we learned during recent crises, local farmers and processors are essential to keeping our nation fed.
 
 

THIS IS THE TIME TO ACT.

Friends, these are the rules and laws that slowly chip away at your freedom to choose. On first glance, this law may appear to protect consumers, but in reality it unequally puts a huge burden on small, local USDA processors.
The TRUTH of the matter is small-scale processors and farmers are not the source of widespread Salmonella outbreaks and despite having more regulation than ever before, people are becoming sick more than ever before. MORE REGULATION DOES NOT EQUAL HEALTHIER OUTCOMES.
FSIS values consumer input even more so than farmers and processors, and now is the time to speak up! The deadline for public comments is Friday, January 17, 2025.
 
 

Here's What to Do:

Go here to submit a comment: Regulations.gov
 
You can submit a personal message, or feel free to copy and paste this comment:
 
“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”
 
👉 Submitting a comment is easy and quick.
👉 You do not need to leave an email and can submit comments anonymously.
👉 If you choose to leave an email, you can opt to receive an email confirmation with a tracking number.
 
 

Want to Dig in More?

I know some of y'alls side hustle is private detective (like me 😉), so here is more information to dive into:
 
The Proposed Rule: Salmonella Framework for Raw Poultry Products
 
More Detailed Blog from Farm & Ranch Freedom Alliance
 
 
This is a crucial moment for the pastured poultry community and for maintaining your choice as a consumer. Let’s make sure our voices are heard loud and clear.

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


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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?

Dan

“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”

Gabrielle Thomas

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.

Coleen Logan

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