In 2010, the Food Safety Modernization Act (FSMA) was signed into law, initiating a shift in the US food safety landscape. FSMA spurred an array of regulations intended to reduce contamination, mitigate foodborne illness, and make it easier to halt and track foodborne illness or chemical contamination. The National Sustainable Agriculture Coalition (NSAC) engaged heavily in this rulemaking process in support of scale-appropriate regulation, guidelines for diversified farm and food operations, and further training resources to make sure that smaller food businesses, farms, and those using sustainable agriculture practices would not be disproportionately burdened by these new requirements. 

In the decade and a half since FSMA became the law of the land, the Food and Drug Administration has finalized some of the required regulations; however, many of these new regulations have been mired by delays. Some of these delays have been necessary, prompted by significant stakeholder engagement and proper timelines, a function of the participatory rulemaking process. Other delays, however, have been driven by rescinded and reproposed rules. For example, the Agricultural Water Standard was found to be overly cumbersome for many types of farm and food businesses, while not proving a meaningful reduction in foodborne illness, and was not finalized as part of the initial Produce Safety Rule. It was only recently finalized, and the plan for enforcement was initiated in 2023, with compliance dates for the smallest farms into 2027. 

With the implementation of these rules staggered over time, farmers and food businesses have found themselves in an increasingly complicated regulatory environment that often only utilizes exemption as the main way to ensure scale-appropriate regulations. This blog post examines some of FSMA’s overlapping requirements, as well as the remaining FSMA regulations that have still not been finalized. While this Government Accountability Office (GAO) report covers all of FSMA, this post covers only those portions of greatest concern to small, diversified farms and food businesses. 

Those statutory requirements contained within FSMA of greatest concern to sustainable agriculture practitioners, and focused on in this blog post, are :

• Section 103: Hazard analysis and risk-based preventive controls
•  Section 105: Standards for produce safety 
• Section 204: Enhancing tracking and tracing of food and recordkeeping 

As these rules derived from this statue have come to overlay each other, and often have different exemptions depending on product, size of organization, and legal structure of the entity (non-profit, farm, packer, retail food) it has become increasingly complex to navigate, especially for those diversified, small to medium sized farms that are key in the development of more sustainable agriculture across the US. These rules have also caused and continue to cause a variety of financial burdens for farms that are smaller and more diversified. Much of this work has been done without the Food and Drug Administration (FDA) being able to showcase reduced foodborne illness attributable to the rules themselves as well.  

Until this moment, a midmortem of the rollout of the entirety of FSMA (though there have been reviews of subsets of the law) has not been conducted by a government entity, only partially by outside stakeholders. 

This recent GAO report provides an overview of what parts of FSMA are completed, partially completed, and not completed, as well as offers more general recommendations.  Most of the requirements identified in FSMA (41 out of 46) have been completed, showing clear FDA progress towards full implementation, though the report also notes many of the stakeholders felt the delay in doing so resulted in confused and unclear incentives for investments in food safety technologies. 

The report makes a variety of recommendations for FDA going forward, across all of the statutes of FSMA. 3 of the 7 recommendations are most relevant to a sustainable food safety audience:

GAO: The Commissioner of FDA should ensure that the Human Foods Program establishes milestones and timelines for updating the agency’s good agricultural practices for fruits and vegetables and publishes them as required by FSMA’s section 105. (Recommendation 5) 

• NSAC’s perspective: If the FDA is to approach reevaluating the Good Agricultural Practices, it should do so in coordination with the Agricultural Marketing Service (AMS) and the National Institute of Food and Agriculture (NIFA) at the US Department of Agriculture (USDA), pre- and post the development, given their historic and current involvement with farmers and food safety practitioners.

The FDA Commissioner should ensure that the Human Foods Program develops a plan with milestones and timelines for establishing a product tracing system to enhance FDA’s existing foodborne outbreak response processes, and that it establishes the system as required by FSMA’s section 204. (Recommendation 6)

• NSAC’s perspective: While NSAC supports the finalization of the Food Traceability Rule, referred to here, there is still work to be done to provide adequate resources and training to small farms and food businesses. 

The Commissioner of FDA should ensure the Human Foods Program and the Center for Veterinary Medicine develop and implement a performance management process to assess the results of FDA’s rules and their contribution to the prevention of foodborne illness. This process should include setting goals to identify results to achieve, collecting information to measure performance, and using that information to assess results and inform decisions for each rule. (Recommendation 7)

• NSAC’s perspective: While some attempts have been made to track the overall impact of FSMA, further data is needed on almost all of the rules that directly connect specific interventions within rules to food safety outcomes. Any further tweaking of the rules into the future will require further documentation to showcase the potential food safety outcomes in the context of other forms of analysis, such as costs to producers.

NSAC has been deeply involved in both formal and informal processes to shape these statutes and rules, and is glad to see FDA has made progress towards the finalization of all the rules.  The development of the performance management data analysis should have come on consequentially with the rules. This GAO report is a welcome and more comprehensive addition to the different analyses of FSMA over the years. 

However, there have been mitigating factors for the food research, investigation, and enforcement section of the FDA, including a lack of funding commensurate with its responsibilities and a complete reorganization into the Human Food Program. Developing methods to analyze both the efforts already made and the remaining rules yet to be fully implemented will improve transparency for farmers and food businesses. It will bring clarity to many on how their efforts and investments have contributed to a safer food system.

It may also help create further rationale for increases in food safety training funding or more precise targeting of food safety programs. Programs such as the Food Safety Outreach Program at USDA or some of the objectives of the Cooperative Agreement Program for State Implementation at FDA provide portions of this funding and have experienced declining real funding over time. If the FDA invests further in the proposed management system, it may reveal further instances where funding for training might best be allocated and help close the gap between the goals of FSMA and the reality, in an equitable way for all farms and food businesses. 

The post GAO Reports on the Mixed Success of Food Safety Rules appeared first on National Sustainable Agriculture Coalition.

Federal food safety agencies have seen significant staff losses in 2025, threatening their ability to serve stakeholders and ensure the safety of our food supply Several federal agencies – including the Food and Drug Administration (FDA), the US Department of Agriculture’s (USDA) Food Safety and Inspection Service (FSIS), and Animal and Plant Health Inspection Service (APHIS) – hold this responsibility. These federal agencies work with state partners to set and enforce food safety standards and help reduce the risk of foodborne illness outbreaks or the spread of disease from animals to humans. Staffing losses at the agencies, particularly inspectors and outreach professionals, threaten the safety of the US food system and the ability to serve agricultural enterprises of all types and sizes 

This post continues the National Sustainable Agriculture Coalition’s (NSAC) series on the federal staffing crisis by examining staff losses at key food safety agencies. In this post, we extend our lens beyond the United States Department of Agriculture (USDA) to also include the Food and Drug Administration (FDA), which is part of the Department of Health and Human Services (HHS). This is the sixth post in the series.  Previous posts have given an overview of USDA staffing losses and cuts at key USDA agencies. All of the posts in the staffing crisis series are here. 

Staff losses at FSIS and APHIS in particular will likely be further exacerbated by the USDA’s planned reorganization. On July 24, 2025, USDA announced a major reorganization of the department, drafted without any input from farmers, Congress, or other stakeholders. The National Sustainable Agriculture Coalition (NSAC) continues to encourage USDA to allow meaningful stakeholder input into any reorganization and to share all comments that were received from stakeholders via an ad hoc public comment. NSAC’s reorganization comment can be seen here.

Food Safety Agencies Face Severe Staffing Shortages

Each of the food safety agencies has experienced significant staff losses in 2025. APHIS has seen the most dramatic staff reductions, losing approximately 20% of their staff to the Deferred Resignation Program (DRP) and other separations between January and March 2025. FSIS lost approximately 8% of their workforce to the DRP and separations. The DRP was a program led by the Department of Government Efficiency (DOGE) to reduce federal staff numbers by offering incentives for employees to resign. Unfortunately, it is not yet clear how many FDA employees left the agency via the DRP, but they have lost at least 3,500 staff to reductions in force in April 2025 and an additional 411 employees to other separations between January and March 2025, according to data from the Office of Personnel Management (OPM). It is not yet entirely clear what portions of these positions have been lost within the broader Human Food Program, or the Office of Produce Safety, those sections within FDA that most impact farmers and the food system. 

Figure 1: Percentage of Staff Lost to DRP and Separations

While each agency takes a different approach and has different responsibilities regarding food safety, these staff losses will pose major challenges for them to fulfill their missions. APHIS, with the largest staff loss percentage, is responsible for preventing and addressing the spread of plant and animal disease. This means that they do not inspect final food products, but their efforts to prevent the spread of pests and disease help protect the human food chain from contamination. After the resignation and separation of more than 1,600 employees, APHIS found itself scrambling to refill positions that it realized were essential to securing the safety of the American food and agriculture system. FSIS is the agency responsible for ensuring the safety of meat, poultry, and egg products. It conducts continuous inspection at slaughter facilities and verifies that processors meet federal food safety standards.  It also liaises with and provides support to states that run their own meat inspection agencies, which have been shown to benefit small meat processors, and other supplementary programs such as the Cooperative Interstate Shipment that support small processors. With hundreds of staff lost in 2025, the agency faces growing gaps in its ability to provide adequate inspection and support for processors, particularly small plants.

Reorganization Threatens to Worsen Staffing Crisis

These widespread staff losses at food safety agencies are likely to be further exacerbated by the USDA’s planned reorganization. While APHIS and FSIS are not specifically named in the reorganization plan, they will undoubtedly experience its impacts. One of the major tenets of the reorganization plan is the movement of USDA staff and offices outside of the Washington, DC capitol region. Approximately 14% of APHIS staff and approximately 8% of FSIS staff are located in Washington, DC, Maryland, or Virginia, according to data from OPM. Secretary of Agriculture, Brooke Rollins expects up to 50% of USDA’s capitol area staff to leave the Department because they decline to relocate. Similarly, they will experience its universal proposal for consolidation of support, FOIA, and Tribal relationship functions. For FSIS in particular, which provides voluntary inspection for non-amenable species including bison, often cultivated by different Tribal nations, this lack of direct connections between FSIS and Tribes could prove harmful. These additional staff losses and other impacts of the planned reorganization will further disrupt the ability of the agencies to fulfill their missions and serve stakeholders. 

Losing Institutional Knowledge and Technical Expertise

The staff at these agencies that safeguard food safety are highly specialized professionals and each loss represents a loss of essential institutional knowledge. It is impossible to know specific occupations or experiences of the staff who accepted the DRP. This is due to the failure of OPM or other agencies to provide any detailed information on the tens of thousands of staff who left federal employment via the program. NSAC joins the calls of many other stakeholders for OPM and all agencies to provide detailed information on the scope and impact of DRP resignations.

While we cannot know the scope of lost institutional knowledge due to the DRP, the FDA staff who otherwise separated from the agency between January and March 2025 had an average of 21 years of experience and the FDA inspectors who separated, specifically, had an average of 19 years of experience, according to data from OPM. The FSIS employees who separated had an average of 16 years of service and APHIS employees had an average of 10 years of experience. Approximately 15% of the APHIS employees who separated from the agency also held masters degrees, doctorates, or another advanced degree, again according to data from OPM. Within FSIS, more than 63% of the staff who separated from the agency were classified as part of the investigations group, which includes inspectors. 

Together, these staff losses threaten the ability of the agencies to both safeguard food safety and to effectively engage with stakeholders such as small and diversified farms and processors. For example, FDA is responsible for the implementation of the Food Safety Modernization Act (FSMA) that significantly expanded the regulation of fruit and vegetable production. NSAC continues to advocate that it is essential that these standards be appropriate and accessible for small and diversified farms and those who implement sustainable practices. Fewer staff at FDA, particularly in the education and inspection domains, may lead to a lack of experience in the design of the remaining FSMA rules and undermine their appropriateness for a wide range of farms, especially those pursuing activities which help mitigate climate and environmental impacts. 

Rebuilding the Workforce for a Safe and Thriving Food System

Together, the staff at these different agencies help ensure a safe food system that serves consumers and farmers. These major staff losses are extremely concerning not just for preventing foodborne illness but also for the ability of the agencies to develop, educate, and enforce standards and regulations in a manner that is appropriate for farmers and processors of all sizes.

If they are understaffed and overstretched, agencies like FSIS might prioritize working with large processing facilities, as no statutory provision explicitly stops them from doing so. This would undermine support and outreach to small and midsize firms. For example, during the recent federal government shutdown, there is evidence that FSIS continued to pay inspectors at large processing facilities while inspectors at small and midsized plants were not paid. This can lead to declines in inspector morale, inspection quality, and long term struggles in hiring and retaining future inspectors.  Adequately staffing these and other federal agencies is essential to serve stakeholders and fulfill the mission of USDA and FDA.  NSAC calls for the immediate restoration of staffing levels as well as transparency and stakeholder input for both the staffing plans and the proposed reorganization. 

The post USDA Staffing Crisis: Food Safety Agencies Struggle as Federal Workforce Shrinks appeared first on National Sustainable Agriculture Coalition.

Editor’s Note: This is the second post in a multi-part blog series analyzing the Farm, Food, and National Security Act of 2024, which was reported out of the House Agriculture Committee on Friday, May 24. The first post provides an overview of the markup process and the bill as a whole, as well as its likely (or unlikely) path to becoming law. This post explores the FFNSA’s impacts on local and regional food systems. Subsequent posts provide a deep dive analysis of the bill’s potential impacts on farmers’ access to land and capital, beginning and other underserved producers, conservation and climate resilience, and sustainable and organic research, among other issues.

The Farm, Food, and National Security Act of 2024 (FFNSA, HR 8467) offers a number of policy reforms and authorizes new programs that seek to strengthen existing programs and sustain the novel United States Department of Agriculture’s local supply chain initiatives. The bill under-delivers, in part, by not targeting initiatives to the small and small and mid-scale operations that are the foundation of local food supply chains. At the same time, it significantly underfunds certain programs, and in some instances, the bill does both of these things at the same time. As a result, NSAC is concerned that many of the new investments included in the House bill will disproportionately benefit large operations and distributors or hamstring the impact of new programs due to insufficient funding.  

The following analysis is separated into sections addressing local and regional market access and development, supply chain infrastructure and support, and food access:

• Market Access and Development
• Supply Chain Infrastructure and Support
• Food Access

Local Food: Market Access and Development

Since the COVID-19 pandemic, Congress has initiated numerous novel food supply chain initiatives through the CARES Act and the ARP Act that bolstered markets and spurred new local opportunities for small-scale operations. By original design, funding for many of these programs is likely to end soon, unless a new farm bill continues and enhances these strategic investments. The farm bill has a longstanding history of supporting local market development through programs such as the Value-Added Producer Grants and Farmers Market and Local Food Promotion Grants, yet any new farm bill must incorporate lessons learned from COVID-era programs into both well-established and new federal programs to better sustain these catalytic market investments.

Food Box Pilot Program

The FFNSA insufficiently promotes new and emerging markets and fails to support smaller-scale farmers in accessing federal markets. Rather than identifying a permanent funding source for the new but already influential market development program – the Local Food Purchase Assistance Program – the bill authorizes a Food Box Pilot Program (Section 4302) that: 

• Directs USDA’s Agricultural Marketing Service to contract with no more than 20 entities to carry out a food box program that provides staple foods to food insecure households,
• Seeks to complement existing federal nutrition programs, increase the capacity of community and faith-based organizations, and support local and regional food systems, 
• Considers a range of criteria when selecting contracts, including whether they have demonstrated partnership networks, experience or commitment sourcing from small and medium-scale farmers, and source local and regional products, when seasonally available or at a reasonable price, and
• Includes a total of $200 million of mandatory funding. 

While there are elements of the Food Box Pilot Program that theoretically support new local markets, there is a track record of a similar program design leading to limited purchases from small, mid-sized farms and farmers of color, inadequately serving the most food insecure communities, and contracting with a few distributors that concentrated funding with few, large companies. 

Food Safety Outreach Program

Investments in food safety education and equipment or training are essential to meeting ever-evolving market and regulatory food safety requirements. Without sufficient investments, these food safety requirements can prevent many smaller-scale producers from entering new markets. The FFNSA reauthorizes some of the programs that provide these investments – such as the Food Safety Outreach Program (FSOP). FSOP, which funds education on a variety of food safety topics, includes an intentional focus on reaching underserved communities of producers. However, FFNSA misses the opportunity to increase funding levels for FSOP, a crucial misstep especially given the array of food safety regulations increasingly impacting smaller producers. (Sec. 7301).

Federal Procurement

The farm bill offers an opportunity to address some of these barriers to enter federal markets, such as USDA’s Commodity Program. The EFFECTIVE Food Procurement Act (HR 6569) created a pathway for this but was not included in FFNSA. However, the bill does direct USDA to study the barriers farmers and enterprises that produce culturally appropriate food experience when trying to compete for federal commodity contracts and make recommendations on how to improve the process (Sec. 10107).

Local Agriculture Market Program 

Despite the significant impact of and demand for the Local Agriculture Market Program (LAMP), the FFNSA does not offer an increase in appropriations or mandatory funding levels for the program. However,  the bill offers program reforms that will generate new demand including a number of provisions from the Local Farms and Food Act (H.R. 2723) to expand access to LAMP funds by reaching food hubs and creating a simplified application and reporting process for projects of less than $100,000 (Section 10102). Unfortunately, the combined effect of the FFNSA will likely create more demand for LAMP while failing to provide sufficient funding to address that demand.

Cooperative Interstate Shipment Program

Meat and poultry processing is a closely regulated industry. Yet, for decades, geographic and funding limitations have frequently prevented Food Safety and Inspection Service (FSIS) personnel from providing food safety education before regulation. These same limitations have also made it challenging for FSIS to cost-effectively regulate smaller processors in many states. As a result, Congress created the Cooperative Interstate Shipment Program (CIS) in the Food Conservation, and Energy Act of 2008 (2008 Farm Bill) to enable products processed at state-inspected plants to be sold interstate if the state has a Meat and Poultry Inspection program equivalent to the federal inspection program.

CIS has expanded markets and opportunities and encouraged the creation of new products in the small plants it serves. Over time, however, it has become evident that the CIS program needs an expansion of scope and funding to serve more small and very small meat processors. The bipartisan Strengthening Local Processing Act (SLPA, HR 945) includes changes to the federal and state regulatory authorities’ cost-share model, which could alter the cost-benefit analysis for states that have their own meat and poultry inspection programs, ultimately making for more effective regulation of small and very small meat processors. Those plants will then be able to work more effectively with the small and diversified farms that are an essential component of a sustainable and equitable food system. 

Unfortunately, the FFNSA declines to make any changes to the CIS program structure, instead promoting outreach about the program and requiring a report on that outreach each year (Sec 12113). While we support more effective promotion of the CIS program,  the failure to include many of the necessary structural and funding changes means that the FFNSA misses a critical opportunity to expand markets for smaller processors, increase competition in the industry, and help bring more nutritious, locally, and often sustainably raised animal products to market. The FFNSA requires that FSIS provide more publicly available  food safety resources designed for small and very small meat processors, which we support. Of specific importance is making more validation studies publicly available, which  small processors can  use to  substantiate scale -appropriate food safety control techniques. (Sec. 12112).

Local Food: Supply Chains

USDA’s recent transformative food system initiative has focused on improvements across the supply chain, with investments in infrastructure, workforce development, value-chain coordination, and business technical assistance. The FFNSA offers a few new options for infrastructure investments but does not adequately respond to the needs of rural communities for specialized food workforce training and technical assistance for scaling businesses. Disproportionate investment along the supply chain can lead to supply without adequate markets for producers, or potentially new infrastructure for businesses without sufficient business planning to strategically scale. 

Infrastructure

The FFNSA attempts to sustain some of the meat processing expansion programs that were created by ARPA, for example through a “new, mobile, and expanded meat processing and rendering grants” program (Sec. 6305). This section bears some but not enough resemblance to the original programs (MPPEP, Local MCap, MPIRG) that were developed in part based on the proposals in  SLPA. 

At only $3 million in authorized funding, the FFNSA’s Sec. 6305 grants are insufficiently funded relative to the demand across the US. Furthermore, the bill expands eligible applicants to include land grant universities, state departments of agriculture, and other organizations with existing capacities well beyond the small and very small meat processors for whom this program was intended. Instead of limiting these grants to small and very small processors, the FFNSA only includes it as a priority that the funding goes to small and very small processors. This, combined with the lack of a ‘socially disadvantaged’ priority means that the FFNSA-created grant program runs the risk of funneling money to processors that already have access to other financial instruments to expand capacity. This fails to meaningfully address the processing bottleneck that smaller-scale producers nationwide experience. 

The FFNSA expands upon the existing business and industry guaranteed loan program by authorizing a permanent food supply chain guaranteed loan that seeks to support commercial food supply chains by financing projects focused on aggregation, processing, distribution, and manufacturing. Additionally, it caps the guarantee fee institutions pay to USDA to 3%, which has been cited as a barrier for a number of lenders. However, with no stated program goals or parameters for business scale or production type, this financial product is unlikely to support emerging food enterprises or small and mid-scale enterprises participating exclusively in regional food supply chains due to the rigorous underwriting standards associated with USDA guaranteed loans (Sec. 6304, 6412). 

Finally, the bill codifies the recently implemented updates to LAMP’s program offerings by ensuring necessary special purpose equipment can be purchased (Sec. 10102).

Workforce Development

Small and very small processors – for whom jobs tend to be more cross functional than in their larger industry competitors – have struggled to recruit and maintain the highly skilled workforce they need. More funding and programs specifically created to support the unique needs of small and very small meat workforce development are important to increase growth in the sector.

Unfortunately, the FFNSA does not offer any new funding or new programs to meet the much needed investment in this sector. The bill does amend the USDA’s Agriculture and Food Research Initiative (AFRI) to include meat processing workforce development as an area of research. The bill also authorizes the creation of new community college grants oriented towards the development of a broader highly skilled agricultural workforce. While this may include meat processing training, it does not do so explicitly (Sec. 7123, 7503). 

Value-chain Coordination and Technical Assistance 

As recently highlighted, the people offering business technical assistance and coordinating activities along the supply chain can often be invisible but are nonetheless essential to operating efficient local food systems. Two of USDA’s most notable initiatives to support these activities are the Regional Food Business Centers and the Meat and Poultry Processing Capacity Technical Assistance program. Unfortunately, the FFNSA does not authorize either program. 

Local Food: Access

A number of USDA programs aim to ensure high quality local foods are easily accessible to all individuals. Many of these programs do so by ensuring families can use their Supplemental Nutrition Assistance benefits (SNAP) in local food markets or by providing additional cash benefits for fruits and vegetables produced by local farmers. 

The FFNSA provides new additional mandatory funding for several programs that increase the accessibility of local food within food insecure communities, including: 

• $2 million annually for the Senior Farmers Market Nutrition Program,
• $5 million annually for the Community Food Project Program (CFP), and 
• $19 million for the Gus Schumacher Nutrition Incentive Program (GusNIP). 

Unfortunately, the increase for the Senior Farmers Market Nutrition Program is insufficient to fix the program’s persistent issue in which some states are allocated so little funding that they pass on the opportunity entirely due to the administrative burden of implementation. While this restores CFP to the higher funding levels it received before the Agriculture Improvement Act of 2018 (2018 Farm Bill), all of these increases will come at the expense of future increases to the Supplemental Nutrition Assistance Program. 

Some changes in the FFNSA will likely lead to greater local food access in vulnerable communities. For example, the bill allows the Secretary of Agriculture to waive the GusNIP match requirement for persistent poverty counties (Section 4306). It also expands the responsibilities and improves the services of the Office of Urban Agriculture and Innovative Production (OUAIP) to improve upon the farmer networks supporting food insecure communities. The bill would also enable community experts to partner with USDA to better serve urban producers through cooperative agreements, and support farmer cooperatives and individual farmers through grants and subgrants, respectively (Section 10004). Yet, similar to the changes to LAMP, the House changes will generate increased demand without any increase or guarantee of funding. OUAIP has consistently been underfunded or forgotten in Appropriations Cycles. Therefore, these program improvements will likely be delayed without adequate funding. 

The post Digging into the House Farm Bill: Part 2 appeared first on National Sustainable Agriculture Coalition.

Contact: Laura Zaks

National Sustainable Agriculture Coalition

press@sustainableagriculture.net

Tel. 347.563.6408

Release: NSAC Welcomes FDA’s Risk Based Approach to the Final Rule on Pre-Harvest Agricultural Water

 Work Remains to Fully Support Farmers in Compliance

Washington, DC, May 3, 2024 – Yesterday, the Food and Drug Administration (FDA) released the Final Rule on Pre-Harvest Agricultural Water, which finalizes a series of updates to Subpart E of the FDA Food Safety Modernization Act (FSMA) Produce Safety Rule.  This is one of the remaining components of the 2015 Produce Safety Rule and has been much anticipated by agricultural and public health communities. For nearly ten years, FDA has wrestled with crafting an appropriately risk- and science-based standard. This final rule represents an impressive shift from the original one-size-fits-all approach to one that can be adapted to farms of varying types and sizes. The National Sustainable Agriculture Coalition (NSAC) has been actively engaged in this process, and welcomes this risk-based final rule, which reflects years of listening and learning on behalf of FDA and the broader stakeholder community.

The final rule demonstrates FDA’s marked improvement in understanding the links between various risk prevention strategies and public health, alongside the importance of ensuring that comprehensive rules have adaptable, farmer-driven assessments at their heart. These changes reflect FDA’s prioritization of engaging with the farmer stakeholder community to better understand the impacts their rules have had across different scales and models of farming. NSAC members have been deeply involved in many of these changes, leading the charge for farmers of diverse scale and production styles in their region. 

“We deeply appreciate the updated, risk-based approach to Pre-Harvest Agricultural Water Standards and the staggered compliance dates of the final rule by farm size. As implementation begins, NSAC is keen to continue to engage with FDA to support farmers’ ability to fully forecast and mitigate risks, especially from adjacent and nearby land uses. Similarly, we are eager to continue partnering with FDA in order to better resource farmers, especially those operating on smaller scales and with more diversified production styles,” said Connor Kippe, NSAC Food Systems Integrity Policy Specialist.

We look forward to working with FDA and other stakeholders to establish a work plan to collaboratively develop further guidance documents that address these concerns, including the translation of implementation resources into languages such as Spanish. Visit NSAC’s blog for additional details on this rule and further guidance issued. 

###

About the National Sustainable Agriculture Coalition (NSAC)The National Sustainable Agriculture Coalition is a grassroots alliance that advocates for federal policy reform supporting the long-term social, economic, and environmental sustainability of agriculture, natural resources, and rural communities. Learn more and get involved at: https://sustainableagriculture.net

The post Release: NSAC Welcomes FDA’s Risk Based Approach to the Final Rule on Pre-Harvest Agricultural Water appeared first on National Sustainable Agriculture Coalition.

The Strengthening Local Processing Act (SLPA) is the most comprehensive meat processing bill around, with specific provisions that address competition, demand for local products, and access to value added services in the meat processing sector. It does so by addressing acute issues for processors vital to our supply chain, and by promoting training programs that bolster the resilience of these processors, the farmers they work with, and food access for their communities. Led by Senators John Thune (R-SD) and Sherrod Brown (D-OH) and Representatives Chellie Pingree (D-ME) and Jim Baird (R-IN), this comprehensive solution to some of the greatest barriers facing independent and small-scale producers and processors has garnered strong bipartisan support, in both the House and Senate.  

History of Independent Small-Scale Meat Processing

Many of the companies created at the advent of mass meat processing have persisted to today, even if their names and principal owners have changed over time. Despite various waves of antitrust activity over the last century, these companies continue to hold consolidated power over the industry, creating an unequal playing field that boxes out small and medium-sized entities. These large-scale processing companies may provide lower cost products for consumers through their economies of scale and vertical integration, yet they have many downsides. They often have unsafe working conditions and a structure that makes it hard to advocate against these abuses. They leave our meat and poultry processing system and supply chain brittle and slow to move with changing conditions such as climate impacts, communicable diseases, or war-related barriers, all of which our agricultural markets have faced in recent years.  

The evolving needs of our food system consequently require agile policy solutions that adapt to the challenges at hand.  Hardworking but under-resourced small to midsize processors lack the support and the financial infrastructure in their communities to expand their capacity. Building an array of financing options can enable different processors to provide more diverse services for producers as well.

Recent Actions

In recent years, and most noticeably during the supply chain disruptions caused by the Covid-19 pandemic, several agencies within the USDA – including Rural Development and the Agricultural Marketing Service – have helped direct critical funding specifically to small and very small meat processing plants. These investments have supported smaller-scale farmers who are implementing important sustainable practices like organic or highly rotational grazing, and who consequently seek a premium on their product through the sale of whole cuts, local marketing, and processing in line with their raising label or certifications.

Examples of these investments are the Meat and Poultry Programs (MP programs), such as the Inspection Readiness Grant (MPIRG), Processing Expansion Program (MPPEP) and Intermediary Lending Program (MPILP) which have helped smaller plants scale up or prepare themselves for federal inspection utilizing different sized grants and loans. Sustaining funding for these programs is vital to continuing to build a more resilient and agile food system.

NSAC was pleased to see rounds of awards from the MP programs. We also supported funding more agriculture of the middle initiatives, with significant investments to help aggregate small producers and support mid-scale producers.  Unlike these other initiatives, SLPA is specifically focused on supporting the smaller ‘mom and pop’ operations that form the cornerstone of local food economies, and local economies as a whole. The Local Meat Capacity and Indigenous Animal Processing Grant Programs, which recently held calls for proposals, will go a long way towards sustaining this goal. The high demand for these two programs, as well as MPPEP, demonstrates a clear need to continue funding programs focused on small meat processors, to better serve the demand from local and sustainable meat and poultry producers.

The history and present-day reality of consolidation in the meat processing sector – coupled with the recent successes in expanding opportunity and support for smaller-scale, independent processing through USDA’s pandemic-era programming – make it clear that the Farm Bill must sustain these investments and permanently authorize programs that build regional processing capacity.  The SLPA provides a vehicle for doing so, and enjoys broad support across the agriculture and food sectors for these reasons outlined below.

1. SLPA will address critical workforce shortages and training needs

Currently, many small meat packers across the country, from Minnesota to California are struggling to staff up. They cannot meet the demand for the highly skilled employees they need or find co-owners if they operate an employee-owned cooperative. 

To realize the full benefits of the previous taxpayer investment in meat processing capacity expansion, additional training programs are needed to create and sustain the diverse workforce these varied plants require and to help grow the next generation of leaders in the sector. 

It is clear highly trained professionals are needed to  help run these plants and provide vital services to their local communities – making sure sustainably raised livestock and poultry make it from farm to table. In addition to prioritizing worker training to address immediate workforce shortages, SLPA would also provide grants to support the development of skills necessary for workers to eventually assume cooperative or individual ownership of these plants as well. 

“[SLPA] creates an Institutional Career Training Program to work towards building a pipeline of talented individuals interested in making a career out of providing a high-quality and nutritious food source for their fellow Americans.”

– US Cattlemen’s Association president Justin Tupper

To do so, SLPA creates two meat processing training program grants that assist and train small plant operators, small plant employees, and the next generation of meat processors and butchers. It does so by supporting training programs in both institutions – such as technical colleges, nonprofits, and worker training centers – and small and very small plants. These two categories allow for flexibility in meeting the sector’s changing needs for workforce training. In each case, SLPA authorizes an annual appropriation of $10 million, a modest amount to launch the program and demonstrate its value over the life of the Farm Bill.

2. SLPA will increase regional and interstate trade and open new markets for local producers

Processors and the producers they serve not only need additional training and support for workforce development, but also easier to access, expanded markets. For producers on the borders of states that do not have appropriately sized plants where they can take their herds to sell into wholesale markets, SLPA would help expand potential markets for them. It would do so by creating incentives for states to create their own Meat and Poultry Inspection programs, or if they already do – incentivize them to join the Cooperative Interstate Shipping program.

“SLPA would also require the US Department of Agriculture to encourage state participation in the Cooperative Interstate Shipment program, which would open access for interstate shipment of meat and poultry, something that isn’t always currently allowed.“

– U.S. Cattlemen’s Association president Justin Tupper 

Currently, only 29 states have state Meat and Poultry Inspection (MPI) programs, which allow for sale and shipment within the state and which are currently cost-shared equally between the state and Food Safety and Inspection Service (FSIS).  SLPA would increase the federal government’s maximum cost share from 50 percent to 65 percent. This would help states with existing MPI programs cover costs and incentivize additional states to establish MPI programs.

States that have MPI programs can also opt into the Cooperative Interstate Shipment (CIS) program which allows for interstate shipment for small plants. Currently, the USDA does not actively solicit participation in the CIS program, nor does it provide the cost breakdowns or the resources available to participating states.

SLPA would require FSIS to conduct outreach to states with state inspection programs that are not part of the CIS program, and to submit a report to the House and Senate Agriculture Committees each year detailing the activities and the results of the outreach conducted. 

To further expand participation in CSI, SLPA would increase the amount of total program costs that USDA will cover from 60  to 80 percent. It also would change the small plant eligibility size for participation in this program from plants with less than 25 employees to plants with less than 50 employees. Increasing the size of plants able to be inspected under the CIS program would create new markets for those plants that are on the size and processing capacity cusp and may struggle to achieve federal grant of inspection, but are interested in pursuing larger markets. For a long time, limited intrastate markets have limited the growth of non federally or CIS inspected  small and midsize meat processors, especially those that may be located close to the state border. 

In addition to creating more market opportunities for processors, SLPA will also increase the amount of state employed inspectors which will mean less inspectors on the federal budget, more money in the states’ economy, and potentially better conditions for the inspectors themselves. For example, this could reduce how far they have to drive and other factors contributing to high turnover in the sector.

3. SLPA will help small, independent processors scale up and stay viable

In various ways, the SLPA takes many of the best parts of the Meat and Poultry programs funded through the American Rescue Plan Act and sustains them at a lower level, but for a dependable amount of time. 

From all of the application cycles, it is clear there is a massive demand for these programs – and there will continue to be going into the future. Because of short timelines for the development of plans, applications, and payouts, many of these programs favored ‘shovel ready’ projects. The programs may  have been selecting for plants that already had plans for expansion, and not necessarily those plants and areas most in need of investment. Moreover,  know from similar payment structures that longer timelines and more dependable grant cycles provide longer-term stability for processors, and the farmers they serve, to feel they can make or plan to make the necessary investments to qualify for these programs.

SLPA authorizes a Processing Resilience Grant Program (PRGP), which would give the Agricultural Marketing Service the ability to continue to invest in currently existing or proposed federally inspected, state inspected, and exempt small and very small plants. This investment could include expanding infrastructure to increase harvest and processing capacity, developing food safety plans, and purchasing new equipment, for example, hide pullers that make it easier for small plants to make use of coproducts such as leather or by products like offal. To target funding to those plants most in need of this support this section limits grants to a maximum size of $500,000 and has a $20 million annual appropriations authorization. 

 “Strengthening and rebuilding local and regional food systems is an important step in ensuring a robust and resilient food system of the future.  Vibrant local processing adds to consumer choices, competition, economic development as well as opportunities for farmers especially small and disadvantaged farmers.  It is an important step in our response to the shortcomings in our food supply that the pandemic highlighted.”

– Greg Gunthorp, American Grassfed Association Board Member, farmer, processor, sustainable food system advocate extraordinaire 

4. SLPA will support a vibrant and competitive livestock and poultry industry

For too long, smaller processing and slaughtering operations have not been provided the resources, financing options, and markets they need to exist. Market consolidation has allowed large meat packers to become overwhelming price makers through alternative marketing agreements, contracts, market power in auction settings, and a variety of other techniques. Over time, proportionally, this lack of competition in the sector has pushed down farmer share of livestock and poultry sales, along with a variety of other factors such as retaliation and antitrust policy. 

By responsibly investing in small to mid sized and independent processing operations, we can create markets where meat processors thrive and farmers and consumers can benefit from more companies in competition both over their product and their dollar. 

“More local processing capacity means more money in the pockets of farmers and ranchers,” said NFU President Rob Larew, adding that “Building out more and better processing access for ranchers helps them circumvent the processing monopolies while also providing homegrown products to their communities.“

5. SLPA has broad support across industry, party, and place in our food system

Whether they raise cattle, poultry, or other animals such as bison, producers critically feel the need for more slaughtering options and to expand their different product streams. For processors that participate in a certification program, such as organic or pastured, this need is particularly acute. To maintain market certifications, producers must work with processors that comply with the relevant certification standards. These processors are incredibly rare and finding one within a reasonable travel distance from the producer is a consistent challenge. Processors hear this demand but, without many of the solutions the SLPA proposes, lack scale-appropriate financial products to be able to expand meaningfully to serve these niche and local markets. 

Farmers, ranchers, processors, local and national organizations all support SLPA, and are working to make sure it is part of the 2023 farm bill. 

“The Strengthening Local Processing Act offers necessary resources that small-scale USDA facilities like ours have been advocating for. The appropriate allocation of these resources, as proposed in the Strengthening Local Processing Act, will allow establishments like ours to continue to survive and thrive during these immensely challenging times,” Nichole Sargent, Owner, Southpaw Packing Company, INC. (DBA Windham Butcher Shop), based in Windham, Maine.

“We look forward to working with Senators Brown and Thune and Representatives Baird and Pingree to advance this legislation through Congress.” 

 – US Cattlemen’s Association president Justin Tupper

“The benefit that the Strengthening Local Processing Act will bring to small processors across the country will ensure that the meat industry will be stronger, better connected, and more informed. With regulatory and training assistance, we look forward to seeing this bill pass to help our world’s meat supply.” 

– Abbey Davidson, American Association of Meat Processors

“NFU is proud to support this bill and will work with our partners to pass it.” 

–NFU President Rob Larew

State and national farm organizations, ranging from the Ohio Farm Bureau to National Farmers Union endorse this bill.  NSAC looks forward to working with Congress and our partners to make sure these critical programs for farmers, ranchers, and the processors that work with them have the support they need to feed our local communities. For more information about the SLPA and to take action to support its inclusion in the 2023 Farm Bill, visit our website.

The post Strengthening Local Processing Act – Critical Reasons for Support in the Farm Bill appeared first on National Sustainable Agriculture Coalition.

The end of a year signifies a time to reflect on all of the most important accomplishments and tribulations of the past year. At NSAC, we had the opportunity to celebrate and find new reasons to expand our advocacy to support sustainable agriculture practices, small-scale producers, diversified farming, local food systems, and beginning and underserved farmers and ranchers. Here are NSAC’s Top 10 accomplishments of 2022: 

1. NSAC’s In-Person Engagement!

After two long, difficult years managing the COVID-19 pandemic, NSAC members gathered for the annual summer meeting in Durham, North Carolina for the first time since the pandemic began. With nearly 100 members in attendance, NSAC’s coalition celebrated a renewed commitment to sustainable agriculture with many in-person conversations, connections made, and visits to local farms and food processing facilities that are doing the hard work to make our food system more sustainable and equitable. 

The NSAC Summer Meeting subsequently launched more in-person engagement with our incredible members. September 2022 saw the first in-person NSAC Fly-In since the beginning of the pandemic, bringing together farmers and food systems professionals from across the country to Washington, DC to discuss important policy and program improvements for a more sustainable and resilient farm system. With visits to Capitol Hill to share grassroots stories, important themes came to the forefront, including the need for increased investment in conservation programs like the Conservation Stewardship Program, government support for local food systems, the passage of legislation like the Agriculture Resilience Act. 

These in-person events provided a much needed return to normalcy. Beyond Zoom meetings and computer screens, NSAC and our member organizations experienced the power and impact of in-person engagement both in the field and on Capitol Hill. 

2. NSAC’s 2023 Platform Has Launched!

With the 2023 Farm Bill reauthorization next year, NSAC staff and members have been busily developing recommendations for ways the Farm Bill can invest in healthy communities, level the playing field for small- and mid-sized farms, build a climate resilient future, and advance racial equity across the food system. After months of hard work from the NSAC staff and with valuable input from our members, we released NSAC’s 2023 Farm Bill Platform, a comprehensive set of policy recommendations for nearly every title of the farm bill informed by expert analysis and the experiences of farmers and food systems professionals on the ground. 

Since the release of NSAC’s 2023 Farm Bill Platform, staff have been busy setting up meetings all over Capitol Hill to share key recommendations. By proactively building solid relationships with Congressional offices now, NSAC is gearing up for an exciting and impactful farm bill year ahead. You can learn more about NSAC’s 2023 Farm Bill Platform by reading our blog series on the Platform here. 

3. Making Strides in Equity

2022 also saw  new initiatives to advance a more resilient and equitable food and farm system. 

In particular, the USDA began convening its new Equity Commission, a 15-member independent body dedicated to addressing the Department’s investments and commitments to improving racially and socially equitable outcomes for USDA programs. Implemented as part of USDA’s Equity Action Plan, the inaugural meeting of the Commission occurred in February 2022, and invited members of the public to register and provide oral comments for the Commission to consider as it began the work of formally addressing equity across USDA programs and policies. Subsequent meetings occurred in May and September of 2022. NSAC strongly supports efforts taken to ensure the equitable distribution of USDA resources such that farmers of all backgrounds, including people of color, beginning farmers, and veteran farmers, have the opportunity to thrive in our agricultural system. For more information on NSAC’s commitment to racial equity, click here. 

4. Breaking Climate Ground with the Inflation Reduction Act

During the summer of 2022, Washington, DC was abuzz with news that Senator Joe Manchin and Senator Chuck Schumer had negotiated the most comprehensive climate change bill ever passed in the history of the United States. The Inflation Reduction Act of 2022 (IRA) offered more than 700 pages of substantive investments in a variety of climate-oriented programs, many of which were relevant to food systems. Of note, agriculture conservation programs, including the Conservation Stewardship Program, Agricultural Conservation Easement Program, Regional Conservation Partnership Program, and the Environmental Quality Incentives Program were reauthorized.  More than $20 billion dollars in incremental payments was allocated through 2026. Additionally, organic producers and those transitioning to organic received explicit support in the bill. Further still, the IRA codified key elements of conservation programs that NSAC has long fought for, including removing the requirement that 50 percent of EQIP funds go to livestock operations, which has long resulted in Confined Animal Feeding Operations (CAFOs) receiving large portions of conservation funds. While the IRA did not address every issue in climate and conservation programs, it certainly made some major improvements. 

Beyond conservation program support, the Section 22006 of the Inflation Reduction Act provided $3.1 billion in funding for USDA to provide relief for distressed borrowers with at-risk agricultural operations. Nearly $800 million has already been disbursed to distressed borrowers with direct or guaranteed loans administered by USDA’s Farm Service Agency (FSA).

As we round out 2022, NSAC staff are busy responding to requests for comments from USDA’s Natural Resources Conservation Service (NRCS) on ways to best implement the expansive funds that have been allocated to agricultural conservation programs in the IRA. With immense dedication and input from our members, our staff have prepared a substantive comment filled with recommendations on how to improve programs and implement new funds for conservation. 

5. Moving Forward on Appropriations

This year NSAC worked with the Biden-Harris Administration and with Congressional appropriators to seek increased sustainable agriculture investments in Fiscal Year (FY) 2023 federal spending, including for the Sustainable Agriculture Research and Education program, conservation technical assistance, and much more. The fiscal year 2023 omnibus appropriations bill, as it currently stands, includes significant funding for key NSAC priorities including a. If the bill makes it through the House and Senate this week, we will see a $5 million increase for SARE, and a more than $40 million increase for CTA, while GLCI would receive flat funding at $14 million. As of this writing, the omnibus FY23 bill is awaiting final passage before the end of 2022.

6. Celebrating Crop Insurance, Competition, and Credit Reforms 

Throughout the year, both crop insurance and credit programs have seen huge improvements that NSAC has been advocating for. 

In July 2022, NSAC released a report on the benefits of crop insurance payment caps entitled “An Economic Analysis of Payment Caps on Crop Insurance Subsidies,” which calculated the potential savings of taxpayer dollars that would result from the implementation of modest payment caps on crop insurance subsidies. This policy would address both the outsized capacity for larger-scale producers to continually receive subsidies on crop insurance while also allowing for greater investments in conservation and other programs that provide farmers with the capacity to manage disasters that might affect crops in other ways. The report was updated in October 2022 to further demonstrate the minimal negative impacts of crop insurance payment caps. 

NSAC also supported a number of updated rules to the Packers and Stockyards Act, which advanced the Biden Administration’s commitment to giving extra teeth to the enforcement of antitrust law and giving livestock producers a fair shake. The first of the rules that NSAC supported included provisions to reform the Poultry Tournament Payment System, which will allow for smaller family farms to receive greater transparency from poultry production companies regarding their contracts. The second rule contained provisions to prevent prejudice against market-vulnerable individuals and to prohibit the use of false or misleading statements regarding contract formation, performance, and termination, among other protections. These two new rules offered significant advancement to ensure a fairer livestock system for producers and keeps in check the antitrust and otherwise unfair practices of powerful livestock and poultry companies. 

In late August, the United States Department of Agriculture (USDA) Risk Management Agency (RMA) announced several changes to improve the effectiveness of the Whole-Farm Revenue Protection (WFRP) program, the only insurance product designed to protect a farmer’s entire operation. RMA also announced a Road Show that offered two virtual workshops in October 2022 which developed into a series of virtual and in-person events this fall to educate producers and crop insurance agents about WFRP. NSAC supports a number of the new provisions that RMA has announced, including increasing maximum revenue limits, adjusting yield reporting requirements, and increasing maximum insurable revenue limits. NSAC looks forward to continuing to work with RMA to continue these positive changes, as well as prohibit negative provisions, such as the ability to adjust price and production expectations at the time of a loss claim, which causes significant discouragement from enrolling in WFRP. By advocating for good WFRP policies, NSAC hopes that more farmers will be able to protect their sustainable, diversified operations. 

7. Making Investments in Local Agriculture Programs

In September 2022, USDA announced its intention to establish Regional Food Business Centers, designed to provide technical assistance and capacity building for local and regional supply chain rebuilding from the impacts of COVID-19. NSAC celebrates this distribution of funds to strengthen local food systems to increase their resilience, and the particular focus on overcoming market barriers for underserved farmers, ranchers, and food businesses. 

The Local Food Purchase Assistance Cooperative Grant Program (LFPA) also saw massive infusions of funds this year, with over $900 million dedicated to state, tribal, and local governments to facilitate local food purchasing to expand economic opportunities for local and underserved producers. This large investment in local food economies shows great potential for supporting smaller food producers, and also offers state and other regional government entities the flexibility to meet local needs. This program further expands on the extensive support that local food systems received through the American Rescue Plan and other supports throughout the COVID-19 pandemic. NSAC will be working to ensure that these and similar programs find a more permanent home in the 2023 Farm Bill to bolster local food systems in the long-term. 

COVID-19 relief also included more capacity for the Value-Added Producer Grant Program (VAPG), which as part of the LAMP program, offers resources to create or expand local value-added producer-owned businesses. Through COVID-19 relief funding, VAPG grants saw reductions in matching requirements and overall increases in funding available, enhancing access to this valuable business assistance program and contributing to local economic development.

8. Expanding Food Safety and Inspection Opportunities for Smaller Operations

NSAC’s Food Systems Integrity portfolio has also seen an exciting year with a number of key programs receiving both fiscal and programmatic support, leading to better conditions for smaller producers and processors. 

The Strengthening Local Processing Act (SLPA), initially introduced in 2020, supports small meat processors dealing with supply chain challenges. Changes made to the legislation in reintroduction will expand access to workforce development funds for a wider variety of groups. NSAC supports this expansion and is advocating for SLPA’s inclusion in the 2023 Farm Bill. 

2022 saw other administrative efforts to support small meat processors. In November 2022, it was announced that USDA would invest over $70 million in 21 grant funded projects in the initial round of the Meat and Poultry Processing Expansion Program (MPPEP) – a program which aims to increase options for livestock producers, promote competition across the economy, and lower costs for American families. NSAC was very supportive of these grants, recognizing that their implementation allows for more proactive steps from the Food Safety and Inspection Service (FSIS) to anticipate the unique capacity and personnel challenges that smaller processors face and support them in building their resilience.

Further, the Meat and Poultry Inspection Readiness Grant (MPIRG) program prioritized smaller plants looking to become USDA-inspected, which further supported smaller processors in meeting the need for more independent, regional meat processing capacity.

9. Introducing the SARE Marker Bill and Other Research Advancements 

The Sustainable Agriculture Research and Education Program, or SARE, is a keystone program that supports and funds critical research to advance sustainable agriculture practices across the United States. NSAC strongly supports the SARE Program and is keen on supporting new marker bill legislation that will ensure that SARE receives adequate funding and support to continue to inform our agricultural system’s advancement towards a more sustainable landscape. NSAC hopes to set the stage for increased SARE and other research investments in the 2023 Farm Bill. 

Organic programs at USDA also saw significant investments this year, including $300 million dollars invested in the Organic Transition Initiative (OTI) which will help build new income streams for organic producers. Increased funding to OTI, and other similar programs, such as the Transition to Organic Partnership Program (TOPP), are already facilitating stronger organic producer networks to help organic farmers gain the top dollar for their products. NSAC is proud that many of its coalition members are strong partners within TOPP, and hope that their influence will continue to strengthen the transition of many producers to more sustainable organic systems.

10. Coming in 2023: The NSAC Climate Rally for Resilience!

The Farmers for Climate Action: Rally for Resilience was announced this year at the 38th annual FarmAid Concert, held in September 2022. Led by NSAC and supported by a number of other farm and food organizations from around the country, the Rally for Resilience, scheduled for March 2023, will be a mass mobilization of farmers and producers from across the United States demanding meaningful climate resilience action from the federal government. The entire slate of programming will include a march, rally and concert, and a fully lobby day dedicated to bringing attention to the critical role that farmers play on the frontlines of climate change. To be involved with NSAC’s efforts for the Rally for Resilience, click here. 

While successes have been plenty, there will certainly be tough battles ahead. As the 2023 Farm Bill reauthorization process gets underway, NSAC will be spending dedicated time and energy to ensure that the successes seen in 2022 continue to grow in the Farm Bill and beyond, all in line with the important proposals put forward in NSAC’s 2023 Farm Bill Platform. As we pause before the New Year, we want to take a moment to celebrate the monumental victories that our coalition has accomplished this year. We cannot do our work without the support and engagement of our members, allies, champions, and supporters. Thank you for a highly impactful year, and we look forward to creating more sustainable, equitable food systems change in 2023. 

The post NSAC’s Top 10 of 2022: A Year in Review appeared first on National Sustainable Agriculture Coalition.

The rising global tumult of the last several years – fanned by the COVID-19 pandemic and international conflicts – has had a myriad of consequences for our food system. One of the most prominent consequences has been the increase of food prices across the world. Among these increases, the price of some retail meats – which you find at a local butcher shop or supermarket – has risen well and above general inflation. Yet despite rising prices, many U.S. farmers and ranchers have seen relatively little, if any, increase – and in some categories a decrease – in their profit margins. 

So, where exactly is this money going?

In the modern era, consolidation in the food processing sector and specifically in the meat industry has been an issue since at least the 1970’s (further explained in our blog series here). While consolidation in the sector is not at all new, the COVID-19 pandemic, spiking inflation, international conflict, and heatflation have created circumstances for the remaining processors and vertically integrated food companies to claim that rising input costs are the reason for the rising price of meat. Yet, many agricultural economists note that this assessment is not fully accurate. While processors may often be paying higher labor costs for a variety of reasons, they are not paying much higher wholesale costs to farmers.

Fundamentally, food processing sector consolidation creates some efficiencies, but greatly diminishes the overall resilience of the sector, including the resilience of the farmers, ranchers, workers, families, and communities who depend on the sector for their livelihood. When timed with the rising food and specifically meat prices in recent years, the negative consequences of consolidation are on full display for all to see. This, in turn, has led to a long-overdue renewed interest in federal legislation that seeks to support farmers, ranchers, and small-scale independent meat processors, to create long term resilience in local and regional processing capacity. 

With the approaching 2023 reauthorization of the farm bill, there is a unique opportunity to reshape federal meat safety and processing policy in a more sustainable and resilient way in order to weather future supply chain disruptions. While not all needed improvements can be made through the upcoming farm bill reauthorization, it is nonetheless the next major opportunity and will serve as a continuing focal point of NSAC’s priorities. 

What follows is a roundup of federal legislation, some new and some old, that would positively impact meat production, processing regulations, and food safety inspection. Most of the bills are in response to the effects of consolidation across the meat industry, and how consolidation allows for upward price manipulation. NSAC has endorsed several of these bills, as noted below. 

Strengthening Local Processing Act – HR.1258/S.370 

The goal of the Strengthening Local Processing Act (SLPA) is to reshape current meat processing policy with an eye towards providing more resources to help small and very small  meat processing plants scale. The SLPA would increase funding for the development of small (under 500 employees) and very small (under 10 employees) processing plants, the states that inspect them, and the workforce necessary to sustain them.

The SLPA would increase the number of employees used to define the size of plants in the Poultry Products Inspection Act and the Federal Meat Inspection Act. It would further allow for a greater percentage (from 50 percent previously to 65 percent) of federal cost share to states that inspect and perform up to the same level of regulation for interstate cooperative shipment, and would provide greater reimbursement for inspections, from 60 percent to 80 percent. It also provides for size-appropriate hazard and critical point analysis across the breadth of the industry. Many smaller processors have noted the need for size-appropriate examples and HACCP guidance.

The SLPA would establish a Processing Resilience Grant program to bolster processing resiliency and development at the local level, via funding upgrades for small and very small plants. The SLPA would authorize $10 million per year in mandatory spending for the grants program, with up to an additional $10 million authorized through the annual appropriations process.

The plant infrastructure grant program is complemented by the creation of a new pipeline for workers through educational development grants, both for a range of educational institutions to provide workforce training, and to compensate small plants for providing this training themselves. The SLPA authorizes $10 million per year for each of these grants.

To date, SLPA has been referred to the agriculture committees in both the House and the Senate and has strong support across the aisle in both chambers of Congress, as well as NSAC’s endorsement. In the House, Representative Chellie Pingree (D-ME-01) continues to be a strong champion of this bill. Across Capitol Hill in the Senate, Senators Thune (R-SD) and Merkely (D-OR) have helped bring many of their colleagues onto the bill as well. 

Agricultural Resilience Act – HR.2083/S.1337

Led by Representative Pingree (D-ME-01) in the House and Senator Martin Heinrich (D-NM) in the Senate, the Agricultural Resilience Act (ARA) is a sprawling act that charts an entirely new vision for the sustainability and justice for our food system. This post focuses exclusively on the ARA’s processing provisions, but you can read more about the ARA in our Climate Policy Roundup and initial analysis in our press release. NSAC has endorsed the entirety of the ARA.

Two main sections of the ARA focus on meat processing and marketing. The ARA was the first legislation to introduce the idea of a Processing Resiliency Grant Program, that the SLPA (which was introduced more recently) now contains. As mentioned above, these programs would help bolster meat processing capacity in those plants best able to process a wide variety of livestock and poultry being used on sustainable, diversified farms. 

The second main processing section of the ARA includes provisions that push for clarity on animal raising claims for livestock and poultry. The current landscape is muddied as some claims have little to no regulatory verification, enforcement mechanism, or well accepted definition and can lead to confusion amongst consumers. The ARA would establish clear statutory definitions, verification methods, and marketing systems in order to promote transparency. 

Title V of the ARA includes a provision that would require USDA to develop rules for animal raising claims (like humane) and or diet claims (like grassfed). These would all be federal definitions and rules, though they could be verified by a third party if they meet the same minimum threshold as the government would follow for verification and enforcement of these claims. This section outlines fines for misuse of the claim, and other penalties. 

Processing Revival and Intrastate Meat Exemption Act – HR3835/S.2001

The Processing Revival and Intrastate Meat Exemption (PRIME) Act – led by Senator Angus King (I-ME) and Representative Thomas Massie (R-KY-4) – would allow meat that is currently slaughtered under a custom exemption to be sold to more than a single customer as long as the processor is in compliance with any relevant state law. Under federal law, custom slaughter is exempt from inspection if the processing is only for the animal’s owner. 

The PRIME Act would expand this exemption beyond the immediate owner of the animal, allowing the sale of custom exempt meat directly to consumers, restaurants, or other retail establishments within the state. While expanding the custom exemption would likely make it easier for small producers to sell directly to consumers and even other small local establishments with greater ease, it is unclear what impact it would have on sales to larger institutions who often require USDA- or state-inspected meat as part of their contracts. 

Likewise, while the bill would lower the compliance burden for local processors and producers – it does not help them start or expand their business. So if PRIME passes but there are no size-appropriate loans or grants to allow small meat processors to exist, it might be challenging for processors to utilize this expanded exemption, even larger processors in the area that have much of their process already aligned with federal requirements.

It has been introduced and referred to committees in both houses, with strong support within Congress with 48 sponsors in the House and 7 in the Senate.  

Butcher Block Act HR. 7606

Introduced by Rep. Dusty Johnson (R-SD-AL) during the heat of the 2021 summer inflation, the aptly named Butcher Block Act passed the House in summer 2022 as part of the Lower Food and Fuel Costs Act. It has not yet moved within the Senate other than being referred to the Senate Agriculture Committee. 

The Butcher Block Act provides a suite of loans and grants for expansion of processing capability across the US. The bill would authorize an appropriation of  $100,000,000 for each of fiscal years 2023 through 2025 for guaranteed loans and authorize an appropriation of $20,000,000 for each of fiscal years 2023 through 2025 for grants. 

However, there is no size limit on either loans or grants in the Butcher Block Act, nor is there any directive to focus on minority owned establishments as exists in the SLPA. The act provides significant discretion to the Secretary to develop the application approval process and does not have a focus on small and very small establishments. Other than limiting the maximum amount of loan available to a single organization – $50 million for organizations generally, $100 million for cooperatively owned businesses – it is agnostic to size. 

The Act would limit funds from being directed towards partially foreign owned enterprises; any processing company that exceeds a 5 percent ownership by a foreign group is ineligible.

Meat & Poultry Special Investigator Act HR. 7606/S. 2036 

The Meat & Poultry Special Investigator Act was originally introduced concurrently with the Butcher Block Act, as a part of the Lower Food and Fuel Cost Act initiated near the peak of our current wave of inflation. It passed through the House as part of that act, and has continued to move through the Senate as its own bill in a way that the other parts of that package did not. In the House, Rep. Abigail Spanberger (D-VA-7) was a champion while Senator Jon Tester (D-MT) again was leading in the Senate, as he often does on many key agricultural issues. 

This bill seeks to create an office and position to enforce the Packers & Stockyards Act, to investigate any potential violations of anti-competitive behavior, and to coordinate with the Federal Trade Commission (FTC) and the Department of Justice (DOJ) to enforce violations. 

This bill follows increasing interest in the regulation and prosecution of anticompetitive behavior, and would give the government more teeth to operate under its existing authority to do so. 

When paired with capacity-building funding for smaller plants, regulation of oligopoly power and anti-competitive behavior can ensure a more competitive, fair, and resilient marketplace. 

Cattle Price Discovery & Transparency Act – HR.7639/S. 4030

Senator John Tester and Representative Cynthia Axne worked together over the last congress to introduce and build support for the Cattle Price Discovery and Transparency Act in their respective chambers. This bill could help level the playing field for smaller producers, who often have less resources to negotiate the complex marketing process associated with cattle ranching.

This act strives to clear up murky industry practices in the cattle industry, such as practices that allow processors to exploit a knowledge difference that only they can have as a central part of the industry. This practice allows aggregators to manipulate cash markets and alternative market agreements (AMA). AMA is a lump sum term for a variety of practices that keep cattle out of cash markets but generally is used in regards to purchase contracts agreed to ahead of time and partially based on cash market price. 

Currently, large processors control upwards of 80 percent of the market, which increases their ability to hide pricing agreements via AMAs whereas everyone involved can see potential prices in auction or cash markets. Likewise, these auction prices are often tied into different types of formula pricing (x percent of this price means you get x at sale) for the AMAs. This arrangement is likely creating a scenario where large packers and processors are able to manipulate both cash markets and the price paid via AMAs by increasing or decreasing the amount of cattle being fed into live markets when it is advantageous to lower the price for them to do so. 

This bill would set regional price standards between producers, packers, and processors that would essentially establish a framework within which AMAs would be reported in a contract library, allowing for producers to have knowledge of industry price trends for AMAs. It would also create a better reporting process for the amount of cattle slaughtered daily, and for reporting daily cutout yield statistics as well. All of this is information that large packers would have to supply to the USDA who would then report it. This information would reduce the information asymmetry between producers and packers, and perhaps help ranchers achieve higher prices.

Small Family Farmers & Ranchers Relief Act (SFFRRA) H.R. 8590

Recently, in an effort to support small ranchers and farmers, Representative David Scott (D-GA-13), Chairman of the House Agriculture Committee, introduced this bill. It provides a variety of ways to help farmers and ranchers who have less than 100 heads of cattle in a way that none of the other bills discussed above do. 

SFFRRA lowers cattle insurance premiums for smaller producers by 2-25 percent, depending on the history of the specific small producer, with greater premium coverage reserved for small, beginning, and veteran farmers. 

The bill also includes a statistically based price support. When the farmer’s share represents less than 51.7 percent of the spread (the difference between the retail value and farmer-wholesale price), a payment of the difference between the current spread and the 80th percentile of the the 10 year rolling average spread will occur for every animal sold up until the 100th head.

Finally, this bill creates a grant program with maximum grant awards of $500,000 and significant discretion for the farmer to decide how to spend the funds. From land to processing equipment, this act is designed to allow farmers, who understand their own operations best, to utilize the grants how they see fit to help reshape the meat policy landscape. Because of the maximum grant size; the focus on small, beginning, and veteran farmers; and the interest in farmer choice around use of the grant, we believe this bill could be helpful in expanding markets and processing capacity for more sustainable ranchers. 

This bill was introduced before the August recess and referred to the House Agriculture Committee, though it has seen no further action since that time. This bill will hopefully garner support on its key provisions before the end of the year. 

Roundup

NSAC strongly endorses the Strengthening Local Processing Act as a central vehicle for transformation of the livestock industry given its comprehensive approach and equity focus. While the other bills would open new small markets, create better rules of the game, or solve a myriad of other issues, we believe that the SLPA addresses some of the most important issues at the heart of the industry.  Size-appropriate infrastructure, technical assistance for plants, and funding to develop a skilled workforce are all critical needs acknowledged across the industry. Building out plants that allow for smaller, diversified farms to market their livestock, improve their soil health, and improve their bottom line is a key component of creating a more sustainable food system. The parts of the ARA that mirror the SLPA and all of its provisions would help improve the marketing and production of sustainably raised livestock.

Many of these bills will help bolster other parts of the industry, including marketing of livestock products from smaller processors and producers.  NSAC looks forward to their continued development over the upcoming Congressional session, and their reintroduction in the following session. Specifically, the Butcher Block Act, if targeted more precisely towards smaller plants, and the Small Family Farmers & Ranchers Relief Act, if expanded beyond cattle, would be welcome additions to smaller-scale sustainable producers and the processors that work with them.

The post Getting Into the Meat of It: A Roundup of Livestock and Poultry Reform and Resilience Bills appeared first on National Sustainable Agriculture Coalition.

Contact: Laura Zaks

National Sustainable Agriculture Coalition

lzaks@sustainableagriculture.net 

Tel. 347.563.6408

Comment: NSAC Responds to the Lower Food and Fuel Cost Act – H.R. 7606

Washington, DC, June 17, 2022 – Today, the National Sustainable Agriculture Coalition (NSAC) issued the following comment, attributable to Eric Deeble, NSAC Policy Director, in response to the Lower Food and Fuel Cost Act – H.R. 7606 which passed yesterday in the House. 

“The National Sustainable Agriculture Coalition (NSAC) applauds the House for taking decisive action to support the creation of a United States Department of Agriculture (USDA) special investigator to enforce fair-play rules in the highly concentrated meatpacking industry when they passed the Lower Food and Fuel Cost Act – H.R. 7606 on Thursday. This fundamental reform would create the “Office of the Special Investigator for Competition Matters” within the USDA Packers and Stockyards Division, which oversees the implementation of the Packers and Stockyards Act.”

This office would address anticompetitive practices in the meat industry by facilitating the coordination and consultation between the USDA, the Department of Justice, and the Federal Trade Commission. NSAC is particularly pleased to see that the House version includes the poultry sector. NSAC urges the Senate to support the creation of the Office of the Special Investigator for Competition Matters when they meet next week and to provide appropriated funds to ensure USDA can build a team of professionals and lawyers dedicated to implementing and enforcing antitrust and anti-competitive rules.”

###

About the National Sustainable Agriculture Coalition (NSAC)

The National Sustainable Agriculture Coalition is a grassroots alliance that advocates for federal policy reform supporting the long-term social, economic, and environmental sustainability of agriculture, natural resources, and rural communities. Learn more and get involved at: https://sustainableagriculture.net

The post Comment: NSAC Responds to the Lower Food and Fuel Cost Act – H.R. 7606 appeared first on National Sustainable Agriculture Coalition.

For the past two years, the role of smaller-scale meat processors has received significant attention because of supply chain disruptions and challenges resulting from the COVID-19 pandemic. While small and mid-sized meat processors are critical to building resilient regional food systems, they face limited access to capital for expansion, a complex regulatory environment, and a highly consolidated livestock sector.

Even before the pandemic, policymakers and advocates were focused on the needs of these important food system stakeholders. A section was included in the 2018 Farm Bill requesting that a university or college conduct a study on the US Department of Agriculture’s (USDA) Food Safety and Inspection Service’s (FSIS) guidance, tools, outreach, and responsiveness to small processors’ needs. The study was completed by Oregon State University’s Niche Meat Processor Assistance Network (NMPAN), a program of OSU’s Center for Small Farms and Community Food Systems, an NSAC member, in December 2020. 

Upon the release of the report, USDA’s FSIS wasted no time in addressing some of the recommendations listed in this report. In February 2022, they announced that their Hazard Analysis Critical Control Points (HACCP) Validation webpage has been updated to include validation studies that can be used to support HACCP plans for fermented products, salt-cured products, and dried products. This change was made in direct response to the study’s recommendation that FSIS make peer-reviewed studies, required to be included in a small plant’s HACCP plan, more accessible for small processors.

The National Sustainable Agriculture Coalition (NSAC) helped convene and co-facilitate the small processor roundtables that brought nationwide producer and processor perspectives together to inform the study. The issue of access to HACCP validation studies then rose to the top of small processors’ concerns. NSAC applauds FSIS for acting quickly to ensure small processors have access to some of these resources, which are often a costly regulatory requirement. NSAC also advocated for these resources to be publicly accessible to regulated processing establishments in the Strengthening Local Processing Act and looks forward to working with both FSIS and Congress to increase the number of validation studies that processors have access to, in order to reduce the regulatory cost for small processors. 

Small Plant Study Recommendations 

The 2018 Farm Bill Small Plant study reported that small processor stakeholders found the inclusion of HACCP plan validation studies to be a costly requirement. Small processors must include these scientific research studies in their required HACCP plans, and subsequently, plans and spent a lot of time and money trying to gather the studies, which hopefully FSIS inspection personnel then approve. Processors have to pay for access to these studies, which can cost a significant amount of money. 

The study recommended that FSIS could improve upon their information tools available for small processors by creating a searchable archive of peer reviewed validation studies for various products. It also recommended that FSIS work with universities and cooperative extension to assist small processors with the requirements to include this peer reviewed research in their regulatory plans. These resources would reduce the regulatory burden small processors face with HACCP plan validation studies. 

FSIS Updated HACCP Validation Information 

FSIS recently added additional resources to their website in response to the small processor HACCP validation study access request. Now, small processors have access to a longer list of FSIS supported HACCP validation studies and, for the first time, links to all publicly available studies for certain products. FSIS also included a list of university and extension contacts that can provide HACCP and HACCP validation assistance to small processors, which can be found here.  

FSIS announced that these website changes were in response to both the study recommendations, and the National Advisory Committee for Meat and Poultry Inspection (NACMPI) Subcommittee on Validation of ready-to-eat (RTE) shelf-stable multi-hurdle lethality treatments recommendations. NSAC appreciates FSIS’s efforts to incorporate stakeholder feedback on this important topic.  

The regulatory requirements for HACCP plans require processors to control identified risks to ensure the meat or poultry product is safe for human consumption. Validation studies are a required part of HACCP plans to confirm all hazards are adequately identified and that the controls in place are scientifically proven to reduce the risk.  When they were initially required in the late 1990s, HACCP plans had a costly impact on small processors. Small processors struggled to support these new regulatory costs in their business plans, leading some to go out of business. 

The updated FSIS web page is an important step towards ensuring small processors have the resources they need to support their HACCP plans and that they can continue providing safe, local and regional meat and poultry products for farmers, ranchers, and consumers. 

Next Steps and Additional Recommendations 

NSAC looks forward to working with FSIS to continue to expand upon these important HACCP plan resources. The updated list of publicly available validation studies can continue to be improved upon and expanded. Not every study has a publicly accessible link, and FSIS can continue to provide these links for products to further reduce this regulatory cost. FSIS can also work with stakeholders to ensure this resource is organized in a way that makes sense to small processors and add additional studies to the list based on stakeholder input. 

NSAC also urges Congress to consider including Section 2 of the Strengthening Local Processing Act in the upcoming Farm Bill. This would provide FSIS with the resources they need to create a more comprehensive and fully accessible list of validation studies for small processors.

The post Food Safety and Inspection Service (FSIS) Releases New Resources for Small Processors appeared first on National Sustainable Agriculture Coalition.

Contact: Laura Zaks

National Sustainable Agriculture Coalition

lzaks@sustainableagriculture.net 

Tel. 347.563.6408

COMMENT: NSAC Responds to the FDA’s Proposed Rule Regarding the Agricultural Water Provisions of the Food Safety Modernization Act

Washington, DC, December 2, 2021 – The National Sustainable Agriculture Coalition (NSAC) issued the following comment, attributable to Eric Deeble, NSAC Policy Director, in response to the US Food and Drug Administration (FDA)’s proposed rule published today that would revise the Food Safety Modernization Act (FSMA) Produce Safety Rule to change certain pre-harvest agricultural water requirements for covered produce other than sprouts:

“For over a decade, NSAC has been working to ensure that important food safety guidelines for farmers are sufficiently simple, flexible, and centered on risk. We are closely reviewing FDA’s newly released proposed Agricultural Water Standard rules now. It is our hope that the proposed agricultural water assessment approach will allow farms to individually assess their risks and tailor mitigation methods to each farm. Upon initial review, we appreciate the agency’s move away from the previous rule, which was too focused on a set number of tests and a testing regimen that would have resulted in significant and disproportionate costs to small, diversified farm operations. 

At its core, this rule continues to place the burden of assessment and mitigation of hazards solely on fruit and vegetable farmers. Problems with agricultural water quality need to be addressed at a societal and systemic level, instead of expecting farm by farm enforcement to correct a problem that originates upstream. The Coalition also remains concerned about the rule’s encouragement of chemically treated water and the potential environmental impact of this element of the rule.

We urge FDA to continue to listen to the diverse range of farmers affected by this rule and collaborate closely with their colleagues at USDA to ensure that all producers are aware of this comment opportunity. 

We look forward to further reviewing this rule and gathering feedback from our members on the impact it will have on sustainable, diversified farm operations.” 

###

About the National Sustainable Agriculture Coalition (NSAC)

The National Sustainable Agriculture Coalition is a grassroots alliance that advocates for federal policy reform supporting the long-term social, economic, and environmental sustainability of agriculture, natural resources, and rural communities. Learn more and get involved at: https://sustainableagriculture.net

The post COMMENT: NSAC Responds to the FDA’s Proposed Rule Regarding the Agricultural Water Provisions of the Food Safety Modernization Act appeared first on National Sustainable Agriculture Coalition.