Spring/Summer 2010 - Robert M. Kerr Food & Agricultural Products ...

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Food Industry arious necessities such as food, water, and energy affect our daily lives, and the way we live. Far too many people are removed from direct contact with the production and distribution of these daily necessities, and do not understand the manufacturing processes. They take for granted the ease of food, water, and natural resource consumption. The United States has the most abundant, easily accessible, and safest food supply in the world. Americans also are fortunate to have an abundant supply of energy and potable water. Many think the cost of water and energy is too expensive, but if you realize these are not evenly distributed by nature, but by man, it makes the cost more easily understood. We, as a nation, have been blessed with wonderful natural resources. However, the food industry has not been so blessed. The increasing cost of following the rules and regulations of the United States Department of Agriculture, Food Safety and Inspection Service, and the Environmental Protection Agency or Department of Environmental Quality has drained 8 | fapc.biz the pocketbooks of small- to mediumsized food processors. We must meet certain standards in our daily operations of production, distribution, and storage of goods. The non-meat products also must meet certain standards, including water. The government also expects us to educate the American consumer on food safety. It is a large problem for meat processors. Once the product leaves the facility, whether to the ultimate consumer, grocery store, restaurant, or any other customer, the processor has no control over how the product is treated and if it is kept safe. We should not be expected to follow the customer home and watch over their household food supply. These changes keep growing like a snowball going downhill without a bottom and keep getting bigger and rolling faster. I have been associated with the meat and livestock industry for more than fifty years. Changes have always been a part of meat processing; however, changes have been coming at a greater speed and in greater numbers the last ten to fifteen years. The changes are like a snowball rolling downhill; they just keep growing. The problem is this particular hill has no bottom. Therefore, this giant snowball is going to keep getting bigger and faster. USDA and FSIS Being a small meat processor, many of the mandated government policies for food safety are not necessarily hard to overcome, but can be very expensive. I am not against food safety, but a firm believer. However, many avenues the government is using to enforce food safety are expensive, and I think redundant. On the horizon for meat processors is Validation of Processes. Validation is the process of proving your Critical Control Points, or CCP, of your Hazard Analysis of Critical Control Points, or HACCP, plan is valid and true. To do this, plants will need to retain meat scientists on staff or hire an outside company to validate all HACCP plans the company uses. This “idea” is directly opposite to currently accepted HACCP practices. At the present time, we can use proven scientific studies from government research facilities to validate our HACCP processes. For example, it has been proven many times by the scientific community, the lethality stage for Escherichia coli O157:H7 is 160 degrees Fahrenheit. However, according to government policy, this may not be a valid CCP in my HACCP program, and I may need to hire an outside company to validate this process. Small establishments do not have the capital and resources to initiate a
validation study on the processes in their facility. The problem to a small, limited budget processor is the cost of a professionally documented study, which has a estimated cost of $9,000 to $15,000 each. In our case, if we are required to do a validation study for each of our HACCP programs, it will consist of sixteen different studies. At the above estimated cost, we will be looking at a tremendous outlay of cash. Since there are proven studies by the scientific community, I think we shouldn’t have to recreate the studies in individual processing companies. If this goes forward as FSIS wants it to, there will be more and more small processors electing to go retail exempt, or only sell wholesale to the amount of $54,300 per year, and do away with state or federal inspection. EPA and/or DEQ Another government agency causing a monetary hardship to small meat processors is the Department of Environmental Quality, also known as the Environmental Protection Agency. These state or federal agencies are not new to our country, but have matured and grown quickly. Water quality is of great importance. However, in this modern environment, the required laboratory testing of water samples is a costly and burdensome endeavor. Small businesses do not have the financial ability to have an in-house laboratory or the technical personnel to comply with the required guidelines set by the government. In our small business, the combined costs of testing required by the DEQ and the USDA totaled $5,000 for 2009. I know we cannot do away with testing of food and health safety. Nevertheless, it is very frustrating when multiple samples must be taken from the same source and sent to the same laboratory for DEQ. DEQ’s reasoning is the samples must go to different testing labs within the department and cannot be shared by the various departments. This is another example of bureaucratic wastefulness, which places the burden of work and proof on small businesses. Ultimately, these costs will be passed on to the consumer as hidden costs, while the government mandates more and more testing to be completed. Managing the snowball I am an advocate of food safety, but I’m also a small meat processor who is trying to keep up with the changes. industry perspective By Gary Crane Ralph’s Packing Company tesscrane@suddenlinkmail.com These changes keep growing like a snowball going downhill without a bottom and keep getting bigger and rolling faster. All I know to do is hang on and stay in front of it. Spring/Summer 2010 | 9
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