Our Comments to the USDA Regarding Meat and Poultry Processing Infrastructure

On July 16th, 2021 the USDA opened formal comments for reducing competition in meat and poultry processing. It is open until August 30th, 2021. We encourage you to consider how bottle-necks in meat processing affect your prices and availability to locally, and regeneratively raised pastured proteins. Submit your comments here. Every voice counts.

Our letter:


Hello,

My family farms near Ivanhoe, Minnesota, I am a member of the Minnesota Soil Health Coalition, and own a land management and consulting business. Many of my customers, fellow coalition members, business clients, and I believe that the USDA has over-regulated meat production with safety standards that stifle new entrants and favor concentrated animal feeding operations (CAFO). The standard CAFO places animals in unsanitary conditions that require them to bed in their own waste. They are fed unnatural substances that cause sickness and new forms of ecoli to grow in the unbalanced rumen of cattle. In terms of animal cleanliness and well-being a CAFO is greatly inferior to a pasture or small barnyard. A great book was written by Michael Pollan called ‘The Omnivore’s Dilemma’ which details his research and that of others on this matter.

It is well documented that livestock can help resolve many of our environmental concerns and bring profitability back to small farms. Studies on topics related to regenerative agriculture and adaptive grazing techniques show the critical role ruminants play with plants and microorganisms in our soil. Ecologist, Allan Savory of the Savory Institute, has been reclaiming degraded topsoil since the 1960’s using livestock. Today, thousands of farmers and ranchers are applying these principles to restore native grasslands and repair degraded soils. Pastured livestock are much healthier and able to act out their natural instincts while selecting from diverse forages. Dr. Fred Provenza’s book ‘Nourishment’ cites many reasons for putting animals back on the land for their health and human health. We now know that grass fed beef has up to 55 times the concentration of healthy Omega-3’s compared to CAFO cattle consuming distiller grains. Also, a new study published by Dr. Provenza and Dr. Stephan van Vliet of Duke University, shows that when compared with plant-based meats, grass-fed beef contains more nutrients [1]. This improved nutritional content starts with the microbiology in the soil which transfers to plants, the livestock, and ultimately to the consumer eating meat.

The point I’m making with this is that society has a lot to gain from getting livestock back on the pasture. The major barrier and cost however is the USDA’s food safety regulations. Farmers and ranchers today are not allowed to process cattle or hogs on their own land and sell directly to consumers. Regulations meant to protect consumers from dirty and unhealthy CAFO animals are applied evenly to farmers and ranchers raising livestock in open air and on clean forages. This shouldn’t be the case. Farmers and ranchers need the ability to slaughter and process livestock on their property and to sell directly to customers. These facilities do not need to be as closely monitored, because the animals are much cleaner and healthier. Most states still allow some chicken processing on farms and that is a model we can look to. Limits on chicken processing, however, should also be removed.

It would be helpful, however, to have many more small slaughter and processing facilities. Again, the facilities that focus on pastured proteins should receive reduced regulation when compared to the CAFO. Another bottle-neck in processing is the skills needed to be a butcher. The knowledge of making standard cuts from cattle and pork takes time to learn and master. The USDA could use some of these funds to create learning applications and recruit young people to this lucrative career. I am not familiar with required certifications to become a butcher, but if there are any, that should be assessed and reduced if possible. Consumers can choose for themselves how they want their beef raised, handled, and cut. We should use the USDA’s funds to educate consumers on how to form direct relationships with farmers and what to look for when choosing an operation to purchase from.

Overall, the best outcome of these funds would be to empower farmers, ranchers, and consumers through education. Burdening farmers and ranchers with loans for more structures is not the answer. Reduced regulation will allow small pastured operations to be more profitable and to even consider converting monoculture crop land into diverse grasslands that will support healthier ecosystems. These ecosystems will provide habitat to endangered and highly beneficial microorganisms, insects, birds, and mammals. As farmers and ranchers are allowed to run livestock more profitably we will see reduced field runoff and erosion into our water supply, decreasing the Dead Zone in the Gulf of Mexico.

Thank you for your consideration,

Jason Wisniewski

Director of Operations – Regenquity

Member – Minnesota Soil Health Coalition

[1]https://www.nature.com/articles/s41598-021-93100-3

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