Compliance Versus Circumventing

The purposes of government regulations for the inspection of meat and poultry products are to:

1) prevent the sale of adulterated, contaminated, or otherwise unsafe livestock products; 2)
prevent misbranding; 3) ensure the safety of consumers by establishing minimum standards for
the production, slaughter, processing, and marketing of these products; and 4) create a system of
licensing, inspection and labeling to trace a product back to its origin if a public health problem
should arise.

An inadvertent side effect of increased regulation and validation is that smaller processors and
farmers may be disproportionately disadvantaged due to economies of scale. For example,
validation equipment is often expensive to purchase and maintain. The smaller volume of output
of smaller plants results in these plants incurring a greater overhead expense on a per pound
basis.

This negatively affects producers and conflicts with the stated aim of our New York agricultural
agencies to increase the sales of value-added farm products. However, a close study of the meat
statutes reveals some exemptions and alternatives that can benefit the small farmer and processor
who are marketing slaughter animals or meat products.

It is far better to have an excellent understanding of the meat regulations and to diligently
study any changes in their interpretation rather than to focus on circumventing them and
risk trafficking in illegal or unsanitary products.

Advocates for the New York livestock industry need to build strong communication channels
with meat inspectors. There is a formal review process for proposed changes in the wording of
statutes. These livestock industry advocates need to rapidly apprise farmers and small processors
when such regulatory reviews are ongoing and find ways to motivate the affected parties to
participate in the process. There are no formal regulatory review procedures when the
interpretation of a regulation is being changed. This is unfortunate, because even a small change
in interpretation can have damaging implications for farmers and processors. Making sure
livestock farmers are knowledgeable about the current regulations governing meat products and
slaughter is a positive first step at improving their ability to communicate effectively with
officials.