AAMP Executive Director Chris Young was in Washington D.C. on Tuesday, February 20th to meet with FSIS Acting administrator Paul Kiecker and members of his policy staff. Young was Joined by two representatives of the North American Meat Institute. There were several items discussed of importance to the industry surrounding policy and guidelines, but the main focus of the meeting was the Revised Appendix A&B.
Both associations expressed several concerns with the document including the science behind it, why FSIS felt the need to move away from the original guidance and how FSIS came up with the number of 500 samples in order to validate and verify any differing process. The outcome of the meeting is that FSIS is continuing to work on responding to the comments and is open to the industry providing scientific opposition to science they have based the new guidance on as well as working with industry as they finalize the document. FSIS also agreed to provide industry and inspection personnel with a notice to clarify that industry is able to use the original Appendix A&B while the revised guidance is being finalized. This is a win for us, as there will be a clear message going out to both industry and inspection.
As of now we have not seen that notice, and FSIS has reached out to discuss the issues AAMP has with the Revised Appendix A & B after reading AAMP’s comments. Young made a phone call with FSIS Policy staff to discuss the issues small plants face and how the enforcement is not consistent or clear. Young expressed again a need for a notice to the industry and inspection that we did not need to follow this until FSIS had reviewed all comments and finalized the document. Young was told that FSIS management was working on the notice, and we should see something soon. Be looking for AAMP to publish this notice in the near future across all of its media outlets. If you have been asked to change your HACCP plan to meet the new guidance document, you do not need to.
FSIS and AAMP have begun working more closely on other issues. FSIS has reached out to AAMP recently and asked for our input and insight on some guidance documents that were up for comment at the end of last year, and FSIS is preparing to respond to those comments and issue the new or revised guidance documents. AAMP has expressed a desire to help FSIS as it reviews policy and guidance documents and creates new ones. AAMP would offer our thoughts on how they would impact small processors and make suggestions on changes that would still allow FSIS to achieve what they would like without as much impact on small processors. Moving forward AAMP and FSIS have agreed to meet at least quarterly and more frequently as needed as issues arise. We are encouraged by the open and honest lines of communication that is happening and look forward to continued conversations on behalf of small processors.
Identifying regulatory reform initiatives at USDA
Here is a chance for your voice to be heard. We would encourage AAMP members as well as any other processor to express your thoughts to FSIS during this comment period. We always talk about having a voice, and now is our chance. We need to all comment on the regulations that we feel are unfair and need revision. AAMP will have discussions with FSIS based on industry comments, but it carries more weight and shows a greater need when more people are saying some of the same things. It only takes a few minutes online to submit your comments and let them know what you think. It is time to take a stand and let your voice be heard.
On July 17, 2017, USDA published a request for information, Identifying Regulatory Reform Initiatives, in pursuant with Executive Order 13777—Enforcing the Regulatory Reform Agenda. USDA is requesting ideas from the public on how to provide better customer service and remove unintended barriers to participation in our programs in ways that least interfere with our customers and allow us to accomplish our mission. USDA is asking for public ideas on regulations, guidance documents, or any other policy documents that are in need of reform, for example, ideas to modify, streamline, expand, or repeal those items.
Comments and information are requested on or before July 17, 2018. USDA will review comments in four batches over a one-year period. The cut-off period for comments for the last batch is July 17, 2018.
Comments can be submitted the following two ways:
- You may submit comments electronically through the Federal eRulemaking Portal at: http://www.regulations.gov.
- Submission of comments by mail, hand delivery, or courier: paper, disk, or CD-ROM submissions should be submitted to Office of Budget and Program Analysis, USDA, Jamie L. Whitten Building, Room 101-A, 1400 Independence Ave. SW., Washington, D.C. 20250.
For proper delivery, in your comment specify “Identifying Regulatory Reform Initiatives.” For more information, please visit https://www.feder