For small meat businesses in America, catastrophic events result from changes high up in the regulatory food chain that make it very difficult for small plants to adapt. The most recent extinction event occurred at the turn of the millennium, when small and very small USDA-inspected slaughter and processing plants were required to adopt the costly Hazard Analysis and Critical Control Point (HACCP) food safety plan. It has been estimated that 20 percent of existing small plants, and perhaps more, went out of business at that time. Now, proposed changes to HACCP for small and very small USDA-inspected plants threaten to take down many of the ones that remain, making healthy, local meats a rare commodity.

The intent of HACCP is to prevent contamination of meat by harmful pathogens. Plant HACCP plans are approved and overseen by the Food Safety and Inspection Service (FSIS), the inspection arm of the U.S. Department of Agriculture. On March 19, 2010, the FSIS published a draft guidance document on HACCP system validation, outlining new rules which would institute regular, year-round testing of all meats, whether or not problems have been identified. The proposal recommends testing for testing's sake, and it will cost small plants tens of thousands of dollars, perhaps even hundreds of thousands, every year. The financial burden appears great enough that this will destroy much of the remaining community-based meat processing industry, which is enjoying a renaissance and creating jobs.

Small, local meat processors have always supported food safety. At our plant, we have had a functioning HACCP plan since 1999, and it works. We undergo extensive E. coli testing every year, and we have never had a positive result—ever. The purpose of HACCP is to employ well-recognized, established processes and process-control parameters to produce safe meat products—processes and parameters recognized and published by the USDA itself. Now, for some reason, the USDA wants to test the system and require excessive end-product microbiological testing, rather than allowing us to depend on these well-recognized procedures. Perhaps a large plant slaughtering 5,000 animals per day can afford its own lab and microbiology staff, and can pass the cost along to the consumer, but most small plants can't. And perhaps large plants should open labs—those are the plants where a massive beef recall can involve millions of pounds.

In my opinion, the USDA needs to recognize that "one size fits all" inspection no longer fits current industry practice and consumer demand. These new HACCP requirements are going to cause a train wreck in a portion of the industry that is growing for the first time in years, and then the USDA is going to have a serious embarrassment on its hands. Someone needs to take a clear-eyed look at this situation and find a way to split the agribusiness mega-plants from the community-based localized plants within the regulatory structure.