April 14, 2010

Docket Clerk, FSIS

Room 2-2127

5601 Sunnyside Avenue

Beltsville, MD 20705

Dear Mr. Alfred Almanza,

Bishopp Family Farm respectfully submits these comments regarding the Draft Guidance on HACCP System Validation that were publically released on March 19, 2010.

As a 5^th generation farmer, NY Farm Bureau member and 2010 New York State Century Farm Award recipient  who depends on the meat industry and in particular small, local, community-based family sized processors like Leona Meats, Kelley Meats and Steiner Brothers, our concern regarding process validation in inspected establishments with HACCP programs have prompted me to express my discontent. 

Through communication with our trusted butchers and other concerned meat processors it has become apparent that initiating systems validation in these establishments would negatively effect our business as well.  It is our belief that this proposed guidance will cause many of the federal and state inspected processing plants that we rely on to be forced out of business because of undue costs and pass these increased costs onto us and ultimately putting our business “behind the eight ball” in getting our grass-finished meats into a burgeoning market.  The loss of income resulting from this regulation will be devastating to our family farm because our business depends on these trusted, local, meat craftsman.

 I am in agreement with this quote:

 “This initiative has the capability of removing a majority of the remaining very

small and small meat industry establishments from inspection. It will hinder

commerce. It will stifle the meat industry by removing the variety of products

currently available. It will obstruct the production of any new products from

being produced and be commercially available in commerce. It will raise the cost

of the products being produced, thus the overall cost the consumers will pay. It

will cause establishments to cut jobs as they downsize due to the lack of

inspected meat product production. It will force more of the meat industry to

put more products out of the current reach of inspection an into retail

exemption”.  - Jay B. Wenther, Ph.D President  American Association of Meat Processors

My issue with this regulation and its unintended consequences is over food sovereignty and our family’s desire to produce and sell sustainably cultivated grass-based meats in our immediate community, to schools and our state.  This regulation stifles and burdens the “little” guy once again and continues to concentrate processing power to a few.  We want to become bigger and better, but that can only happen as our smaller processing facilities continue to grow with us.

Mr. Almanza, Do you realize how busy our farm is right now in the springtime?  I am distressed and saddened that in lieu of sleep and mending fences I must become, once again, politically active, and speak out against this regulation that totally misses the common sense part of our’s and my fellow abattoir’s, passion and hard work to feed our citizens.  We don’t fit in your nice and tidy box, so making the playing field conform to undue constraints is ridiculous.

I feel its time to have a true brainstorming session with the folks you are trying to mandate.  Repeal this initiative until you have asked the people in the field how it can be made better.  These important decisions should never be taken lightly as we are out here on the front lines making sustenance from sunshine and grass while creating an environment that respects Mother Nature and future generations of eaters. 

These two quotes sum up my view on the situation that will ultimately affect my grandchildren:  “A good decision should be based on the results in seven generations” and “The end result should love all the children, yours and mine”. 

Bishopp Family Farm appreciates the chance to comment on the Draft Guidance on the HACCP System Validation regulation.  Thank you for your time and consideration.   

Sincerely,

Troy Bishopp, Bishopp Family Farm