Progress report for EDS23-051
Project Information
Even prior to the COVID-19 pandemic, access to processing was a significant barrier and risk for grass fed, pasture raised, and niche meat producers. A top reason sustainable agriculture producers could not access timely processing was and continues to be small plant shutdowns in the event of a humane handling violation. Small plants are shut down more frequently and for longer periods of time compared to large plants (Thistlethwaite 2021). This is partly due to the closer proximity of inspectors and the lack of regulatory support and training for small plants in comparison to larger plants. Small plants do not have teams of experts and attorneys to help them address a human handling suspension in a timely manner. As a result, these small plants might be shut down for days, weeks, or months. The impact of these shutdowns are devastating to the farm and ranch businesses that rely on scheduled slaughter and processing dates.
This project hopes to provide educational tools and training for farmers and processors to understand and manage their risks when it comes to humane handling regulations and preventing business shutdowns. Through a guide for farmers on humane handling regulations and issues, we hope to educate farmers about the legal requirements small slaughter and processing plants must comply with, as a number of farmers are considering more on-farm slaughter options due to the processing bottleneck. The guide will also include recommendations for farmers on next steps and preparations they can take to manage their business risks in the event of a small plant shutdown due to a humane handling violation.
There are also regulatory plans small plants can put into place to hopefully prevent a suspension in the event a humane handling violation occurs. Under an updated FSIS Directive, small plants can often avoid a suspension for a humane handling violation if they have an effective robust systematic approach in place and no history of multiple violations. Unfortunately, according to recent data, only 56% of very small plants and 81% of small plants have a robust systematic approach, compared to 100% of large plants (OBPA 2016). Smaller plants cited a lack of clarity from FSIS inspectors and a lack of resources as top reasons they have yet to adopt a robust systematic approach (Thistlethwaite 2021).
Our project will include resources for smaller plants to help create and strengthen their robust systematic approach plans. We will create a support guide with Q&A and tips on how to create or strengthen a small plant’s robust systematic approach. Our team will utilize their humane handling regulatory expertise and experience with robust systematic approach plans to ensure the educational materials are targeted towards small processors for multiple species of grassfed livestock. Through these resources, we hope more small plants in Arkansas and Oklahoma will adopt their own robust systematic approach to ensure that sustainable farmers and ranchers in these states are not impacted financially by small plant shutdowns from humane handling violations.
- Identify key humane handling and slaughter regulations and legal risk management tools for compliance with these regulations that will be included in the educational resources.
- Construct a guide for farmers in Arkansas and Oklahoma on the humane handling and slaughter requirements for farmed animals.
- Create a support guide for small processors on how to implement an effective robust systematic approach, among other tips and information.
- Host a half day virtual workshop for farmers and processors in Arkansas and Oklahoma on humane handling and slaughter requirements and best practices.
- Assess all educational resources’ effectiveness in helping farmers, including those exploring on-farm slaughter, and processors manage their risks when it comes to humane handling and slaughter regulatory requirements.
Cooperators
- - Technical Advisor
- - Technical Advisor
Education
Our approach has been to gather feedback from the target audience as we draft the educational materials to ensure it is understandable and relevant to the farmer and processor audience needs. We had a producer draft an outline with the key areas that would be helpful, and met to discuss what key legal areas should be expanded upon based on that interest. Then, once the outline draft was finalized, we shared it with a local processor and other experts and received a significant amount of feedback that we incorporated into the outline and the draft of the Humane Handling Legal Guide.
We have been working with a LL.M. in Agricultural and Food Law Graduate Assistant on the drafting of the Humane Handling Legal Guide. This has included guider the student through navigating these laws and writing for a farmer audience. The student took the outline, which we received processor and farmer input on, and drafted based on this feedback, which provided them with the experience of working directly with the industry they hope to work in one day.
We have had bi-weekly meetings with key team members to revise and shape the draft. We are in final editing stages before sharing it more widely with our farmer, processor, and other key expert reviewers.
Educational & Outreach Activities
Participation Summary:
The project’s target audience includes: 1) Arkansas and Oklahoma sustainable livestock producers; 2) the small processors these producers rely on to slaughter and process their livestock; 3) new small processors, including on-farm processing at any level of inspection, such as custom exempt processors; 4) new and long-term employees at area small processors who hope to expand their humane handling and slaughter knowledge. Our project team includes stakeholders that fall into these categories as well.
We will conduct outreach for the farmer guide and processor guidebook in a variety of ways, including through local and more regional networks. Team members Manning and Wells will share the guides and assessments with the local Grassroots Grazing Group and their processing networks. NCAT will share the guides and assessments with NCAT’s network of Arkansas and Oklahoma farmers and ranchers and processors. The Cypress Valley Meat Company will also share the guides with its farmer and processor network. We hope to share this more widely than Arkansas and Oklahoma to hopefully serve as a model of a practical, clear guide to humane slaughter regulations which could be replicated for other regions. The team members from the Law School LL.M. Program in Agricultural and Food Law will share the guides on the Oregon State University Niche Meat Processor Assistance Network and other processor networks. Each project team member will share the guides and assessments on the guide’s effectiveness with their sustainable agriculture networks. The guides will be published both online and in-print, and shared at organizational meetings and future educational opportunities.
Our outreach plan for the half-day workshop includes scheduling the workshop date during the slower season for area processors and farmers and ranchers to ensure maximum participation is possible. The virtual setting will also allow for maximum participation because COVID-19 precautions, venue expenses, and travel cost will not be a barrier to participation. We hope through a virtual format, we may even be able to expand our reach beyond Arkansas and Oklahoma, and into other key Southern SARE states with significant sustainable livestock production.
The workshop will provide interactive discussions, lessons learned, and best practices - as participants will have ample time to learn from one another. 50 participants will allow for smaller breakout discussions and more interactive education opportunities. However, we will allow up to 100 participants, and include more of the project team to help moderate discussions, if needed.
We will set up workshop registration months in advance of the date, and share the registration information via the methods described above. The workshop educational materials will be supplemental to the guides, and participants will take a deeper dive into this complex regulatory information.
We will receive workshop support from Dr. Shawna Weimer, the Director of the Center for Food Animal Well-being at the University of Arkansas Division of Agriculture, who will volunteer to present and assist with farmer and processor outreach and education.
In the future, we hope the workshop could be replicated in person at state meat processing association conferences, and other relevant educational events.
We hope the farmer and rancher guide’s clear regulatory information, checklists, and examples will provide practical information that will allow farmers to understand and apply this information to their operations. The guide will educate sustainable livestock producers about these regulatory requirements for their own slaughter pursuits, as well as their communications with area processors and curious customers about the slaughter process. Farmers will learn from the guide and workshop about the support and practices they can pursue that will ensure compliance at their small processor. The workshop and guide will also focus on methods to mitigate farmers’ business risks in the event their small processor is suspended.
The support guide for small processors will provide examples and a Q&A and tips, to ensure any small processor is able to have a robust systematic approach, which will mitigate the risk of a humane handling violation and suspension. Given compliance with the regulations is often dependent upon the rate of human error at a facility, the guidebook will help ensure there are clear steps to take in the event a mistake does occur, which can mitigate the impact of that mistake.
We also hope both guides will provide clear examples that are applicable to current and new small processors’ employees. Our vision is that both guides will be adaptable for a more thorough handbook and training for processing plant employees.
As mentioned, the risk of a small processor shutdown from a violation of these requirements could impact all area direct-marketing farmers and ranchers trying to process their products at that facility. By taking a systems-based approach, we will support a critical supply chain sector that sustainable livestock producers rely on for their viability, while also educating farmers and inadvertently some consumers about the regulatory requirements specific to animal welfare.
Our complete outreach plan also includes: Press releases, blog posts, future conference presentations and webinars, printed handouts, and other efforts to reach small processors, farmers and ranchers, and relevant organizations in Arkansas and Oklahoma.
The following team members will be our outreach leads:
National Center for Appropriate Technology (NCAT) is a national nonprofit organization which conducts training and outreach in sustainable and organic agriculture, with staff in
10 states, including the Southeast Regional office in Arkansas. NCAT will conduct outreach to area farmers on the guides and share widely the virtual workshop registration. NCAT has relationships with farmers and grassroots farm organizations and NCAT’s Southeast Regional staff work closely with livestock producers across Arkansas and Oklahoma. NCAT staff have also provided educational resources and training on topics such as processing regulations. NCAT’s Livestock Specialists Margo Hale and Linda Coffey will support the project by reviewing educational resources, promoting project webinars and publications, and connecting producers and processors to project materials. Hale and Coffey have extensive experience as sustainable livestock production educators and are both livestock producers. See their letter of support here: NCAT-AR LLM livestock LOC.
Lauren Manning (cattle, sheep, goats)
For the last seven years, Lauren has been a partner in Ozark Pasture Beef, a partnership of farmers selling grass-finished meats to local consumers in NW Arkansas. She raises cattle, sheep, and goats and routinely accesses local processing services. During the pandemic, Lauren was unable to continue providing meat to the community due to a lack of available processing services. Lauren is a member of Grassroots Grazing Group, a local group of sustainable pasture-based livestock producers with the goal of furthering production and marketing education.
Lauren is also an attorney with a background in civil litigation and a masters of law (LL.M.) degree in food and agriculture law and policy from the University of Arkansas School of Law. She now teaches in the LL.M. program as an adjunct covering courses like farm animal welfare and agricultural cooperatives law. In addition to her work in academia, Lauren is a senior associate at Croatan Institute, a non-profit research and action institute focused on the intersection of finance, farming, and food. Prior to that, she worked at AgFunder, a venture capital firm focusing on agrifood tech. She started as a member of the media/research team and eventually moved to the investment team. See her letter of support here: Lauren's LOS humane handling.
Ann Wells (beef) -
Ann co-founded Ozark Pasture Beef in 2000 and has direct-marketed pasture-raised, grass-finished beef and lamb to the NW Arkansas region ever since. Prior to OPB, Ann was a companion animal veterinarian then a large animal veterinarian while also running a sheep operation in Kansas. As an Oklahoma native, Ann has substantial experience in and connections to the regional agricultural community and has worked with countless small-scale processors throughout her career. Ann also has substantial experience participating in grant-funded projects in various capacities including a program lead, researcher, educator, and more. Ann is a founding member of Grassroots Grazing Group. See her letter of support here: LOS - SARE Education Grant Ann Wells.
Cypress Valley Meat Company is custom meat processor with multiple locations in Arkansas and NE Oklahoma serving small to medium-sized farmers and ranchers. They process cattle, hogs, bison, lamb, and goat in our facilities servicing customers with both USDA-inspection requirements and without.
Cypress Valley will support the project by participating in drafting and reviewing sections of the guidebooks or manuals and participating in the virtual workshop. Cypress Valley’s experience with sustainable livestock production, meat processing, humane handling regulations, and food safety in manufacturing will provide a wide range of expertise for this project. Chris Shaw, Director of Operations, and Kim Schroeder, Director of Food Safety and Quality Assurance, have over 30 years of combined experience in humane handling regulations and daily experience with USDA and livestock that will contribute significantly to this project. See their letter of support here: LOS Template - SARE Education Grant (1).
Shawna Weimer, Ph.D., Director of Center for Food and Animal Well-Being at the University of Arkansas Division of Agriculture, will also conduct outreach and support for this project. Dr. Weimer has experience, as a former extension agent at the University of Maryland Cooperative Extension, with conducting outreach and education to farmers and ranchers. She is an animal welfare expert aHACCP (Hazardous Critical Control points) and PAACO (Professional Animal Auditor Certification Organization) certified. See Dr. Weimer’s letter of support here: Weimer LOS - SARE Education Grant.
Learning Outcomes
Not applicable until educational materials are published
Project Outcomes
We did not have sufficient time in the drafting of the Humane Handling Guide to include labeling requirements. While not specific to humane handling regulations, there is some overlap for farmers hoping to use humane handling label claims. We hope to one day receive funding to focus on educational approaches around labeling claims for sustainable farmers and ranchers.