Final 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 two virtual workshops 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 educational approach gathered feedback from the target audience to draft understandable and relevant materials for the farmer and processor audience.
We took the following steps to draft the Farmer's Guide to Humane Handling Requirements:
- 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 those interests. 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 worked with an LL.M. in Agricultural and Food Law Graduate Assistant and law student research assistant on the drafting of the Humane Handling Legal Guide. This has included guiding the students through navigating these laws and writing for a farmer audience. The students 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. Three attorneys assisted with drafting the more technical sections. Both students felt the experience taught them important legal skills and technical knowledge. The students are both planning to practice in rural Arkansas and will be equipped to address both farmer and processor legal issues in this area based on their work for this project.
- We have had bi-weekly meetings with key team members to revise and shape the draft.
- We had producers, processors, and other experts including Chris Shaw with Cypress Valley Meat Company, Dr. Weimer with the University of Arkansas Poultry Science Dept., NCAT's team, and the team at the Humane Handling Institute at the University of Wisconsin River Falls review the guide and provide comments for both technical issues and adaptability for the farmer and processor audiences.
- We incorporated the feedback and then had a virtual workshop on the guide which included expert panelists from NCAT, Dr. Weimer, Chris Shaw with Cypress Valley Meat Company, and Dr. Anderson with the Humane Handling Institute. The workshop's approach included practical tips for farmers on how to navigate these issues with processors, and an explanation from a processor on why small processors prefer certain steps when animals arrive at the plant in order to prevent a humane handling violation from occurring. We also focused on the main cause of violations, missed-stuns. We shared the recording on youtube to make it accessible.
Overall, the Humane Handling Guide for Farmers provides the legal basics in plain language, includes easy to use checklists and charts for farmers, and provides important tips on how to manage risk when it comes to these issues.
The other processor focused factsheet on a Robust Systematic Approach took a similar approach. A law student research assistant was provided with an outline and conducted research and writing. Professor Nuckolls supervised and reviewed the factsheet. Denise Perry, of Single Shot Consulting, LLC, an expert on Robust Systematic Approaches reviewed the factsheet for accuracy. The team at Cypress Valley Meat Company also reviewed the factsheet for accuracy and plain language for processors. Their feedback was included in the final draft of the factsheet.
Then we had a virtual workshop on a Robust Systematic Approach which explained what it is, how processors can use it to avoid serious humane handling violations that shut down their plants, and practical advice from Chris Shaw on why processors should prioritize this. The webinar was recorded and is available on youtube as well.
We uploaded both the guide and factsheet to our website and have shared them widely.
For both the virtual workshops and guides, we created an evaluation to assess the impact of these materials and shared the evaluation with the guides and youtube links.
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 in partnership with Cowry & Clay conducted outreach on the guides and assessments with local farmers and their processing networks. NCAT shared the guides and assessments with NCAT’s network of Arkansas and Oklahoma farmers and ranchers and processors. The Cypress Valley Meat Company also shared the guides with its farmer and processor network. We shared 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 shared the guides on the Oregon State University Niche Meat Processor Assistance Network and other processor networks. The Humane Handling Institute at the University of Wisconsin River Falls also sent the materials with their network. Each project team member shared 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. However, due to unavoidable project delays we had to find a time in the evening that worked during the busy season. The virtual setting allowed for maximum participation because venue expenses and travel cost are not a barrier to participation. Through the virtual format, we expanded our reach beyond Arkansas and Oklahoma, and into other key Southern SARE states with significant sustainable livestock production.
The workshop provided interactive discussions, lessons learned, and best practices.
We set up workshop registration in advance of the date, and shared the registration information via the methods described above. The workshop educational materials were supplemental to the guides, and participants took a deeper dive into this complex regulatory information.
We received 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 volunteered 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 have also been invited to conduct a continuing legal education on this topic to an attorney audience in Dec. 2025.
The farmer and rancher guide’s clear regulatory information, checklists, and examples provide practical information that will allow farmers to understand and apply this information to their operations. The guide educates 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 learned 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 also focused on methods to mitigate farmers’ business risks in the event their small processor is suspended.
The support guide for small processors ensures 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. Sadly, Ann suddenly passed away prior to the start of this work. We contracted with Cowry & Clay, an organization that conducts outreach to farmers and processors to complete the project work.
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
Skill: Recognize and adapt to how humane handling compliance is assessed
Knowledge: Knowledge about the Humane Handling Requirements for Slaughter
Knowledge: Knowledge about the farmer's role in Humane Handling Requirements for Slaughter compliance
Knowledge: Understanding of how to manage risks in the event of a humane handling violation
Project Outcomes
- Produced materials to help farmers and ranchers that sell direct to consumer meat and poultry products manage their economic risks around humane handling violations.
- Ensured farmers are able to minimize their risks in the event of a humane handling violation at their processor.
- Educated small processors serving sustainable farmers in managing their economic risks with humane handling requirements.
- Strengthened the opportunity for animal welfare certifications for farmers and ranchers.
- Prevent the suspension or potential closure of processors for humane handling violations to ensure the processing bottleneck issue for sustainable farmers and ranchers is not exacerbated.
- Educated farmers and ranchers on their humane handling and slaughter responsibilities, even if they slaughter under an exemption.
We did not have sufficient time and funding 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.
The project was delayed and transitioned some due to parental leaves, illness, and the passing away of farmer participant Ann Wells. We were able to adapt but believe we would have had more participation if the original timeline and project participants remained the same.
There is a clear interest from rural attorneys to learn more about this and PI Nuckolls was invited to present a continuing education webinar for attorneys on these materials. The target audience for similar resources in the future might include rural attorneys that work with small processors and farmers and ranchers.