Farm Action Urges USDA to Modernize Outdated Processing Size Definitions

Today, in response to the U.S. Department of Agriculture’s (USDA) Advanced Notice of Proposed Rulemaking, Farm Action submitted a public comment urging the USDA Food Safety and Inspection Service (FSIS) to update how it classifies the size of meat, poultry, and egg processors, arguing that the current definitions no longer reflect the realities of today’s industry.

Currently, FSIS largely determines a processing facility’s size based on employee count. That classification then shapes regulatory requirements, food safety inspections, and access to federal resources. According to farmers and processors in Farm Action’s network, that approach no longer accurately reflects the scale or capacity of modern processing operations, particularly in an industry shaped by automation and consolidation.

This outdated method imposes disproportionate burdens on independent small-scale operations and can limit access to grants, exemptions, and other support programs by treating them the same as highly automated facilities or plants owned by large multinational corporations with far greater resources.

“Two facilities with comparable workforce sizes may process dramatically different product volumes depending on their level of automation, processing technology, and operational structure. In practice, employee-based metrics often obscure rather than clarify the actual scale of operations,” Farm Action wrote in its comment.

Farm Action urged FSIS to update establishment size definitions to better account for production volume, corporate ownership structures, and the actual compliance capacity of processing facilities. 

The organization also called for more detailed size categories to create a more accurate classification system and better distinguish independent processors from facilities operating under large corporate ownership.

The organization said these proposed updates would help ensure federal resources and oversight are better aligned with the actual scale and capacity of processing facilities while improving support for independent processors. 

Media Contact: Lucy Sears, [email protected], 202-853-5510

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