The following is a letter to Minister Letnick following his meeting with a groups of local producers and processors in Falkland. The view reflects the consensus of those attending the meeting.

Dear Minister Letnick,

Thank you for taking the time to meet with a small group of local growers in Falkland October 2/12. The outshot of that meeting was your request to put on paper the four points this particular group felt would help you address your concerns about the Meat Regulations.

As you are aware, it is generally felt that the imposition of the Meat Regulations has been considered a failure, especially among small lot holders. These are the people who, for years, grew meat animals annually; 10-20 head of cattle, a small flock of sheep, or grew chickens, had them processed locally and sold the product directly to local consumers. We called these direct farmgate sales. These were personal and often long-established arrangements and, where an independent local processor was involved, could easily be characterized as classic, small scale value-chain arrangements.

The system worked, it provided spin-off economic benefits for auction houses, small abattoir operations and cut and wrap facilities. It supported local economies and offered the small lot holder a way to make good use of their land. The Meat Regulations and their ensuing ripple effect resulted in a dramatic disappearance of small lot producers as well as many of the existing abattoirs and slaughter operators, caused a reduction in the availability of local livestock supply for the remaining abattoirs and left many people, including the consuming public who were avid fans of buying direct from their local farmer, unhappy.

One aspect of the justification for the Regulations that was particularly galling to producers and slaughter facilities alike was the adverse health claim. It was purported that the existing practices were presenting unacceptable health risks. This claim, to our knowledge, was never supported by fact.

Today, we are faced with a complex set of problems: too little supply for the existing small abattoirs; custom cut and wraps, or butcher shops that were popular among local producers going out of business; the problem of an inspection protocol that is ill-afforded and in some cases insufficient to meet abattoir needs; a problem of inspection not delivering the preventative needs expected; and a substantial amount of media attention to meat processing errors that has created overblown food fears.

You asked us to propose solutions. The following are four linked points we feel would help improve things.

Self-inspection: This is an idea, admittedly, that has mixed popularity with processors. While one small-scale poultry processor would willingly take it up, with training, her comment was that the media has done such a great job of painting the processor with suspicion that, under current circumstances, conducting self-inspection would probably lose her some business, at least to start with. However, it would give her more freedom to process more birds on her schedule, rather than her having to throttle down to the 3 days/wk she is now only allowed for an inspector.

For the BC Cattlemenís Association (BCCA), the issue is public confidence. They would like to see across-the-board independent third-party inspection because it helps support public confidence. But, their perspective is based on an export and wholesale supply point of view.

What differentiates the BCCA view from the independent, private sale view is that the single animal sale is personally established; it takes place face-to-face, is based on trust and confidence in the supplier and involves a de facto assumption of personal liability on the part of the producer. Repeat sales, the reputation of the producer is gauged entirely on the quality of the last animal sold.

We question why any level of government would want to interfere with such a private transaction as that.

Where the processor, the third party in this value-chain arrangement is willing, confident, able, trained and/or experienced and permitted, the province could extract itself substantially from that form of transaction.

Scaled oversight: The example offered you in our meeting related to an apparent USDA policy concerning small-lot poultry production, which was applied in some U.S. states, not all. The role of the state varied according to the scale of production.
In essence, the number of birds grown determined the extent to which the state regulated the slaughter, processing and sale of the birds. The apparent assumption was that very small producers sold direct and on a face-to-face basis and thus traceback and quality control occurred inherently in the transaction. Somewhat larger producers, those who were likely to wholesale or supply local grocers, were required to meet certain slaughter facility set-ups and expectations. Permits were required and facility and facility or processing investigations were undertaken reactively, or upon complaint. Larger operations required more stringent oversight.

When the Meat Regulations were established, there was resistance on the part of government to allow for a two or three-tiered approach. One assumption was that this would open the gates to cheating. Another was that people donít know how to judge the quality of the product they are buying nor how to measure the character of the seller.

The restrictive practices now in place have not prevented nor likely have reduced the incidence of cheating.

The imposition of rules and policies based on these assumptions, giving no regard to the ability of people to make their own ethical choices and measure their interpersonal relations has not been worth it.

A return to, or an allowance for a tiered approach would show confidence in people being able to make their own judgements and in the power of the marketplace to achieve an acceptable norm.

Facility vs Individual slaughter animal inspection: We heard stories in our meeting about both very good and very poor slaughter facilities that existed prior to the imposition of the Regulations. These were not unregulated facilities, but facilities that were given insufficient attention by the existing authority, the Ministry of Health. Rather than fixing the facility inspection problem and taking enforcement action, a per-animal inspection practice was introduced.

There are now two reasons why abattoirs like the presence of the inspector: one is that this relieves the abattoir operator of liability and, secondly, in some cases, even provides them free labour, if not free technical training to slaughter floor staff.
Additionally, having an inspector present diverts the problem of having to reject a customerís problem animal to the inspector; a handy, personally blameless way of maintaining customer relations.

Reasons why a per-animal inspection has not been entirely satisfactory include: that inspection is no guarantee of product health beyond what is obvious, it is costly and time-consuming, and it is often redundant. Experienced slaughter floor operators are as well equipped to identify problem animals as is the inspector.

Then thereís this irony: while abattoirs are inspected, cut and wrap facilities arenít, in the same way. Local butcher shops, or cut and wrap facilities are only subject to facility inspection. If meat contamination is a driving reason for inspection, there is an obvious inconsistency between these two practices. Meat can be as easily contaminated as it moves through the supply chain from the abattoir to the butcher shop to the home of the consumer as it can be on the kill floor.

In fact, the increased distance a producer has to travel to get to a processing facility has arguably exacerbated the risk of contamination.

We suggest that for the small-lot producer, the same treatment be offered as is required of the butcher shop; facility inspection is adequate.

As an augment, you might want to consider the establishment of a Ministerís enforceable code of practice much like has been established by the Ministry of the Environment. In those cases, stakeholder consultations are key to arriving at an agreeable set of standards according to which peer expectations emerge. Thus, indirectly, this approach contributes to the professionalization of the industry. Where an anomaly occurs, the Minister has the authority to cite the standard and can easily justify enforcement action.

This approach also puts the onus back onto the abattoir operator to operate their facility according to a commonly agreed to standard, the same as is expected of any trade.

It is a self-policing approach backed by a big stick.

It is an approach easily rationalized by the provinceís need to be able to govern better at a lower cost without diminishing the expected quality of performance.

It shifts the burden of performance responsibility a certain number of degrees away from government and onto to the operator for meeting facility standards.