Livestock producers need more time to make required changes to their operations in order to comply with the Commonwealth of Massachusetts’ proposed Regulations Implementing the Act to Prevent Cruelty to Farm Animals (the Act), says the North American Meat Institute (Meat Institute).
With less than five months to go before the Act will be enforced, the Meat Institute urges the Commonwealth to delay enforcement and allow time for the proposed rule to be made final so livestock producers and packer processors can understand the final rule and make any required changes to their operations.
Mark Dopp, chief operating officer of the Meat Institute, submitted comments to The Commonwealth of Massachusetts Office of the Attorney General pointing out the “elephant in the room” that needs addressing.
“The Act provides that the ‘The Attorney General shall promulgate rules and regulations for the implementation of this Act on or before January 1, 2020.’ The Attorney General is 19 months late and counting in meeting that deadline. Simple equity demands that the agency delay enforcement of the Act so veal calf producers, hog farmers, packer/processors and the rest of the supply chain have time to understand and comply with yet to be published final regulations,” Dopp said.
Regulatory compliance requires the veal and pork industry to divert resources from maintaining a critical food supply and reallocate personnel to prepare for the compliance deadline, he wrote.
“For example, packer/processors will need to examine their operations and supply chains to ensure only compliant pork and veal is sold into Massachusetts – should they decide to continue supplying that market. To implement those changes in the absence of final rules is impracticable, if not impossible. For these reasons, the Meat Institute respectfully requests that, at a minimum, the agency delay for two years after publication of final rules enforcement of the Act and regulations,” Dopp wrote.
In addition to burdensome and costly certification and recordkeeping requirements of the proposed rule, the Meat Institute also noted that, although Massachusetts did not conduct an economic impact study, the State of California’s economic analysis for its similar proposed law (Proposition 12), found that the California law and proposed rules will cause consumers to pay more for pork and veal, with no identified benefit to California citizens.
“The proposal would require a packer that harvests hogs, processes those hogs and produces bacon and pork tenderloins, and sells those products to customers in Massachusetts to create and keep for three years a “certification” for every single transaction,” Dopp said. “Large packer processors could have thousands of transactions a year in Massachusetts. Plus, they undoubtedly sell covered pork or veal products to third parties who, in turn, sell the covered products in Massachusetts but the packer often will not know when it sells the product whether that product will be sold in Massachusetts. Indeed, the distributor may not know when it purchases from the packer to whom the product will be sold.”
The Meat Institute suggests that instead of mandating individual certifications for every transaction, the agency should implement a simple outcome-based requirement, a release said. The seller would supply the purchaser with a guarantee, certification, or other information to demonstrate the animals or products are compliant.
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