July 14, 2021
In comments submitted to the California Department of Food and Agriculture (CDFA), The North American Meat Institute (the Meat Institute) said the State of California’s proposed rules for Proposition 12 (Prop 12 or the law) are burdensome, complex and unworkable, providing no food safety or animal welfare benefit.
“The proposed rule by the California Department of Food and Agriculture (CDFA) admits there are no benefits to Californians as a result of Prop 12 and admits the deaths of breeding sows will increase,” said Mark Dopp, Meat Institute Senior Vice President Regulatory & Scientific Affairs and General Counsel. "Multiple sections of the rule should be withdrawn or significantly revised."
The Meat Institute submitted 12 pages of comments, found here, that said the rules, if finalized, would create a bureaucratic labyrinth of regulatory provisions:
requiring an almost unworkable annual certification of veal and breeding pig (sow) facilities;
creating an overly complex accreditation process for entities allowed to certify those facilities;
imposing detailed recordkeeping requirements on producers and throughout the supply chain;
imposing problematic labeling provisions; and
granting legally questionable enforcement authority.
The text of the notice and proposed rule can be found here.
The following are key findings in the notice published along with the proposed rule:
Estimated costs for businesses to comply regarding pork: “Estimated ongoing cost is greater than the initial cost of conversion at $100,000 per year for a typical breeding pig farm due to smaller inventory of breeding pigs, lower piglet output per animal and increased breeding pig mortality.”
CDFA acknowledges that animal confinement space allowances prescribed in the Act (cage-free for egg-laying hens, 43 square feet for veal calves and 24 square feet for breeding pigs) “are not based in specific peer-reviewed published scientific literature or accepted as standards within the scientific community to reduce human food-borne illness, promote worker safety, the environment, or other human or safety concerns.”
“This proposal does not directly impact human health and welfare of California residents, worker safety, or the State’s environment…”
CDFA also identified higher costs for schools, universities, prisons, and county jails. And discussing “Benefits to human health, worker safety, or the State’s environment” CDFA said “The Department has made an initial determination that the proposed regulatory action will have significant, statewide adverse economic impact directly affecting California businesses including the ability of California businesses to compete with businesses in other states.”
Finally, the agency identified an impact Prop 12 is likely to have – forcing low income consumers to pay more for food. “Covered pork, and especially covered egg products will become more expensive to consumers starting in January 2022 because of the animal confinement standards mandated in statutes. … Therefore, the Act will disproportionately reduce food purchasing power of low-income consumers. … Food consumers most affected will be those low-income consumers that are not enrolled in assistance programs.”
In late June, the Supreme Court of the United States denied a petition filed by the Meat Institute to review California’s Prop 12, an initiative enacted in November 2018 after California voters approved it. At the time, the Meat Institute said it would consider other options.
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