USDA-FSIS Seeks Input on Potential Updates to Establishment Size Definitions
The U.S. Department of Agriculture’s Food Safety and Inspection Service (USDA-FSIS) has issued an advance notice of proposed rulemaking (ANPR) to gather stakeholder input on whether and how the agency should revise its establishment size definitions for meat, poultry, and egg production facilities.
The current size classifications, established under the 1996 Pathogen Reduction/Hazards Analysis and Critical Control Points (HACCP) Systems Final Rule, categorize establishments as very small, small, or large based on employee count and annual sales. These definitions have historically been used to assess regulatory impacts, implement regulatory requirements in phases, and tailor assistance to small businesses.
As of December 2025, FSIS-regulated establishments include 2,961 very small, 2,847 small, and 508 large facilities.
However, FSIS has increasingly relied on additional metrics, including production volume thresholds, to inform regulatory analysis, sampling frequencies, and inspection requirements. The agency said these evolving practices have prompted consideration of whether current size definitions accurately reflect modern industry structure and operations.
Possible Alternative Categorization Approaches
The ANPR follows recommendations from the (now disbanded) National Advisory Committee on Meat and Poultry Inspection (NACMPI), which reviewed the issue in September 2024. The committee concluded that the existing categorization scheme may group establishments that have significantly different operational scales and resources.
NACMPI recommended that FSIS consider a dual-metric approach to classification. Under this framework, establishments would be categorized both by production volume and by business size factors such as employee count, annual revenue, and corporate ownership structure. The committee suggested that production volume could better inform regulatory requirements, while business size metrics could support determinations related to financial assistance and compliance resources.
The committee also raised concerns about establishments classified as small but affiliated with larger corporate entities, suggesting that ownership structure should be considered when determining eligibility for federal programs.
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Consideration of SBA Standards and Additional Categories
FSIS is also seeking input on whether its size definitions should align with Small Business Administration (SBA) standards, which define small businesses based on employee thresholds that are generally higher than FSIS HACCP categories. NACMPI advised against adopting SBA standards outright, citing concerns that employee-based metrics alone may not accurately reflect operational scale or resource availability.
In addition, FSIS is requesting feedback on the potential creation of additional size categories, including classifications based on production volume, product type, or other operational characteristics such as processing methods or facility capacity.
Request for Data and Comments
Stakeholder feedback will inform whether FSIS moves forward with proposed changes to establishment size definitions to better reflect current industry conditions and improve regulatory effectiveness.
Specifically, FSIS is seeking input on:
- Economic impacts of current HACCP size classifications
- Potential effects of revised or new classification systems
- The role of production volume, corporate ownership, and other factors in defining establishment size
- Data collection, reporting, and verification methods for size-related information
- Impacts of size definitions on regulatory requirements, industry costs, and federal program eligibility.
The full ANPR can be accessed here. Comments must be submitted by May 26, 2026 on regulations.gov under docket number FSIS-2026-0001.
