For the discussion about prospective applicants, NACMPI considered the obstacles underserved communities face in accessing FSIS information resources, barriers to applying for FSIS inspection, strategies for FSIS to raise awareness of its resources, available data and information that could help FSIS identify underserved communities that would benefit from increased slaughter or processing capacity, and actions FSIS could take to stimulate increased slaughter or processing capacity in these communities. As reported by NACMPI, the single most impactful action FSIS could take is to publish a clear, concise guidance document that points prospective applicants to resources for determining whether or not they need inspection, how to apply for inspection, how inspection works, and how to begin the process of designing a production facility that complies with regulatory requirements. NACMPI also recommends utilizing Enforcement, Investigations, and Analysis Officer (EIAO) personnel to conduct onsite consultative outreach visits for prospective establishments, as well as enabling products from state inspected establishments to enter interstate commerce by lifting the prohibition on “at least equal to” state meat and poultry inspection programs.

With respect to small and very small establishments that already receive FSIS inspection, NACMPI deliberated about the barriers that inhibit such establishments from operating successfully under FSIS inspection, the kinds of information that would help make small and very small establishments in underserved communities more successful, ways in which FSIS can more effectively promote awareness and use of current valid scientific information to support food safety systems in these establishments, which organizations are effective at providing assistance to these establishments and what FSIS can learn from such organizations, and actions FSIS can take to more effectively aid existing small and very small FSIS regulated establishments in underserved communities. After discussing several behavioral, cultural, educational, financial, geographical, infrastructural, linguistic, technological, and other barriers faced by small and very small establishments, NACMPI concluded the main barrier these operators face is the overwhelming burden of implementation of 9 Code of Federal Regulations (CFR) 416, 9 CFR 417, and many other regulations.

In NACMPI’s consideration of specific actions that FSIS can take to more effectively support regulatory compliance of small and very small establishments, trust and transparency were main themes. Some members of the subcommittee felt strongly that there is a culture of fear of the FSIS inspection process due to inherent power dynamics that may hinder processors seeking federal inspection or successfully remaining under federal inspection. Concrete actions NACMPI recommended to FSIS to better support small and very small establishments in underserved communities include unifying and standardizing the food safety messages in training for inspectors and processors; facilitating and expanding regional listening sessions, town halls, and summits to better integrate small and very small industry with the FSIS mission and streamline communication with regulators; creating a quarterly newsletter that can be distributed to inspection program personnel (IPP) who can then report directly to regulated facilities during weekly meetings and inform of regulatory updates, webinars, new resources, and other happenings; and taking immediate action to improve the capacity of the Small Plant Help Desk to provide support to facilities in a timely fashion.