WHAT HAPPENED: NCC this week filed comments with USDA’s Food Safety and Inspection Service (FSIS) in response to the agency’s proposal to revisit how it classifies meat and poultry establishments as “large,” “small,” or “very small.” NCC’s comments call on FSIS to amend the 30-year-old employee headcount method and replace it with a production volume-based system — and to add a new “medium” category to better reflect how the industry actually operates today.

WHY IT MATTERS: The way FSIS categorizes a plant affects everything from how new regulations are introduced to what resources and support a facility can access. The current system counts employees — a metric that made sense in 1996 but has grown increasingly outdated as automation has allowed plants to produce far more product with fewer workers. Under today’s rules, a highly automated facility and a small family operation can end up in the same “small” bucket, even though their scale, complexity, and regulatory needs may be significantly different.

WHAT NCC IS ASKING FOR: NCC recommended that FSIS use data it already collects — production volume in pounds per day — to build a new four-tier classification system tailored separately for each species (chicken, turkey, beef, pork, etc.). We also urged the agency to update those classifications at least annually so that plants are placed in the right category should their operations grow or change. For administrative purposes like grant eligibility or reduced inspection fees, we said revenue-based metrics can play a limited role — but shouldn’t be used for regulatory classification.

THE BOTTOM LINE: NCC supports FSIS taking a fresh look at this system and sees it as an opportunity to make oversight smarter and more efficient. Getting the classifications right means small plants get the support they need and agency resources go where they’ll have the most impact on food safety.