A comment is longer than the petition for animal cruelty investigations

The Food Safety and Inspection Service (FSIS) has, since last Sept. 2, been considering a  14-page petition from Animal Partisan requesting that it issue a notice to convey that: 

1) State government officials are not categorically preempted from enforcing state anti-cruelty laws by the Federal Meat Inspection Act, the Humane Methods of Slaughter Act, the Poultry Products Inspection Act, and 

2) FSIS personnel should cooperate with state government officials in the enforcement of state anti-cruelty laws and improve clarity and frequency of communication (i.e., Letters of Concern (“LOC”)) to those officials. 

The petition also requests that FSIS incorporate these points into the language of all relevant materials, including future LOCs and the following directives:

• Humane Handling and Slaughter of Livestock, FSIS Directive 6900.2;

• Verification of Good Commercial Practices, FSIS Directive 6110.1; and

• District Veterinary Medical Specialist (DVMS) – Work Methods, FSIS Directive 6910.1.

Since it was submitted, the Animal Partisan petition has received significant comments that are almost entirely favorable. These have included submissions by the Veterinary Association for Farm Animal Welfare, the Association of Prosecuting Attorneys, the Animal Welfare Institute;’ Animal Outlook, the Animal Welfare Institute, and others.

The petition, under review at the FSIS Office of Policy and Program Development, has now received a comment that, at 16 pages, is longer than Animal Partisan’s filing.

The extended comment from The Farmed Animal Advocacy Clinic (FAAC ) was submitted on behalf of the Animal Kind Alliance (AKA).

The FAAC comments support Animal Partisan’s Petition #23-07, requesting Notice Clarifying the Limits of Federal Preemption, and FSIS’ Role in the Enforcement of State Anti-Cruelty Laws. It’s comment begins with:

“The Farmed Animal Advocacy Clinic (FAAC) submits this letter on behalf of Animal Kind Alliance (AKA), an organization deeply committed to advocating for the humane treatment of farmed animals and the implementation of sustainable agriculture practices. 

“To that end, AKA works to reduce animal agriculture’s impacts on the climate crisis by dismantling the cruel production and processing practices underlying this industry’s climate impact. It is incumbent upon us, as responsible stewards of the environment and its inhabitants, to amplify farmed animals’ voices and fight against any injustices they may face, including animal cruelty committed at slaughterhouses. Therefore, we support Animal Partisan’s petition #23-07.”

Further down is this:

“It is an open, long-observed secret that “animal cruelty is the price we pay for cheap meat,” as Rolling Stone Magazine reported over a decade ago. Despite having had this knowledge since at least the time of Upton Sinclair’s The Jungle, animal cruelty remains rampant in the slaughter industry. And still, animal cruelty charges are rarely levied against those in the business of slaughter. Throughout the past several decades, there have only been a handful of cases involving animal cruelty at slaughterhouses.”

Finally, its closing comment:

“FSIS should grant the Petition and issue a notice that conveys that the FMIA, HMSA, and the PPIA do not categorically or automatically preempt the enforcement of state anti-cruelty laws and that FSIS personnel will endeavor to cooperate with state government officials in the enforcement of state anti-cruelty laws. Clarifying jurisdictional boundaries, working collaboratively, and empowering states to address animal cruelty is paramount for protecting animals, humans, and the environment.”

The Farmed Animal Advocacy Clinic is based in South Royalton, VT.

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