A response is longer than the petition for an investigation into animal cruelty

Since September 2, the Food Safety and Inspection Service (FSIS) has been considering a 14-page petition from Animal Partisan requesting that it issue a notice to clarify the following:

1) State officials are not categorically prevented 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 must cooperate with State government officials in enforcing State anti-cruelty laws and improve the clarity and frequency of communications (i.e., Letters of Concern (“LOC”)) to those officials.

The petition also requests that FSIS include these points in the language of all relevant materials, including future LOCs and the following guidance:

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

• Verification of Good Business Practices, FSIS Guideline 6110.1; And

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

Since its filing, the Animal Partisan petition has received significant responses that have been almost entirely positive. This includes contributions from the Veterinary Association for the Welfare of Farm Animals, the Association of Prosecutors and the Animal Welfare Institute; Animal Outlook, the Animal Welfare Institute and others.

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

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

The FAAC comments support Animal Partisan Petition No. 23-07, which requests a notice clarifying the limits of federal preemption, and FSIS’s role in enforcing state anti-cruelty laws. His comment begins:

“The Farmed Animal Advocacy Clinic (FAAC) is submitting this letter on behalf of Animal Kind Alliance (AKA), an organization strongly committed to advocating for the humane treatment of farm animals and the implementation of sustainable farming practices.

“To this end, AKA is working to reduce the impact of livestock farming on the climate crisis by dismantling the cruel production and processing practices that underlie this industry’s climate impact. It is our job, as responsible stewards of the environment and its inhabitants, to amplify the voices of farmed animals and fight against all injustices they face, including animal cruelty committed in slaughterhouses. That is why we support Animal Partisan petition #23-07.”

Further on it says this:

“It is an open, long-observed secret that “animal abuse is the price we pay for cheap meat,” as Rolling Stone Magazine reported over a decade ago. Even though I had this knowledge at least since the days of Upton Sinclair The jungleanimal cruelty in the slaughter industry remains widespread. And yet, animal cruelty charges are rarely levied against those who engage in slaughter. In recent decades there have been only a handful of cases of animal cruelty in slaughterhouses.”

Finally, his closing comment:

“FSIS should grant the petition and issue a notice clarifying 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 attempt to cooperate with State government officials in the enforcement of state anti-cruelty laws. Clarifying jurisdictional boundaries, working together and empowering states to tackle animal cruelty is paramount to protecting animals, people and the environment.”

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

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