Submitted electronically: https://www.federalregister.gov/documents/2018/02/01/2018-01256/modernization-of-swine-slaughter-inspection#open-comment
Paul Kiecker
Acting Administrator
Food Safety and Inspection Service, USDA
Docket Clerk
Patriots Plaza 3
1400 Independence Avenue SW
Mailstop 3782, Room 9-163 A,
Washington, DC 20250
Re: FSIS-2016-0017
Dear Acting Administrator Kiecker,
On behalf of the National Employment Lawyers Association (NELA) please accept these comments expressing our strong opposition to the United States Department of Agriculture (USDA) Food Safety and Inspection Service’s (FSIS) proposal to radically change the food safety inspection system in swine slaughter plants, which will endanger public health and worker safety. NELA strongly opposes the proposed Modernization of Swine Slaughter Inspection rule: FSIS-2016-0017 (RIN 0583-AD62). We are particularly opposed to any increase in maximum allowable line speeds in hog slaughter facilities above the current allowed 1,106 head per hour (hph), and urge the USDA to withdraw this proposed rule.
NELA is well qualified to comment on the issues identified in the NPRM because it is the largest professional membership organization in the country comprised of lawyers who represent workers in labor, employment, and civil rights disputes. Founded in 1985, NELA advances employee rights and serves lawyers who advocate for equality and justice in the American workplace. NELA and its 69 circuit,