Docket Management
Docket: 02D-0468 - Draft Guidance-Manufacture& Labeling-Raw Meat Foods-Carnivores&Omnivores
Comment Number: EC -1

Accepted - Volume 1

Comment Record
Commentor Mr. Peter Moolhuizen Date/Time 2002-12-20 10:08:45
Organization Taylor Pond Farms LLC
Category Company

Comments for FDA General
Questions
1. General Comments We are a small family farm that raises and sells meat rabbits throughout the state of Michigan. We not only sell products to the consumer market but we also sell a large quantity of product to pet owners. All of our rabbits are processed at a state inspected plant. We process at a state inspected facility because there are no USDA facilities in our state or surrounding states. While we have no problem with some guidance in this area, we do have a problem with the requirement that only USDA inspected products be used. By forcing us to have USDA inspection you are basically putting us out of business and depriving pet owners of a high quality excellent meat source for their pets. How can we process rabbits if there is no USDA processing plant and secondly we would have to add the cost of inspection to our product, because rabbits are not considered livestock and do not enjoy the free inspection serves that other meat groups enjoy. We actually pay for the inspection services of the other groups. The extra cost of processing (which would add over $1.50 in cost per pound) would make our product cost prohibitive to the pet owners. We pride our self's in the quality of our meat, we are a chemical and drug free facility and only use rabbits that are to big or do not meet our customers requirements. We use no diseased or dead animals in our products at all. We only use healthy livestock for our ground meat, which is processed, ground and frozen all within the same process. If you are going to force companies to use USDA approved meat than two things need to occur. 1: Rabbits need to be classified as livestock to allow us to get the free inspection services and keep us cost competitive with other meats and 2: Support should be provided to allow small operations in states to start USDA rabbit processing plants. Unless these two things happen, you are limiting the access to high quality products to the owners of pets throughout the United States and impacting our business's dramatically. Thank you, Peter & Barbara Moolhuizen 15784 Taylor Street West Olive MI 49460 Phone: 616.844.4031 Fax: 616.844.4032




EC -1