Comment Log Display

We at Foster Farms have the following comments regarding the
proposed changes to the regulation for the mandatory reporting of
greenhouse gas emissions.  Our comments are limited to certain new
definitions appearing in the proposed regulation and are editorial
in nature.  The comments are intended to clarify the definitions
and thereby facilitate compliance.

In Section 95102 we request the following changes to the
definitions of “poultry deli products”, “protein meal” and “whole
chicken and chicken parts”:

Revised the definition of “poultry deli product” as shown below to
specifically include the term “franks”, and to account for the
transfers of these products to other facilities for additional
processing (e.g., sending franks to a facility where they will be
further processed to become corn dogs).  We recommend the following
wording:

(62) “Poultry deli product” means the products, including corn
dogs, sausages, and franks,  that contain a significant portion of
pre-processed poultry, that are cooked and sold wholesale or
retail, or transferred to other facilities.

Revise the definition of “protein meal” to “protein meal and fat”
to specifically include all significant rendered products including
poultry fat and feather meal.  We recommend the following wording:

(65) “Protein meal and fat” means meal meal, feather meal and fat
rendered products from poultry tissues including meat, viscera,
bone, blood, and feathers.

Revise the definition of “whole chicken and chicken parts” to
provide additional examples of parts and to account for transfers
to other facilities for additional processing (e.g., sending wings
to another facility for seasoning and cooking).  We recommend the
following wording:

(89) “Whole chicken and chicken parts” means the whole chicken or
chicken parts (including breasts, wings, drums, and  thighs) that
are packaged for wholesale or retail, or transferred to other
facilities.

We understand that these comments may be too late for consideration
in this revision to the regulation.  We do note that there was a
limited comment period for this regulatory change before it was
heard by the Board.  If the comments cannot be considered for the
current regulatory change we then request that they be considered
in the development of compliance guidance documents for this
regulation.  We would be pleased to discuss any questions or
concerns you may have regarding these comments.  Thank you for your
consideration of our requests.