Based on a requirement arising from the Food, Conservation, and Energy Act (Farm Bill) of 2008, the Food Safety and Inspection Service is proposing to define “catfish” for the purposes of continuous inspection under the Federal Meat Inspection Act (FMIA). This comment is intended to provide an in-depth evaluation of both the analysis and the rule beyond the score provided by the Mercatus Regulatory Report Card (attached as Appendix B to this comment).

The catfish rule received a Report Card score of 25 out of 60 or, on a scale of 100, a grade of 42.1 The best analysis thus far evaluated in the Mercatus Center’s Report Card project received a score of 48 out of 60 possible points; the catfish regulation scores well below this level. This suggests that the analysis is done quite poorly in terms of the quality and use.