by George Looby, DVM
For those contemplating the sale of meat products off the farm, the first thought might be to butcher the old hens and sell them at a nearby farmers market. Butchering and processing is not necessarily an easy job but the demand for locally grown products is growing. However, there are rules and regulations that stand in the way. The extension service of the University of Connecticut has prepared a booklet designed to provide direction to those who are considering doing some home butchering and what a farmer can and cannot do with their farm butchered products.
The regulations that are in place are there for a very good reason — they are not there to make life miserable for the producer. They are designed to ensure that the products offered for sale are as safe as possible for consumption. Consumers are becoming increasingly sophisticated about the food they purchase and are not above asking some very pointed questions about the route the food traveled before it is prepared in their home kitchens.
Regulations governing food preparation can come from the federal government down to the town or city level. Unraveling it all is something that those most closely affected can help achieve but regulations must be adhered to. Failure to comply can only further complicate a smooth beginning for a new project. Any start-up business should have a check list of questions to consider when starting out. Included on this list would be a search to see if there are any obscure regulations which may impact any start-up business.
The Extension Service offers some steps to follow when exploring the idea of starting a food business:
- Check with your city or town hall about zoning regulations, fire safety, permitting and a business license
- Well or spring location, water testing frequency, results and reporting must comply with the Public Health Code requirements
- Develop a specific plan about the product. This allows regulators to know your goals and allows them to ask relevant questions during any hearing
- Develop an overall business plan
- Check with your insurance provider concerning product liability coverage
Being proactive in your dealings with food inspectors, do your homework and have the preliminary work done before a meeting thus saving time and creating a good impression to get approval necessary before work can begin. It doesn’t hurt to develop a comfortable relationship with those you will be working with for a long time.
There are a number of agencies with whom any prospective food processer will interact. One of the first is the local health department which is responsible for enforcing the Public Health Code. One question that a prospective food processor should ask local health authorities regards the specific regulations that apply to a food processing operation. Another local official who should be contacted is the Planning and Zoning Officer who oversees all construction activities in a given town or city to ensure that the proposed activity planned for that site falls within code.
At the state level the Department of Consumer Protection oversees the retail sale and distribution of all meat products from food establishments where food is stored, offered for sale, processed or prepared, including transportation.
The Connecticut Department of Agriculture offers a Small Poultry Inspection Program which is available to any poultry producer of not more than 5,000 turkeys or 20,000 poultry operating a USDA exempt poultry slaughter facility.
The Connecticut Department of Energy and Environmental Protection may have rules regarding water pollution and solid waste management.
A federal agency with whom a start-up food processor may have to act is the USDA’s Food Safety and Inspection Services (FSIS). This agency is responsible for ensuring that meat and poultry are safe, wholesome, not adulterated and properly marked, labeled and packaged.
As is true for almost all regulations there are exemptions that apply in rather specific situations. The owner of poultry may slaughter poultry that they have raised themselves exclusively for the use of members of the owners’ family and his non-paying guests and employees. It is interesting to carefully note the wording of many of these regulatory rules. They seem to try to be as inclusive as possible in such a way as to avoid any misinterpretation when challenged.
The rules regulating exemptions for meat are much the same as those which apply to poultry. An individual may slaughter and prepare his own animals without any regulatory intervention. The same holds true for custom slaughter operations. They may do custom slaughtering and preparation for an individual on animals owned by that individual with the same restrictions that apply to poultry as far as distribution and consumption are concerned.
For those who are past the start-up phase of their businesses, there are additional opportunities to further refine the products for sale.
One of these programs has been labeled Livestock Feeding Claims whereby the feed manufacturer is audited on a regular basis for its product to meet those of an analysis by the Agricultural Marketing Service (AMS). Another is the “never fed beta agonists” claim in which the producer certifies that they have never fed those products in their operations. This group of drugs is designed to promote feed efficiency and produce a leaner carcass — more gain with less feed. These drugs have some recognized drawbacks including an apparent increase in the mortality rate among cattle. Other programs monitored by the AMS that may be used in promoting a safer, more palatable product include the non-hormone treated cattle program, the USDA tenderness program and the Certified Responsible Antibiotic Use Program. Complying with any one or all of these monitored programs can enhance the marketability of products.
An ever-increasing segment of the population favors products that are grown or raised organically. This consumer base must be recognized and accommodated. Livestock products that are sold labeled or represented as organic must be from livestock under continuous organic management from the last third of gestation or hatching with the following exceptions:
- Poultry or edible poultry products must be from poultry that has been under continuous organic management beginning no later than the second day of life.
- Livestock used as breeder stock may be bought from a non-organic operation onto an organic operation at any time provided that such livestock are gestating and the offspring are to be raised as organic livestock, the breeder stock must be brought onto the facility no later than the last third of gestation. Dairy animals are not included.
Organically raised animals that are subsequently sold to a non-organic operation may not be sold as organic. Careful record keeping is essential to maintain clear, concise record of all animal’s point of origin, points of sale and subsequent disposal.
There are overlaps between state and federal regulations. This summary is not meant to be the final word on any specific regulation. Carefully study any regulations that could conceivably impact any startup operation.