by Deborah Jeanne Sergeant
If you’re contemplating obtaining a USDA processing license for your on-farm meat processing facility, Jim Eklund, owner of Eklund Processing in Stamford, NY, offered some advice: Get ready to do a lot of paperwork. Eklund spoke at the NOFA-NY conference, hosted online. He presented “USDA Processing” to share the challenges and benefits of going from a 20-C license to a USDA license.
Eklund said the biggest difference between the two is the paperwork. “To start out for the plans, you have HACCP plans,” Eklund said. “I have two three-ring binders filled with just paperwork of what we do every day. Why do you clean equipment in a certain way, step by step? You have to tell your meat inspector how you do it. Every step has to be written out in detail.”
The HACCP is the Hazard Analysis and Critical Control Points, which identify potential hazards and also how the operator plans to address these risks.
“For example, when you’re mixing some sausages with salt and pepper and spices, how do you know the spices don’t have anything wrong with them?” Eklund said. “You need a letter of guarantee from the source that they don’t contain foreign materials. Everything you do, you need scientific data that someone has done a study showing that it’s safe to do it that way.”
For the Sanitation Standard Operating Procedures (SSOP), he must document procedures for employee and facility hygiene and provide studies from a university or private facility showing why he adopted that standard.
“How do you know your thermometer is calibrated?” Eklund said. “If you don’t have a study, you’ll have to calibrate it before every temperature you take. One study says weekly. After months of searching, I found one that said to calibrate it once a month. You can pay a consultant to find these for you. Before I found that, we were calibrating every single day.”
For grinding meat, he developed a 15-step process diagram; however, if just one arrow in the process is misplaced, the inspector could close his operation. It’s not a matter of simply paying a fine – a closure means downtime and lost revenue.
“That’s a big problem,” he said. “You have to tell the inspector every single step with the physical, chemical and biologic outcomes that will, can or are likely to occur.”
The paperwork would be completely overwhelming; however, he has one employee who does paperwork all day.
The processing room must be free of rust, cracks in the wall and 28 other issues that he and employees look for every morning. A crack may indicate that a rodent or insect could enter the facility, for example. “You have to have the paperwork to prove it,” Eklund said of the daily inspection. “Stainless steel is your best friend.”
Labeling must also be accurate. For example, “grass-fed” may not be printed on a label for meat from an animal that was fed grain.
Processors may not perform their own grading. “A USDA grader has to come in to inspect and then send it in to get pre-approval that the farmer grew a grass-fed animal,” Eklund said. “You cannot make a claim without proof to back it up. Labeling approval can take a long time.”
In addition to the expected checklists for general operating procedures, operators must document each process, along with proof for each step of that process. For processes like smoking, processors must provide inspectors with studies on water content and that the process performed is acceptable.
Eklund referred to websites including meathaccp.wisc.edu, fda.gov/food/hazard-analysis-critical-control-point-haccp/haccp-principles-application-guidelines#app-h, fsis.usda.gov, asi.k-state.edu/research-and-extension/meat-science/haccp and cornell.app.box.com/s/35oi9wcfwvpxuyg5bcqbnv0vs0h3hhii for more information.
While it seems like only an initial amount of work to set up all the documented processes and logbooks, Eklund said these are “living documents, always changing” and that processors must tweak them as necessary. Any new recipe, change in procedure or alteration of a process requires an overhaul of the associated paperwork. And every employee must be trained in all of these procedures, with documentation that the training occurred.
Hiring a consultant to write a whole plan could cost about $15,000. Because of the expense, most operators choose to do it themselves. Thankfully, they do not have to guess at how to do it.
“Some colleges like Cobleskill have a class that can help you with training on how to work with the inspector,” Eklund said.