@Krazyquilts
One final follow up, as I do head counts of birds, with that many poultry, you likely are selling eggs unless you eat an awful lot.
Under 300 birds (the last time I checked) you remain below FDA regulations, so you are still considered a small holder.
However, not giving legal advice here but as I have worked through my own concerns, if someone who purchased your eggs should ever get sick (they forgot to wash the pan, they let them spoil, then used), and they blame you, and your eggs were tested and found to have illegal residue, by FDA standards you are responsible for any fines and liabilities of those drugs found in the eggs. (Yes federal fines could be imposed).
There are no egg police running around checking on small holders, which is why we are "unregulated," so any issues that arise will be because someone became sick (God forbid) and blamed you causing a reason to test your eggs.
I've personally decided it is easier to defend my eggs if I follow FDA approved standards. If I do need to use off script, it is better, legally, to go through a vet (but we can't always). If I do choose to go on my own, I then am very, very, careful to use drugs that have a research history with pull times and follow an ample pull time for my public eggs. (I can do what I want with my private eggs).
I sell as "farm fresh" not "organic" so it gives me some leeway. (Organic is a whole 'nother ball of wax, and very hard to get certified, nearly ridiculous for a small holder).
Just what I've pondered.
LofMc
This is older, prior to 2017 standards, but useful:
http://www.farad.org/publications/digests/122015EggResidue.pdf
Should be current list of approved drugs
http://www.farad.org/vetgram/egglayers.asp
And studies which show residue
http://www.farad.org/publications/miscellaneous/LayingHensEggResidues.pdf
One final follow up, as I do head counts of birds, with that many poultry, you likely are selling eggs unless you eat an awful lot.
Under 300 birds (the last time I checked) you remain below FDA regulations, so you are still considered a small holder.
However, not giving legal advice here but as I have worked through my own concerns, if someone who purchased your eggs should ever get sick (they forgot to wash the pan, they let them spoil, then used), and they blame you, and your eggs were tested and found to have illegal residue, by FDA standards you are responsible for any fines and liabilities of those drugs found in the eggs. (Yes federal fines could be imposed).
There are no egg police running around checking on small holders, which is why we are "unregulated," so any issues that arise will be because someone became sick (God forbid) and blamed you causing a reason to test your eggs.
I've personally decided it is easier to defend my eggs if I follow FDA approved standards. If I do need to use off script, it is better, legally, to go through a vet (but we can't always). If I do choose to go on my own, I then am very, very, careful to use drugs that have a research history with pull times and follow an ample pull time for my public eggs. (I can do what I want with my private eggs).
I sell as "farm fresh" not "organic" so it gives me some leeway. (Organic is a whole 'nother ball of wax, and very hard to get certified, nearly ridiculous for a small holder).
Just what I've pondered.
LofMc
This is older, prior to 2017 standards, but useful:
http://www.farad.org/publications/digests/122015EggResidue.pdf
Should be current list of approved drugs
http://www.farad.org/vetgram/egglayers.asp
And studies which show residue
http://www.farad.org/publications/miscellaneous/LayingHensEggResidues.pdf