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I'm thinking of writing a letter...

Discussion in 'Meat Birds ETC' started by eatmorechicken, Jul 21, 2011.

  1. eatmorechicken

    eatmorechicken Chillin' With My Peeps

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    My state adopted the USDA's requirements for processing chicken meat with the exception of having an inspector present on butcher days. Of which means that I would have to put down a copious amount of money to build a state of the art processing facility to legally sell chicken. Mobile units are allowed for custom processing only (not for sale). I would be exempt from USDA inspection as long as I stay under 20,000 birds of my own raising. But if the state's requirements are nearly identical to the USDA's, then what am I really exempt from? The USDA even allows more freedom to do other things such as butchering birds for other growers, sell out of state ect.

    I find that the state's requirement for poultry processing is a huge disadvantage for small growers like myself. There is hardly enough money in growing and selling the chicken without the added expense of a costly facility. I believe that successful businesses become successful from starting very small and simple then building up to a large scale, or the owners are independently wealthy and have the funds to start and sustain a business until it starts making money.

    An exemption from state inspection would make things much more realistic for a small chicken businesses to begin and grow. Perhaps an exemption from state inspection if farmers produce under 5,000 of their own raising. I understand that these laws were set in place for public safety, but they are awfully one sided. There needs to be better mediation between consumer and producer. Perhaps encouraging the consumer to investigate the safety of their food would have a positive effect for local economy and society.

    I'm thinking of writing a letter to the governor and/or commissioner of the my states department of agriculture concerning chicken processing. Is there any body else that you would suggest? I have never written a letter to a government official before, so what would be an ideal format, or what kind of convictions should I include? Is there anything else that I can do? Please give me your thoughts and any suggestions. Thank You



    edited: effect instead of affect?
     
    Last edited: Jul 21, 2011
  2. PotterWatch

    PotterWatch My Patronus is a Chicken

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    I'm confused about the requirements. Your state says that you can follow USDA guidelines except that you must have an inspector present for every butchering?

    If it were just following the USDA guidelines, that would be great news. The USDA basically says that if you are selling under 20k, all you have to do is process your birds in a sanitary manner, all birds must come from your own property (you can't process birds for others), and you must have a safe handling label along with the city and state your farm is in and the exemption number you fall under. Here is the text for a Producer/Grower under 20,000:

    Producer/Grower – 20,000 Limit Exemption A poultry grower may slaughter and process more than 1,000 birds as exempt product for distribution as human food when the following eight criteria are met [PPIA Section 464(c)(1)(C) &(c)(3) “Section 15 (c)(4)”5; Title 9 CFR §381.10(a)(5) and (b)(1) and (2)].
    Criteria:

    1.
    The producer/grower slaughters and processes, on his or her own premises, no more than 20,000 poultry, raised by him or her, in a calendar year

    2.
    The producer/grower sells, in a calendar year, only poultry or poultry products he or she prepares according to the criteria for the Producer/Grower – 20,000 Limit Exemption; he or she may not buy or sell poultry products prepared under another exemption in the same calendar year in which he or she claims the Producer/Grower
    – 20,000 Limit Exemption [PPIA Section (464)(c)(1) last sentencebefore (c)(2)];

    3.
    The poultry products are distributed solely by the producer/grower and only within the District of Columbia or the State or Territory in which the poultry product is produced.

    4.
    The poultry are healthy when slaughtered;

    5.
    The slaughter and processing at the producer/grower’s premises are conducted using sanitary standards, practices, and procedures that produce poultry products that are sound, clean, and fit for use as human food (not adulterated);

    6.
    The producer only distributes poultry products he or she produced under the Producer/Grower Exemption;

    7.
    The facility used to slaughter or process the poultry is not used to slaughter or process another person’s poultry unless the Administrator of FSIS grants an exemption [PPIA Section 464(c)(3); Title 9 CFR 381.10b)(2)]

    8.
    The shipping containers, when distributed in intrastate commerce (instead of the required features of a label of inspected product) bear:

    a.
    producer’s name,

    b.
    producer's address, and

    c.
    the statement, “Exempt P.L. 90-492.”
    Instead of the Federal law, a State law may be cited when operations are exempted under the authority of a State law and the operations are reviewed by a State Agency.




    Producer/Grower 20,000 Limit Exemption Notes:
    •
    The producer/grower may sell, intrastate, the poultry products he or she prepares to other businesses for resale as meat or meals, including a distributor, hotel, restaurant, retail store, institution, or small enterprise when the product is produced under a Federal or a State exemption.
    •
    FSIS has determined that when a grower producing poultry under the Producer/Grower Exemption rents slaughtering or processing equipment and operates such equipment on his or her premises, he or she is not disqualified for the Producer/Grower Exemption. In this situation, the grower is not required to request an exemption from the Administrator of FSIS. However, the slaughter or processing unit may not be used to slaughter or process another person’s poultry while it is on the renter’s premises.

    Basically, there are no specifics for what "sanitary conditions" means. As long as you are being clean about your processing and properly storing the birds once they have been butchered, you shouldn't have an issue. We process our birds outdoors with our eviscerating area under a mesh canopy to keep the flies away. We use plain soap to clean everything when we are done for the day, no bleach or other harsh chemicals. Even if you have to have an inspector there (though I can see that as being pricey if you have to pay every time an inspector comes out), you shouldn't have to build any kind of fancy facility. We have had a meeting with a USDA rep. who confirmed that there are no actual regulations for a small grower like ourselves, only guidelines. Keep your processing at least as clean as you would for your own family and you should be fine.

    This is our label (front)
    [​IMG]

    back
    [​IMG]
     
    Last edited: Jul 21, 2011
  3. eatmorechicken

    eatmorechicken Chillin' With My Peeps

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    Wow thanks for the response.

    It was my impression that my birds need to be inspected by somebody... somewhere. The health dep. came down on the farmers markets and now the farmers markets require a certificate of some sort that shows that the birds have been legally processed at a facility.

    Utah requires a permanent building, impermeable walls, sanitary work tables, septic system, bathrooms ect., and that's for under 20k birds. But let me get this straight. If I have 20k + birds a year I must comply with USDA. If I'm under 20K then I fall into the state's requirements. The USDA is pretty much the basic foundation for requirements, then the state adopts and adds onto those reqs. I don't beleive the state really knows how to handle all of the small growers popping up so they use the safest route (use the same method the USDA uses for 20K). 2 growers in my state have built facilities this past couple of months. Both payed A LOT of money. one went state inspected, the other is USDA and charges $5 per bird. The USDA inspected guy tried for a long time to understand what the state was expecting for facilities. In his frustration with the state he decided to go USDA. The state inspected guy is still waiting for approval to use his building and seems hopeful for approval but a little skeptical. Is there any way around this? It would be really nice to know that all of the run around I'm going through is not necessary.
     
  4. eatmorechicken

    eatmorechicken Chillin' With My Peeps

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    Also if your under 20k a USDA inspection is voluntary right? Can I say that I comply with USDA guidlines for small growers and call them USDA complient?
     
    Last edited: Jul 21, 2011
  5. PotterWatch

    PotterWatch My Patronus is a Chicken

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    Farmer's markets can be a whole different problem from simply selling. We are unable to sell at farmer's markets because of county health departments. They want us to be inspected by the USDA but the USDA won't inspect us because we are exempt (we couldn't even get an inspection if we requested it). We are doing everything legally as far as the state and fed. gov., but the county health depts. don't care.

    If your state has imposed more regulations than the USDA, that is too bad. We are lucky to be in a state where we are only asked (as far as the state is concerned), to follow USDA guidelines. Have you tried contacting someone from the state to make certain that you are reading the regs. correctly. That certainly is a lot to ask from a small grower.

    If you are following USDA guidelines, I imagine that it would be fine to say that you are USDA compliant.
     
    Last edited: Jul 21, 2011
  6. Denninmi

    Denninmi Chillin' With My Peeps

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    If you're writing letters, the first people to write should be your state representative and state senator. The legislative branch MAKES the laws, the executive branch only enforces it and fleshes out law with administrative rules. If you want it changed, you need to do that via the legislative branch. So let them know why this law isn't working for you and other small farmers like you.
     
  7. CatDaddyAlbert

    CatDaddyAlbert NoFeathersRuffled

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    I know it seems complicated....and in fact it is. I have been hatching eggs and growing birds for years. I will butcher one once in a while, but not often. I have no problem with it, I just do not do it.

    Having been a field research scientist for Perdue Farms in Maryland I can tell you that the people at the USDA have not a clue CLUE about what goes on. These are government workers waiting for their retirement checks while we, the small grower and farmer, try somehow to make a living. They will let China send contaminated food to this country for human consumption but put unreasonable burdons on people that would like to process even a few birds. It is just what they are and how they work.
     
  8. eatmorechicken

    eatmorechicken Chillin' With My Peeps

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    Quote:There isn't a whole lot of info available on the web... this is from my states mission statement for meat and poultry inspection

    The purpose of the Meat and Poultry Inspection Program is to work in partnership with the meat plant owners to ensure that consumers purchase a clean, wholesome, properly labeled meat product. The meat production facility management has the ultimate responsibility to produce a clean, wholesome, properly labeled product. The meat and poultry inspection program assigns meat inspectors to the meat slaughter and meat processing plants to inspect meat being slaughtered and processed. The meat and poultry inspection program employee is responsible to monitor and verify through records and hands-on verification that the plant fulfills its responsibility. Any consumer who purchases a meat product from an inspected facility in Utah is our ultimate customer.

    The meat and poultry inspection program is granted its authority by a formal set of meat and poultry regulations that have been passed by the US Congress. The state of Utah has adopted these regulations as our own and has formed a cooperative working agreement with the US Department of Agriculture, Food Safety Inspection Service (FSIS) to form and operate an official meat inspection program within the state of Utah .

    When an individual applies and is granted a license to operate an officially licensed meat plant in Utah , numerous requirements must be met to sanction this facility and its operation. The plant must meet specific building requirements, plant management must complete a series of application forms in order to be granted a license to operate an official meat plant in the state of Utah, and an annual fee is required to license a meat production facility.

    then they provide a link for USDA fsis. I talked with the state last year and again several months ago. Both times they told me that all poultry needs to be butchered in a certified facility. then they emailed me this link http://www.fsis.usda.gov/OPPDE/rdad/FSISNotices/Poultry_Slaughter_Exemption_0406.pdf plus another pdf for facility guidelines. This doesn't make sense to me because if they adopt USDA regulations then wouldn't they also adopt the exemptions? I'm pretty sure I need a facility for my birds. The other two growers already built theirs and they have been talking with the state for a year now, and I know they are definitely under 20K birds. My state does not provide clear info concerning poultry processing. They say one thing then send me USDA published articles that say another! I can see why one would just play it safe and go for the voluntary USDA triangle brand.​
     
  9. eatmorechicken

    eatmorechicken Chillin' With My Peeps

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    Quote:That would be a good start [​IMG] thank you for posting!
     
    Last edited: Jul 21, 2011

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