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New USDA Rules Will Put Small Slaughterhouses Out of Business

by: Jill Richardson

Mon Apr 19, 2010 at 18:40:57 PM PDT


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One of the biggest hurdles to producing or obtaining local, sustainable meat is the lack of slaughterhouses that are USDA-inspected (or even state-inspected) and willing to slaughter livestock in small, occasional batches from small farmers. The big slaughterhouses want a constant supply of animals to kill - they aren't interested in processing 15 cows a year if that's all you've got. A friend actually looked into what it would take to have a local slaughterhouse process her chickens. The answer came back: Don't bother asking the price, you can't afford it. The reason? For the slaughterhouse to do all of the required cleaning before accepting her small number of chickens, it would cost so much that the cost-per-chicken would be outrageous.

It's with this in mind that I read a very disturbing email that was forwarded on by the Cornucopia Institute. The email lays out a problem very well, so I have pasted it below but removed anything identifying the sender. The basic problem is that the USDA wants to impose regulations on all slaughterhouses (big and small alike) that would cost the little guys (or their customers, small farmers) more money than they can afford.

Jill Richardson :: New USDA Rules Will Put Small Slaughterhouses Out of Business
Hi all,

I'd like to make you aware of an issue that small meat processors and slaughterhouses like [us] are dealing with right now that could have long-lasting and detrimental impacts on farmers and anyone who is involved in this ever-growing sustainable food movement.

On march 19th, the USDA responded to a letter that meat industry associations had sent 6 months prior, looking for clearer interpretation of certain regulations about validation of their HACCP systems (Each plant is required to have a HACCP plan in place to maintain pathogens like e coli, regulate safe handling of animals, and regulate safe, germ-free processing).

The response from the USDA to the meat associations, sent by Alfred Almanza, the administrator of the Food Safety and Inspection Service, was astounding. It outlines proposed regulations that would cost small meat plants hundreds of thousands of dollars annually!

The proposed regulations would  require every meat plant (no matter how big or small), to perform their own  testing of carcasses, products, and machinery at every point of processing by collecting samples and then sending them to a lab. The data collected in these tests would be further documentation of pathogen control in the plant. Currently, smaller plants (who do not have the capabilities to perform these tests) are able to use previously collected data and apply it to their own methods. This has proved a safe and reliable method of controlling pathogens thus far.

Based on the figures presented in that document and the number of different products that [our plant] currently offers, (bacon, hot dogs, sausages, bologna, etc. in addition to our handling of raw meat cuts) the proposed regulations would have an additional cost to us and other small meat plants of over $500,000.00 with an additional $180,000 per year after that!

The proposed regulation would not only affect us, but would have direct implications for farmers with whom we do business.  As a result of the added cost to us, we would have to raise our processing costs by $.50-$1.00 a pound! As the proposed guidance document is currently being interpreted, this is a very real issue with very real implications for us as a processor and you as livestock producers and interested stakeholders.  By increasing the demands for pathogen control, the USDA is only making it more difficult for small, local slaughter facilities to exist.

Below is an excerpt from Capitol Line-Up, a newsletter put out by the American Association of Meat Processors (AAMP), from April 1, 2010:

This initiative has the capability of removing a majority of the remaining very small and small meat industry establishments from inspection. It will hinder commerce. It will stifle the meat industry by removing the variety of products currently available. It will obstruct the production of any new products from being produced and be commercially available in commerce. It will raise the cost of the products being produced, thus the overall cost the consumers will pay. It will cause establishments to cut jobs as they downsize due to the lack of inspected meat product production. It will force more of the meat industry to put more products out of the current reach of inspection an into retail exemption.

-Jay B. Wenther, Ph.D
President
American Association of Meat Processors

The letter goes on to explain that there's a website that will have updates on this as they become available and asks folks to send comments to the USDA before April 19 (today). It's a little late for that but if you have any interest in trying to send in comments anyway, give it a go. The email address to send to is draftvalidationguidecomments at fsis.usda.gov

Hopefully, Cornucopia Institute will follow this issue and I'll be able to follow up and tell you what ultimately happens.

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USDA wants to impose (4.00 / 2)
I am not a conspiracy theory person. I don't think I am, anyway. I try not to propogate them, and I try to discount those that find their way to me.

But honestly.

The more stuff like this I read, the more I think that perhaps USDA is responding to inexorable pressure from Big Ag to put the little guys out of business. It never stops. A battle can be won, but the war continues.

All in all, it seems that the best that can be said for USDA is, it has severe schizophrenia in this arena.


Add to your theory (hypothesis), (4.00 / 2)
the fact that most regulators don't have the slightest clue about the differences between large scale slaughter houses and small slaughterhouses.

Add to those, the fact that most regulators and especially legislators, have, as their primary input, those players in the large scale national and international slaughter/packing/processing industries, and you have a perfect storm that has the very real potential to put small slaughter houses out of business, even if that wasn't the actual intention.

That's why I'm all in favor of onfarm custom slaughter. If you care that much about supporting local farmers/ranchers, then spend a little extra money to buy a chest freezer and buy a half, whole or quarter animal and put it up for the winter. The only reason private citizens need inspected slaughter is if all you want to buy is a steak or roast here or there.

Of course, on farm custome slaughter doesn't work for restaruants and others in the food service industry.

The thing about commercial slaughter, at least as far as poultry goes, is that the integrators (Tyson, Foster Farms, Perdue, et al) have already gone out and built their own slaughter houses. There's nothing to stop individual farms from doing the same thing, except that it's horrendously expensive and you have to more A LOT of poultry to make it pay, which is why the integrators are, as they say, vertically integrated.

And then there are interesting USDA slaughter rules like for rabbits. If you slaughter rabbits, even if it's only one, you are not allowed to slaughter anything else until the next day. Why? I have no idea, and neither did the FSIS inspector for my area when she told me that. We were both mystified.

I've been looking into getting a permit for on site custom slaughter so I can charge for the service for the animals I raise here and sell to my CSA subscribers. I think I can do it for around $1,000 to build the facility, and a bit over $200/year for the permit. I'd have to slaughter a lot of chickens and rabbits to pay for that.

Normal people scare me.... But not as much as I scare them.


[ Parent ]
permits (4.00 / 2)
would a small or mobile facility need separate permits for different animals? Would one facility be subject to different requirements depending on animals slaughtered? If one facility could use one permit for fowl, rabbits, goats, sheep, emus, cattle, hogs, etc., maybe it would make more sense.

Something like this happened in Canada a year or two ago, and small facilities were indeed put out of business. I forget whether the situation was provincial or federal, but I think it was provincial (British Columbia.) Communities are trying to get together to build regional facilities but it is, as you note, horrendously expensive.


[ Parent ]
Well, it depends on the country, (4.00 / 3)
and in the US, it depends on what state you're in and if you want to sell to restaurants, or sell meat to consumers.

I'll let you know what I understand of the rule in Oregon. I'm only going to do Oregon because that's the state I'm most familiar with, as this is where I live.

Here, as I understand it, you may slaughter up to 20,000 poultry/year without federal inspection, no permit, etc., as long as the poultry meat isn't crossing state lines. Oregon does not have state inspection, so it's federal or nothing. I think than any time you sell meat that crosses state lines you need federal inspection, but I don't know if that's poultry meat or red meat, I think it's both.

That's federal for poultry. Then Oregon rules take over for intrastate sales. Here goes -
If you slaughter fewer than 20,000 birds you don't need to do it under inspection, you're exempt. However, if you receive any compensation for the slaughter, you must have a permit allowing you to do custom slaughter, you have to have (I think) a seperate permit for red meat (which, in Oregon, oddly enough, covers emu as well as hoofstock, even though I thought that emu were classified as poultry in this state) and one for poultry/rabbits. Those permits are in addition to a food license of some kind, I forget which. That's so you can sell live animals and slaughter for the buyer of the live animal(s) for their own personal use.

I think, that in Oregon, there are some other hoops you have to jump through if you want to slaughter poultry and/or rabbit for sale to restaurants or to sell dressed birds or rabbits to customers.

I think Kookoolan farm in Yamhill county, Oregon recently built a facility to process poultry, but I don't know if it's inspected or if it's just so that they can sell dressed chickens at the farmers markets.

It's kind of confusing because when you look at the statutes, one set says one thing, and another will say something that seems to be completely the oposite. For instance, one will say if you slaughter for any kind of compensation, that you have to have a custom slaughter permit, which would lead one to think that perhaps if you did the slaughter for free, then you'd get out of all of that. Then the next one I read said that if you did any slaughter that wasn't for your own personal use, you had to have a permit, which would lead one to believe that if you went over and helped a neighbor slaughter a steer you'd be breaking the law, which is complete bunk, but who knows.

I've even gotten conflicting answers on poultry from our local FSIS inspector when I talked to her once. I try not to call her, because she gets one hour/day in the office, other than that she's in plants inspecting, sampling, etc. and I hate to bother her with a question that I should be able to answer on my own by looking up the appropriate statutes.

The only mobile slaughter I know about here in Oregon, is a custom slaughter out of Colton just a few miles from here. When he slaughters an animal for you, if he does the cut/wrap, the packages come back marked "not for resale". There is one inspected mobile slaughter up in the Puget Sound area in Washington state. The slaughter has an inspector who travels with it and the slaughterman. The nice thing about federal mandatory inspection - the government pays the inspector's wages. Under voluntary inspection, which is what happened to the emu industry right at the begining of the slaughter market, the slaughter house pays the inspector's wages. FSIS inspectors are not cheap, they don't work for anywhere near minimum wage, and they are all licensed, accredited veterinarians. That costs lots of $$$. It's one of the major reasons the emu slaughter market went in the tank. No one could afford an extra $100/head for the inspection.


Normal people scare me.... But not as much as I scare them.


[ Parent ]
What is the purpose (4.00 / 1)
of an inspector in small/mobile facility situations you describe? What might go wrong without an inspector? Whatever the purpose of an inspector is, could the same purpose be accomplished by having the slaughterman be trained/accredited/certified/licensed in some way, preferably without the need to be a veterinarian?

[ Parent ]
In general (4.00 / 2)
if you want to sell meat by the pound as opposed to selling live animals, the animal has to be slaughtered under inspection. The mobile inspected slaughter enables the unit to come to the farm as opposed to the farm transporting animals to the facility.

I think there has been some talk about having inspectors specially trained and relaxing the veterinary standard. One reason, maybe, that they are required to be veterinarians is that one of the inspector's duties is antemortem and postmortem inspections for health. Personally, I think there's no reason why a slaughterman(woman) shouldn't be able to do the inspection as well as the killing, dressing and cut/wrap, but maybe that's just me. The postmortem inspection includes collecting certain organs and looking at organs for signs of disease. Anyone who slaughters animals for any lenght of time should know how to do that anyway. Also, with the shortage of inspectors, which FSIS has been alerting people to for a long, long time now, I'd think that making it possible for non veterinarians to become inspectors would be a real advantage.

Normal people scare me.... But not as much as I scare them.


[ Parent ]
When I worked for a Boeing contractor... (4.00 / 1)
...painting airplanes, we had FAA inspectors come in occasionally and flip the place upside and down, but after they were satisfied we were all properly doing the jobs we were trained to do, they left and that was it.  Until next time.  The inspectors didn't have to stay and watch us work the entire time, both 12-hour shifts 24 hours a day for the 8 - 9 days the plane was in our hangar at PDX.

So yeah, good question -

Whatever the purpose of an inspector is, could the same purpose be accomplished by having the slaughterman be trained/accredited/certified/licensed in some way, preferably without the need to be a veterinarian?

Aren't these people called "supervisors" in every other industry?

Ha, now that I think about it - when I worked for American Red Cross Blood Services, we never had FDA inspectors hanging over our shoulder while we worked, either.  And when I was in environmental remediation in New Jersey, no state DEP/DEC/DNR/etc... or EPA people ever visited the lab or any of our field sites.

So in terms of ensuring "safety", aren't things like the nation's blood supply and commercial air fleet just as vital to everyday life as our interstate meat supply?  The Red Cross doesn't get shut down when FDA isn't in the building...

Coming soon to a Philadelphia near you!


[ Parent ]
On farm processing (4.00 / 2)
In Ohio you can process up to 1000 chickens (and likely other fowl) on your farm but you cannot process a single cow, pig, sheep, goat or deer on your farm for any reason. And those chickens can be sold from the farm only to individuals. you cannot take the meat to a farmers market, you cannot sell the meat to any institutions which means without a state or USDA inspected slaughter house you get incredibly limited on how and to whom you can sell.

I guess I could build my own slaughter house but since I spend most of my time raising and marketing produce I would have zero time to actually run the slaughter house and most farmers I know are in the same boat-if there were a 1000 hours in a day and I had a staff of 50 than I could swing such. of course I am lucky to live within a n hour of a state inspected facility that already does the whole HCCP (you have to if you can do inspected slaughter) thing and I think can weather this new regulatory storm. They are reasonable at $4 a bird killed, cleaned, bagged and labeled (if you have ever processed 50 chickens in an afternoon in a cloud of mosquitoes than you know exactly how reasonable this cost is)


[ Parent ]
speaking of Ohio (4.00 / 1)
What did you find out about mushrooms/truffles?

[ Parent ]
Truffles (4.00 / 2)
I found out they were indeed truffles but likely not the culinary kind (but still edible) and That I do not think I will ever become a truffle aficionado-man they stink!

[ Parent ]
Thanks for reminding me. (4.00 / 1)
When I read about prices paid for local chickens, I don't think about costs of slaughtering, etc. My bad.

[ Parent ]
The future is Mobile Slaugherhouses (4.00 / 2)

http://seattletimes.nwsource.c...

The old slaughterhouses are going to go away since it makes sense to bring the slaughterhouse to the farmers.  I suspect the carbon foot print is lower since farmers are not transporting animals to the slaughter facility.

These mobile facilities are easier to clean and the USDA inspector travels with it.

Sometimes old technologies out live there usefulness if not our nostalgia.  



Now (4.00 / 2)
Now if we can get these to every county in the USA. Right now maybe 5% of the USA is covered by such things and several states are making it very hard, if not impossible to set up mobile units.

[ Parent ]
I agree with you, especially for inspected slaughter (4.00 / 3)
The nice thing about the mobile facility is that it's way, way less expensive to build/buy one of those, as it's essentially a large, specially equiped trailer. I think the one up in Washington state cost around $250,000 to build. A fixed location facility would cost between $1,000,000 and $2,000,000 to build.

Because the animals don't leave the farm, there's no shipping stress, injury during shipping or shrinkage due to shipping. You could have a kill pen and even train the animals to enter on their own on cue, which is kind of what I do for emus and will be doing for the calves, goats, lambs, and any other large animal we slaughter or have slaughtered out here. In my opinion, on farm slaughter is absolutely the best way to go.

The disadvantages to mobile slaughter is the driving, and the mobil unit can't process as many animals in a day as a fixed location slaughter house can. Plus, you still have to have a facility to hang the carcasses in and an inspected facility to cut/wrap.

But on the plus side, you don't have to have lairage to hold the livestock between delivery and slaughter. Groups of livestock need to be seperated from each other for a variety of reasons - to keep different customers' animals straight (you don't want to deliver customer A's lambs to customer B and vise versa), also, when you bring a group of animals into an area, especially if the confines are tight, you don't want to bring one group in and then bring another group in even a few hours later as the first group will have set up a territory and you're liable to get fighting to establish dominance, which will bruise and stress the animals even more than they are already, and may well lead to injury.

With mobile slaughter, each farm can provide it's own lairage, even if it's just a simple pen.


Normal people scare me.... But not as much as I scare them.


[ Parent ]
From the NY Times today... (4.00 / 1)
The lack of slaughterhouses is one example of how the rapidly growing local-food movement has taxed the existing food production and distribution networks. Some advocates of the small farmers have called for help from Washington. What role, if any, should the federal government play in creating better food processing and delivery systems?

   * Zachary Adam Cohen, consultant
   * Blake Hurst, farmer
   * Tom Philpott, Grist.org
   * Benjamin Shute, farmer
   * Wenonah Hauter, Food & Water Watch
   * Miriam Latzer, farmer
   * George Saperstein, veterinarian
   * William Alexander, author

Each contributor's piece is at the link...

Coming soon to a Philadelphia near you!


Personally I'd like to see more people (4.00 / 2)
buying whole/half/quarter live animals and having slaughter/cut/wrap done by exempt custom slaughter. I would say that in every state in this country there are custom slaughter service providers.

So the real reason we need more inspected slaughter is that people want to be able to go out and buy a steak for dinner instead of going to the trouble of getting a chest freezer and putting up meat for the year.

You know, as much as I'd like to see more inspected slaughter for independant producers, the fastest way to do this is to encourage people to buy live animals and have them custom slaughtered.

Normal people scare me.... But not as much as I scare them.


[ Parent ]
By (4.00 / 2)
the fastest way to do this is to encourage people to buy live animals and have them custom slaughtered.

this I meant that the fastest way to increase availablilty of locally raised red meat animals and poultry available to consumers.

Normal people scare me.... But not as much as I scare them.


[ Parent ]
Agreed... (4.00 / 1)
I was thinking the other day about picking up an eighth of beef from Kookolan Farms in Yamhill (Kookolan says you can legally sell down to an eighth in Oregon, I thought it was a quarter?  that's even better!), and maybe also splitting a half of a lamb or a pig with a neighbor (yes, my years-long vegetarianism recently lapsed, obviously).

I don't have the upfront cash or the freezer room right now, but I do think that's what I'm gonna do next year.  An eighth is a good size for me, I think I can use it all especially when family comes to visit, but it'll take up the entire freezer for a while.  That's okay though, because there's pretty much nothing in my freezer to begin with!  Heh.  Just some asparagus, and maybe some other stuff soon.  A pint or quart of ice cream in the door, occasionally...

Have you heard of the Portland Meat Collective?  Sounds like they're working on encouraging the same thing you're talking about for those of us in the city who don't quite have the room for chest freezers, or who live alone, etc.  I'm gonna get in touch with them soon.

Coming soon to a Philadelphia near you!


[ Parent ]
I've been in touch with Portland Meat Collective (4.00 / 2)
I'll be raising rose veal, lamb and goat if you're interested.

PMC seems to still be in process of getting the organization off the ground. I've heard back from them intermittently off and on for the last few months.

Berlin Reed of The Ethical Butcher has also been in contact with them I think. I have a lot respect for Berlin. He's been jumping through all the hoops to be able to sell the bacon he's been making in Portland. I so much want to get some of his bacon, especially the lamb bacon. OH HEAVEN!

Normal people scare me.... But not as much as I scare them.


[ Parent ]
I may still be raising a couple of pigs if you're interested (4.00 / 2)
but it looks like the gal I was going to buy the weaners from won't have any till fall, so slaughter would be in the spring. The lady I want to buy weaners from is in Estacada and has Tamworth pigs.

Normal people scare me.... But not as much as I scare them.

[ Parent ]
Cool... (4.00 / 1)
We'll talk!

Coming soon to a Philadelphia near you!

[ Parent ]
lockers (4.00 / 1)
Today my brother stores his meat in his own freezers, but when my father was alive and hunted, he had the game processed at a facility that offered freezer lockers. If freezer lockers aren't available now, maybe they will begin to become available.

[ Parent ]
Self Storage... (4.00 / 1)
Seems like an opening for one of the dozen or so large 'self store' facilities scattered around industrial areas of every medium-to-large American city.

Load a single storage unit with a few individual lockable chest freezers, only hook them up to power when they're rented, you can probably make back the initial investment in 2 or 3 years, or less...

Would be interesting to look into how many of these places have empty space that could be better used for other purposes (such as providing space for meat lockers).  There's even one of them a little over a mile from me, at SE Holgate and 17th Avenue adjacent to the Union Pacific Brooklyn rail yard.

Coming soon to a Philadelphia near you!


[ Parent ]
That's brilliant! (4.00 / 2)
A couple years ago, I saw an article in the Philly Inquirer about self-storage for wine collectors.  This seems like a much better use of the climate control.

[ Parent ]
It would be a great idea (4.00 / 2)
except I doubt that a place like a storage unit rental company would be interested in jumping through the hoops. To store food for someone else you have to have a licensed and inspected food facility.

A better approach would be for friends to get together and do something like this - friend A buys a small chest freezer and parks it as friend B's place. Put a lock on the thing and pay your friend for the electricity to run the thing. If you buy your own freezer, you'll make your investment back in the first year you use it to store your meats, and it's darned handy for putting up those vegetables for winter.

Don't have a friend who'll do that for you? Get together with several friends, each of you has a small chest freezer, you all go in on a small unit at a place like Public Storage. Each puts a lock on their own freezer, and each has a key to the storage unit.

Low cost, and no one has to get a fancy, shmancy food permit or have the health inspector over. Plus you're all portable. If you ever move, your freezer goes with you and you're not dependant on moving to another location with a meat locker, all you need is electricity.

Normal people scare me.... But not as much as I scare them.


[ Parent ]
public storage (4.00 / 1)
Jay's/your idea sounds like a business opportunity for the public storage places. I don't know if any now have electricity in the units, most don't except for a light, but they could change that easily enough.

[ Parent ]
There's always a business oportunity somewhere (4.00 / 2)
PS has climate controled units available, and I wouldn't be surprised if there weren't electrical plugs in some or all units. I supose it depends on what the building code says. I know in residential and commercial construction there are different requirements depending on where you are in the building and what the use will be.

Normal people scare me.... But not as much as I scare them.

[ Parent ]
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