The proposal I made on this blog back in January, to allow direct sales of meat butchered at customer processors between the meat’s producer and the final customer, has taken an interesting step forward (read my first followup here).
After I posted the same proposal to the Columbia Tribune’s online food forum, it generated a good discussion and was generally well-recieved by respondents. A reader with political connections forwarded it on to a local state representative, Chris Kelly, who expressed interest in pursuing the idea and contacted me to discuss it further. I had sent the idea to my own state rep, Paul Quinn, who didn’t take an interest and dismissed it by offering this gem: “the bottom line is that you will have to deal with the rules and regulations.” Mr. Kelly, on the other hand, took an active interest in the practical and philosophical value of the idea, and has promised to have his staff research the legal and practical possibilities of moving forward.
So while that’s happening, I just want to post a few more bits of information that offer a framework for how this could happen. Missouri seems to follow the Code of Federal Regulations (CFR) in dealing with meat processing laws, as the Missouri Meat and Poultry Inspection Program (MMPIP) cites CFR for all its regulatory framework (as opposed to a more stringent Missouri law). Thus:
9 CFR 303.1 exempts the custom preparation of carcasses, meat or meat food products derived from the slaughter of cattle, sheep swine, goats or game animals from official inspection. However, custom operations are subject to sanitary inspection by the Missouri Meat and Poultry Inspection Program.
This proves that custom facilities are inspected by the state and found to adhere to sanitary standards, so there are basic consumer protections in place.
Moreover, Missouri apparently follows CFR 381.10 in exempting poultry processing and sales from inspection as long as the product is “sanitary” and is labelled with “the processor’s name and address and the statement `Exempted–P.L. 90-492′”. This includes:
The slaughtering of sound and healthy poultry and processing of poultry products…by any poultry producer on his own premises with respect to poultry raised on his premises, and the distribution by any person solely within such jurisdiction of the poultry products derived from such operations; CFR 381.10(a)(5)
The slaughtering of sound and healthy poultry or the processing of poultry products…by any poultry producer or other person for distribution by him solely within such jurisdiction directly to household consumers, restaurants, hotels, and boardinghouses, for use in their own dining rooms, or in the preparation of meals for sales direct to consumers; CFR 381.10(a)(6)
The operations and products of small enterprises (including poultry producers) not exempted under paragraphs (a) (1) through (6) of this section that are engaged in any State or territory or the District of Columbia in slaughtering and/or cutting up poultry for distribution as carcasses or parts thereof solely for distribution within such jurisdiction; CFR 381.10(a)(7)
I had known that uninspected processing and sales of poultry on-farm were allowed, but until doing some further research last night had not known that official Federal policy is to allow all of the above (and quite a bit more if you read through all of CFR 381.10) without inspection and with a basic labelling requirement.
How much more of a precedent do we need? There is a clear regulatory framework available for custom processing of poultry without state or federal inspection, relying on labelling to distinguish the products from those which have been inspected. In fact, Federal law for poultry is quite a bit looser than what I had proposed for livestock (I had not included the possibility of sales to retail or restaurants).
Seems to me that all the precedents and frameworks are in place for this. For some reason of which I’m not aware, poultry are treated very differently from livestock in Federal and state regulations, but I don’t see any reason that this should be the case. It’s an arbitrary and illogical difference that holds down the development of small farms and restricts consumer choice in their meat supply. Let’s hope Chris Kelly can get somewhere with this.