Each week I visit with a variety of small-scale meat processors in and around Pennsylvania, sharing with me their most recent concerns or challenges. The Commonwealth is a bit of an anomaly when it comes to local meat processing infrastructure … because it has one. There are a handful of similar states, namely Ohio and Wisconsin, yet those states have a state meat inspection program. Pennsylvania, on the other hand, relies on federal inspection, and because of that, we have more USDA-inspected small and very small (those are USDA categories) plants than any other state.
This post is about different types of inspection and their associated rules, but before we get any further into the matter, I will explain a few things about state versus federal meat inspection. I have been approached by various groups whose members have somehow developed the notion that state meat inspection would be “easier” (less rigorous?) than federal inspection and that Pennsylvania would be better off if it had state inspection. Aside from the cost associated with it (to the state’s budget), it is federal law that a state inspection program must be “at least equal to” a federal inspection program. In fact, USDA-FSIS provides guidance about what states and local administrations should consider when identifying and addressing potential foodborne hazards.
The regulations pertaining to meat processors are extremely complex, so I’m going to take a stepwise approach in explaining them via a series of blog posts. The intent is to inform livestock producers and people interested in the meat processing business of what rules to consider (and this also goes for current meat processors who might need a little rule refresher…). Today I’m going to discuss some of the rules associated with animal slaughter and how that impacts subsequent sales of meat (for PA).
The short version: if you are going to receive payment for pieces of meat (restaurants included), the animal must have been slaughtered at a USDA-inspected slaughterhouse. There are two kinds of slaughterhouses in Pennsylvania – (1) USDA-inspected and (2) USDA-custom exempt (sometimes just called “customs”). With option #1, a USDA inspector is always present during slaughter. With option #2, some compliance folks from USDA visit the plant maybe once or twice per year. Really the only use for a custom-exempt slaughterhouse is if the meat is to be used by the animal’s owner… and that is all. In a custom-exempt situation, the side or quarter or whatever share of that animal must be sold before the animal is at the slaughterhouse. That’s why the meat *should* have “Not For Sale” stamped on all packages of the end product.
I take that back … there are probably 3 types of slaughterhouses in Pennsylvania, with the 3rd being so hopelessly distant from options 1 or 2 from above that we will not even discuss them …
Somewhat confusingly, because USDA requires certain things of custom-exempt processors and this is explained in various ways to the slaughterhouse customer (often the producer, not the consumer), people are confused as to whether or not the slaughterhouse is inspected. Just because they need the contact information of customers to accommodate USDA needs does not mean they’re inspected. How can you find out if a plant is “inspected” or not? Ask them if what their first [species you’re contracting] slaughter CCP is. If they can answer quickly, then it’s probably a legit deal.
Why am I making a big deal of this? First of all, I don’t like it when people get into trouble for doing something they didn’t know was wrong. There are many do’s and don’ts… What someone can or cannot do with meat from an animal they raised should be known by the farmer, but that’s not always the case. Nor can the processor always explain the rules. Second, this subject received my attention after hearing from many existing USDA-inspected processors in Pennsylvania (and other states), stating that custom-exempt processors were undercutting their butchery market. The frustration is this (and I only have anecdotal information yet it’s very believable to me): a farmer opts to go with the less expensive custom-exempt processor (since they don’t have nearly the operating expense as an inspected processor) and the turns around and sells that meat illegally.
That’s a very interesting situation considering I so often read about how there’s a national shortage of inspected slaughterhouses. Are people that are willing to butcher the rules essentially aiding inspected operators to go out of business? Is this a problem that is being fueled, at least in part, from within?
Next time I delve into regulatory questions I will discuss “retail exempt” and what that means…