This is the second part of an article exploring Georgia’s poultry processing rules. Read part one here.
Georgia’s small-scale farmers face a barrier to growth in the poultry industry: If they want to slaughter more than 1,000 birds a year, they must meet stringent inspection standards established by the U.S. Department of Agriculture for large-scale poultry processing operations.
The USDA imposes strict rules on commercial poultry processing plants. For sanitary reasons, the plant must meet very specific construction guidelines. Each bird that is killed must be approved by an employee of the USDA’s inspection arm, the Food Safety Inspection Service. And the business must provide office space, laundry and cleanup facilities for inspectors.
Normally the USDA doesn’t require bird-by-bird inspection for businesses that slaughter fewer than 20,000 birds in a year. But Georgia’s rules do not acknowledge this exemption for small farmers, essentially requiring any farmer processing more than 1,000 birds a year to meet the federal inspection requirements for commercial processors.
The problem? Local-food advocates say the requirements are too difficult and costly for small farmers to meet.
A complex process
A 33-page document called “Applying for a Federal Grant of Inspection For Meat and Poultry Establishments” (which refers the reader to several more external pages of federal code) outlines a multi-tiered, seven-step process. It includes creating written plans that outline food safety and sanitation procedures, called the Standard Operating Procedure for Sanitation and the Hazard Analysis Critical Control Point plans.
“If you’re going to apply for a grant of inspection through FSIS/USDA, there are a number of guideless to meet their standards to be inspected—everything from where the wastewater goes, to what you do with the bird feathers, all the way into proper lighting and cleanable surfaces,” says Brian Sapp, manager of a nearly complete, million-dollar poultry processing plant at White Oak Pastures in Bluffton. “[Just] developing a HACCP plan, getting it approved, and coming up all with the documentation, that could take 40 to 50 hours for somebody who knows about HACCP. Your average everyday farmer, it would probably be impossible without help.”
Sapp estimates that constructing a 20,000-bird-a-year plant to meet federal inspection standards would cost between $500,000 and $700,000. To clear a profit, “You’re talking at least 10 years,” he says.
The costs associated with adhering to the rules are much more manageable for commercial processors, who in Georgia slaughter about 4.6 million birds per day.
Rex Holt, who as head of the Georgia Department of Agriculture’s meat inspection program patiently fields questions about Georgia’s non-existent poultry inspection program, says the state’s hands are tied. “A lot of my interpretation is from the FSIS folks telling me how to interpret [the Georgia rules],” he says. He’s not convinced that changing the rules would be in the best interest of the consumer, anyway: “If we did have the ability to open up the rules, in my opinion we’d be lowering our food safety standards.”
In the absence of a review and possible rewrite of those rules, Georgia farmers who wish to raise relatively small numbers (between 1,000 and 20,000) of pastured birds have few options. In theory, they could bring them to a nearby independent processing facility (called “custom slaughter” in FSIS vernacular) that has earned federal grant of inspection. Unfortunately no such business exists in Georgia.
“The facilities that have gotten up and running, they have not survived. You have to have the market there,” Holt says.
So for now, at least, farmers who want to process more than 1,000 birds per year must load them onto a truck, drive them several hours to a processing plant across state lines (the nearest are in Kentucky and South Carolina), wait all day while the birds are killed and processed, and then drive the resulting product back.
The transport expenses of such an undertaking, plus the loss of at least one full workday, cut deeply into a farmer’s profit margin. Not to mention the toll on the birds. Pastured poultry farmers go to great lengths to provide their birds with natural, low-stress lives, an effort that is severely undermined by forcing the birds into crates and hauling them several hours before they are sent to chicken heaven.
Why should you, the consumer, care?
• Cost: The added expense of fuel and loss of time adds to the price of pastured poultry.
• Economic opportunity: “This is an economic issue for rural farmers,” says Jennifer Owens, Georgia Organics advocacy director. “There are no options for processing for an independent producer in Georgia. The big guy is shutting the little guy out at a time when the economy is really depending on the growth of small businesses, particularly in rural areas.”
• Environmental impact: The locally grown chicken you just bought for dinner in all likelihood took a road trip out of state. That trip burned fuel.
• Animal welfare: If you buy pastured poultry in part because you care about the quality of the animal’s life, then you probably would prefer that it not be subjected to a frightening six-hour trip—in a crate, on a truck—before it meets its end.
The GDA advocates that farmers pool their resources and build a cooperative poultry processing plant. (Holt says in recent years, state universities have expressed a willingness to explore the idea.) Georgia Organics is raising funds to help with the construction of an independent facility.
In the meantime, farmers are training hopeful eyes on Will Harris III, president of Georgia’s most famous grass-fed beef operation, White Oak Pastures—and Georgia’s 2011 Small Business Person of the Year. Once White Oak’s new 130,000-bird-per-year processing plant is up and running, Harris wants to offer its services to smaller free-range poultry farms.
Kurt Ebersbach, a senior attorney with GreenLaw, has been working with Georgia Organics to advocate yet another solution to the state: Change the rules. Georgia could accept the federal inspection exemption for producers of fewer than 20,000 birds, he says. Or it could provide for a more cost-effective inspection system as opposed to bird-by-bird. “Exempt facilities still have to follow sanitary practices,” he says. “The GDA can ensure that smaller facilities are following sanitary practices by checking them periodically and by requiring them to furnish a sanitary practices plan as a condition for getting a license. They can do unannounced periodic inspections to verify that facilities are implementing sanitary practices.”
If the GDA were to explore a revision of the rules, Holt says, “We’d have to bring all the people to the table”—including state food safety and consumer protection experts, small farmers and large processors.
Some of the local farmers I’ve spoken with theorize that Georgia’s poultry giants are the real reason that hasn’t happened. Is it actually possible that Big Chicken would put up roadblocks against these teeny producers of free-range birds? I have no idea. But what is clear is that the current food-safety inspection rules hamper the ability of Georgia’s small farmers to make a living raising pastured poultry. And that is not necessarily good news for our food supply.
Food safety is, after all, one of the driving forces behind the local food movement. Many consumers believe, for good reason, that small-scale farmers who are raising food for their neighbors are inclined, for social and economic reasons, to handle that food with special care.
Sanitation is essential. But bird-by-bird inspection does not ensure total food safety. Notes Ebersbach: “The big places that are doing routine inspections, it’s not like it’s a great guarantor of public safety. Given the sheer volume of birds going through, the inspectors have only a few seconds to examine each bird.”
Image: A plant with the capacity to slaughter and process well over 100,000 birds a year—still tiny compared to Georgia’s large commercial poultry plants—is under construction at White Oak Pastures in Bluffton.