Mobile Slaughtering Questions; from letter to SFJ

[jac]

Hey Geoff I much prefer the phrase “tax avoidance” “tax evasion” is illegal:D.. been under the radar for years tryin not to crash and burn:cool:… good point on the transport of live animals for slaughter.. and 3days!!!!!:eek: is that all the time the big guys hang beef ??.. jeez with hanging times like that its no wonder a lot of folks are turning to chicken… and we all now how bad those are reared by the big guys…
John

[Joshua Kingsley]

Here in the rutland area we have another option and that is there is a fellow that will come to the farm and get the beef or pork to hanging that is state inspected and then he has a small reefer that he transports to a local slaughter house that will cut for retail sale, the deal is that the meat can only be sold in state because it is not Fed inspected but is state…
This has worked well for our farm for personal use because the animals are killed where they have grown and there is no added shipping stress. The cost is minimal compared to some places that process and I am happy that with this situation I can if I want deliver the final blow in a manner that I feel is right.
Joshua

[dominiquer60]

Goeff,
The unit that you describe sounds better than what NY has now. The guy selling meat next to me uses the only mobile unit around here. It is an option that gives the farmer more control over his hanging and cuts. In order to use the mobile unit you must apply for a 20c license. This is the same license that your local cheese maker needs for a cheese room, or commercial kitchen, or grocery store butcher. It basically means that you have clean tested water, a 3 bay sink and a facility that can be sterilized easily, and a working cooler. This guy has a good water source and a cooler and freezer on site, the rest is in the mobile unit and the license to be able to cut is only in effect when the Mobile unit is on his farm.

His animals must be sent to a USDA facility to be butchered for retail cuts, and these cuts can only be sold instate because they are not cut at a USDA facility. The major benefit of this set up is that Frank gets every scrap of meat from his animals and can custom cut, grind and smoke what ever his customers desire as long as it is done in the mobile unit and his inspected smokehouse.

It would be really nice to have a small trailer unit available for on farm exemptions. We had one here in my area when pasture poultry first boomed, it had everything needed to kill and process a few birds under the 1000 bird or less exemption. Why can’t we have something like this for a few pigs or a cow or two. We can slaughter and butcher our own here, but it would be nice to have a small set up that facilitates it easier, and be able to sell a little extra on the side.

It seems that there are many different ways to do a mobile processing unit. If it comes down to having national mobile unit standard for food safety sake I can see how it will take away the benefits that each current system has, and take away from Rural Vermont’s push for an on farm slaughter exemption for sales.

Erika

[Carl Russell]

I agree that a small farmer-owned unit SOUNDS good…. in fact the whole concept of mobile units is good. Where is breaks down for me is creating policy that continues to place regulation on very small producers that require them to operate under financial consideration that will affect the scale of their operation.

The unit that Geoff describes will not come to my farm to allow me to kill one steer at an affordable rate. It will require me to think about either moving my animals to another location, or arranging for others to bring their animals to my farm, all of which interferes with the mindful process that is exemplified by our system.

My story is actually immaterial to this discussion. I only use it to highlight a scale of agriculture that is often dismissed as “hobby”, or “too small to matter”. I understand that in many areas such as where Geoff lives, small operations are much bigger than many operations in our state.

However, what we are doing with Rural Vermont is to try to protect and cultivate a vital food system where there can be many participants. In our region there are many small patchwork farms where people are not going to be able to have an economy of scale that will allow them the kinds of choices that may seem commonplace for larger operations.

The fact is that as nice as having four clean walls may be, they will not guarantee that abscessed livers are noticed, or that intestines are not nicked, nor will they prevent hands from transferring manure from hide to flesh any more than an outdoor venue. What they will require is that these units be kept clean and inspected because of the exposure to many animals and environments, adding cost over the farm-site, even for animals slaughtered for personal use.

Where food sovereignty comes in, is in the action of a government to enact policy that on the surface seems to be reasonable, like four clean mobile walls, which in application add levels of cost and management that cuase operations to make decisions about scale, which in turn affects the base of our food systems, developing larger specialized farms. This sets us as a community up to be more vulnerable to the vagaries and economics that could seriously impact those systems.

The other way that this comes into play is that at our scale, with our mindful attention to how the lives of these animals affect our own lives, and how the environment that they are killed in plays into it, we get almost 30% more per pound for our meat than friends of mine who don’t take it to that level, or sell on the hoof.

Granted what I am doing is illegal, but the only options that are available to them are dictated by regulatory and market-based costs and prices. Because they don’t have the option that I am proposing, they operate at a scale required to absorb costs, which forces them to sell quantity into a market that dictates prices to them.

We just want to see policy that actually reflects the existing patchwork of possibilities that are in practice. We believe that continuing policy that in action affects the scale and methodology of agricultural enterprise is problematic. We have seen our food systems directed by this manner of regulation over the last 75 years, and we can’t continue to accept that. It is important that we think about how regulations affect all scales of enterprises, and without bias implement policy that allows success at every level.

Carl

[mitchmaine]

Carl,
I like your story and its clear that you take great care and pride in your work. I also hear your frustration and pain.

I have a story to share. Years ago, I took great pride in the work I did in the woods. It takes time to do good work with no economic incentive at all. No one paid you then to do a good job. Pulp is pulp and logs are logs, worth not a penny more or less how you cut it.

Then along comes this insurance salesman with a plan. $500. and a certificate and we call ourselves professional loggers. The first to buy in, in my opinion, were the roughest ones of all. But they got the gold star and the certificate and it was still a bunch of bullshit, but landowners bought into it and the papercompanies bought in and gave it some teeth, and before long I was the one out on the street. All the hard extra work meant nothing. So now, cpl is the industry standard, has turned itself around to mean something, but it wasn’t always that way.

Perhaps your story may have a good ending. They are clearly not the same tale at all and you can punch all the holes you want in them, but I hear the tone in your voice and understand the frustration when the system comes in without your invitation to fix things.

Hope you find some peace there. I kept cutting, finding “creative” ways to sell wood, but they got around to plugging up the holes till I couldn’t fit in. my guess is the same thing will happen here too.

Good luck with it and best wishes, mitch

[near horse]

Carl,

I do see and empathize with much what you’re saying. The issue of scale for one thing. I can imagine a system in which there’s a “basic fee” for using the mobile unit and that “fee” would be a much larger proportion of the income generated from one steer slaughtered vs 10 steers and leading to the “slippery slope” of bigger and more to spread the cost out.

In addition, I’m always about 1 second away from punching someone in the mouth when they throw up the term “hobby farm”.:mad: and base it on gross receipts or land used. I just attended an oilseed/biodiesel workshop and there were a lot of “farmers” w/ big land, big tractors, and big checkbooks that I consider to be “hobby farmers” – they don’t actually farm the ground (hired man does that stuff). But those SOB’s sure understood every nuance of the govt subsidy farm plans etc – hardly qualifies as farming.

Please accept my apologies (to all) if I’ve sounded callous to your concerns as that was truly not my intention. I had/have hope that this mobile system could help serve a need for small producers and keep the “nay sayers” satisfied (and silence them for a while). As more discussion goes on, more points emerge that need to be addressed. Including hanging carcasses, custom/retail cutting etc.

As often is the case with legislation, if you can get ahead of it (like it appears you and Rural Vermont are trying to do) and try to guide it, you have a “better chance” of ending up with something you can live with versus trying to change it after it’s been approved. So, some questions that come to mind are: if there were to be a smaller farm exemption:

1) Would you be willing to put a number slaughtered/yr (or whatever) limit on it? Like the 1000 birds thing.

2) Would you be willing to allow some oversight by VAA that there is some compliance with the requirements (whatever they end up being) of the smaller farm exemption? Do they do that with the 1000 birds to make sure you’re not processing more than that?

3) Ther might even need to be some type of documentation that you have “smaller farm” status to allow the exemption etc.

My point is that you make a very good case for the very small producer not being able to really benefit from the mobile unit idea (without serious modifications) – which was supposed to be beneficial to those particular farms. But as you well know, if you’re trying to negotiate a change or exemption etc, you need to have something you’re willing to offer up (those examples above are just a simple few quick ideas, although they might not be the most palatable. More paperwork.)

I’m still completely baffled at the custom cut/retail thing. I’ve never heard of such a thing.

There are some questions that come to mind here that I can’t answer. Like how do those guys sell exotic meat legally? We have some elk and bison guys near us and I know they tried to use the University meat lab (USDA inspected …) with disasterous results. Elk don’t fit in a cattle knock box correctly and not many facilities are ready for bison activity. So how do they get around it? Or emu, ostrich …… I don’t know but it might demonstrate other places that exemptions have been applied.

Best of luck.

[Donn Hewes]

A USDA inspected mobile slaughter plant is a red herring. There is no way a small scale can afford to have an extra person standing around watching us kill and cut a few animals. This trailer is NOT a vehicle to transport a safe, clean, Licensed environment around to the various farms. If that was all they wanted we could do that on each farm. It is a vehicle to transport an inspector. We need to seek clean, safe, simple, and ecologically sound ways to kill, preserve, and sell meat from our farms.

One of the big problems with USDA slaughter today is the great distances we are all driving to get our animals slaughtered, cut and rapped. unfortunately these trucks will haul our meat back to the USDA plant, and just use more fuel than if I had hauled them there myself. Why isn’t there a USDA plant in my county? Because they cost several million to start and are hard to make profitable. This is the problem that needs to be solved.

Like Carl I have nothing against mobile slaughter. We had a state inspected truck visit our farm in Washington State many years ago. It was an excellent kill, and provided our farm, and friends with excellent meat. The carcasses were taken to a local plant a few miles away for cutting and rapping. We weren’t properly prepared to do it our selves back then. Of course this wasn’t a USDA slaughter and we couldn’t sell cuts.

[Carl Russell]

As often is the case with legislation, if you can get ahead of it (like it appears you and Rural Vermont are trying to do) and try to guide it, you have a “better chance” of ending up with something you can live with versus trying to change it after it’s been approved. So, some questions that come to mind are: if there were to be a smaller farm exemption:

1) Would you be willing to put a number slaughtered/yr (or whatever) limit on it? Like the 1000 birds thing.

2) Would you be willing to allow some oversight by VAA that there is some compliance with the requirements (whatever they end up being) of the smaller farm exemption? Do they do that with the 1000 birds to make sure you’re not processing more than that?

3) Ther might even need to be some type of documentation that you have “smaller farm” status to allow the exemption etc.

My point is that you make a very good case for the very small producer not being able to really benefit from the mobile unit idea (without serious modifications) – which was supposed to be beneficial to those particular farms. But as you well know, if you’re trying to negotiate a change or exemption etc, you need to have something you’re willing to offer up (those examples above are just a simple few quick ideas, although they might not be the most palatable. More paperwork.)

I don’t think we as a group have come to a number yet, but I am thinking that the cut off would be something like 10 total large animals annually. Some people think that is way too small, but from my perspective that is truly a small farm, and as you say VAA and USDA are not going to want to see this as an open door. Furthermore, many more animals and the mobile slaughter unit could probably be cost effective…. if they all went at the same time.

I also think the overview is acceptable. We already are required to file paperwork for every animal we take to the custom shop…. and we are trying to make this exemption activated by contractual agreements anyway, so I think that it would probably make sense that VAA be able to see a paper trail.

I think that this is the problem with the so-called exemption, most people think it means no requirements, but I think it only makes sense to validate what we are doing by registering etc. The blind-eye thing is a big part of the impasse. We need to get VAA to understand that we are trying to help them deal with a scale of production that is completely unregulated now because many are flying under the radar.

I/we realize it is a tough row to hoe. It’s just important to make the effort. We actually do have strong support and interest in the VT legislature……..

Carl

[Robert MoonShadow]

First of all, ‘Thank you, Carl’ for starting this thread. I had a suspicion that it might be very interesting – and so it is.

I read Carl’s letter in SFJ, and initially thought I disagreed on some points. I reread it, to better formulate my vague misgivings, only to realize that he didn’t seem to be advocating either way on whether small farmers selling direct to the public should be federally inspected; but rather they should have the choice…as well as the public, as well. After reviewing his letter and the postings herein, I come to the conclusion that no where – NO WHERE, does he even hint that his customers are unaware of the circumstance and situation. They KNOW that he slaughters the meat at his farm – and if they’re actually buying it onfarm, then obviously, they can see for themselves the environment in which he does it. And thus, can evaluate for themselves any possible risks involved. It’s not like he’s selling this meat at Wally-world 2,000 miles away from his home. So who is the government to take away my/your/his choice on what type of meat or food to buy?
For the record: this entire posting of mine is based on my own understanding of Carl’s situation, so any errors or presumptions are mine own.

[goodcompanion]

@Carl Russell 24259 wrote:

Actually in VT, for any meat to be purchased by a consumer the animal must be slaughtered in an inspected facility. That could be a mobile unit. I’ve looked into this, but in Vermont for an animal to be custom cut (facility inspected meat is not), it has to be owned by the person before it is killed, and it must be killed on the owner’s property. So I would have to sell the animal to my customer, transport it to their home, take the mobile unit over there, and then kill it for them.

Carl

As I understand it, the law reads that a live animal may be sold by hanging weight. It is the buyer’s responsibility to kill and butcher the carcass.

This leaves a lot of gray area in which you can project your own scenarios. What if the buyer contracts with another, for instance the farmer, to kill and butcher according to the buyer’s instructions? The VAA says that this is not permissible, but that is just one interpretation of a vague law.

The VAA does say that it is okay for the farmer to carry the live animal to a custom slaughter facility (such as may also process deer for hunters). The custom slaughterers kill and process according to the buyer’s instructions. The resulting product may not be sold retail, and can only be used for the buyer’s household consumption. This practice too is founded on an interpretation.

Technically if it is the buyer’s animal when it is still alive, what right does the state have to intercede and dictate who may and may not be hired and where the job may or may not be done? But the state does insert itself into this contract, like it or not. But the legal waters are very murky.

I remember a friend, Bruce Henessey, was conducting on-farm slaughter several years ago. When told by the VAA to stop, he said that he felt he was acting within the legal framework of the live animal sale law, processing the live animals according to the wishes of their (new) owners. VAA said they didn’t agree, and would take him to court if he didn’t stop. He stopped.

Carl, please correct me if I’m wrong, but I thought Rural Vermont is pushing for the legislature to clarify the original statute, with language would make on-farm slaughter explicitly allowable as a form of live animal sale. The VAA would have to interpret and follow this law accordingly.

In the context of the vague law on the books, the VAA is trying to cover its posterior. If “exemptions” are officially allowed and problems develop, as things stand legally right now, it is on their head.

In the other direction, maybe it is possible that if we liberalize live animal sale to the point that the USDA takes deep offense, maybe there is some federal process to force VT to bring its standards in line. But maybe not? Since we are talking about sales that by definition must be internal state commerce maybe it is none of their concern?

[Carl Russell]

Erik, the law was already “clarified” to say that if the owner of the animal contracts with the farmer to raise and slaughter the animal on the farm then it can be done under the ownership exemption, but VAA has rested on another interpretation that says that it is OK IF there is an inspectable custom facility on the farm, ie. mobile slaughtering unit.

You are right about the USDA and VAA. VT has a meat inspection program that must meet at minimum the USDA standards…. so that is the rub… VAA is worried that they may allow something that USDA would balk at and revoke the inspection program.

My own theory is that VAA actually must continue to create rules to prevent on-farm slaughter of meat for sale, and doesn’t want to address this issue with solutions, precisely because if they acknowledged that it is going on without enforcement, they (we) would lose the program.

Carl

[mstacy]

Carl,

I was moved by your article in SFJ. Judging by the breadth and passion of responses in this thread I am not alone. I had not considered that mobile slaughter units could potentially threaten other on-farm slaughter options, but you raise a very valid point.

I strongly support the concept of contractual consent between buyer and farmer. It embodies the “glass walled slaughter house” concept that Joel Salatin espouses. It is similar to raw milk sales in Vermont. However where the consumer and producer are blind to one another I see state/federal inspection as very appropriate.

From my perspective the food safety regulations are rife with inconsistencies, contradicitions, and vaguaries. In my opinion the “itinerant custom slaughterer” provision (Vermont statute Title 6, Chapter 204, 6 VSA 3306, F) is open to intepretation. If an license-exempt individual can slaughter my customer’s animal can I not legally slaughter the animal myself? How many people get sick from consuming home processed game animals? How many illnesses can be attributed to uninspected poultry in Vermont. I suspect the numbers are relatively small.

There is also the question of what we charge for. Suppose that I sell a pig to my neighbor for a fixed price and then at a later date help him process the animal. Have I violated any laws?

I am oposed to needless transportation of live animals to slaughter facilities. If I raise an animal I feel obligated to see it through to the end.

Regards,

Matt

[goodcompanion]

@mstacy 24581 wrote:

Carl,

From my perspective the food safety regulations are rife with inconsistencies, contradicitions, and vaguaries. In my opinion the “itinerant custom slaughterer” provision (Vermont statute Title 6, Chapter 204, 6 VSA 3306, F) is open to intepretation. If an license-exempt individual can slaughter my customer’s animal can I not legally slaughter the animal myself?

Matt

Good point. I just had a steer custom slaughtered at my farm yesterday, and the felllow said to me that it was exempt for him to slaughter out in the snow like we did it, but not to take the carcass to his own shop and cut and wrap it on behalf of the buyers. Even though his shop is a state-approved processing facility. Doesn’t make sense. But nothing in this debate seems to make much sense.

But at any rate it seems that there is a legal disconnect between this explicit approval for exempt “itinerant slaughterers” and the VAA saying that on-farm slaughter can take place only in inspected custom facilities (as in the Jan 2011 agriview) with all the requirements that are entailed. Pretty long list there actually, you have to have state approved water and sewer connections–that alone rules out most farms being able to have approved facilities, since most ag buildings have neither septic nor sewer.

[near horse]

Wow – I just read thru a summary of the VT regs in something like Agri-vermont. Rife isn’t even a strong enough word to cover that mess I read. It’s like each member of the legislature wrote down one issue then they put ’em in a hat and pasted together the first 10 or 12 they pulled out!

I apologize – I HAD NO FREAKIN’ IDEA it was like that – those folks appear to be able to screw up a rock fight:mad:. Good luck.

Matt – with stupid regs like these we’ll have to escalate from farmer pirate to either “farmer vigilante” or “farmer anarchist” (didn’t want to say farmer terrorist but I thought it.)

[Carl Russell]

near horse;24672 wrote:

….
Matt – with stupid regs like these we’ll have to escalate from farmer pirate to either “farmer vigilante” or “farmer anarchist” (didn’t want to say farmer terrorist but I thought it.)

Now we’re talking:eek:.

In fact there are some folks…. I’m not naming names :D.. out here that may be on the verge of making some public demonstrations….

After all it is our responsibility to break stupid laws.

Carl

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