Farm Enterprise Regulation
Posted: June 3, 2010
The only thing that aggravates me more than regulations, regulators and rules – is the consequences of not understanding the risks we take when we don’t follow the sanctioned steps for starting, owning or managing a business. Add the requirements that go specifically with a farm and/or food business, and the information to learn and contacts to make seem vast. Unfortunately, if we don’t take the time, we remain outside the system. And when trouble strikes, those outside the system are at greater risk of negative social, financial and environmental impacts, than those in the system, or so I believe.
Where to begin? Today, I’d like to briefly explore the things I believe those farm-types selling directly to consumers, and/or involved with any sort of processing might want to be aware of.
Produce: Direct marketed, fresh off the stem, local farm produce has virtually no regulatory framework or oversight. Keep it clean, wholesome, off the floor, protected, and cooled. The buyer is expected to wash everything at home. But, as soon as we take a knife to something, we are now processors.
Produce processor (not potentially hazardous). In Pennsylvania there are a few straight forward regulations when we start to alter the natural state of produce. Keep it clean, covered, and in sanitizable containers, hand-washing, and temperature control, get involved at this level. Produce processor (potentially hazardous). Fruit pie, bread, jam, jelly, candy, pastry items have an additional level of interested regulators. We are now mixing, cooking, packaging, and labeling. All of these steps offer opportunities to harm the consumer.
Produce processor (hazardous). Now the Pennsylvania Department of Agriculture (PDA) insists we utilize a commercial kitchen to prepare our food products. Canned produce, soups, custards, pumpkin pies, and non-fruit pies (chicken pie as an example) require the additional food safety capacity available only through a commercial kitchen.
Eggs: If you produce less than 3,200 hens gets you fall under the PDA guidelines promoting local poultry production. Cleanliness, container and temperature control guidelines are the prominent features of this program.
Dairy: All milk and associated dairy products are regulated by PDA. There is a process for everything imaginable. Direct sales require specific permits depending on what you are doing. Bacteria testing, sanitation, equipment and facility cleaning, and quality raw milk strike me as the significant factors for this category of farm related food.
Your regional PDA personnel are also equipped to assist with any business under PDA sanctions. You will be looking for a “food sanitarian” or a “dairy sanitarian” depending.
Poultry: Poultry includes chicken, turkey, goose, and duck items. All product and product variations require the involvement of at least one regulator. Nothing can be done all-by-ourselves without having our system at least approved and verified as meaningfully usable to produce safe products for sale and consumption.
Meat: This category covers cattle, pigs, sheep and goat. All product and product variations require the involvement of at least one regulator. Nothing can be done all-by-ourselves without having our system at least approved and verified as meaningfully usable to produce safe products for sale and consumption.
Voluntary: There are many livestock/animal type items (such as bison, deer, rabbit, pigeon) that we produce and process for sale known as “voluntary”. These items have oversight assigned to PDA.
In addition to current and ever changing farm and food regulation – there are signs on the horizon of other guidelines we might want to be aware of: Good Ag Practices (GAP) are showing signs of significance in all PA farm and food activities. Worker hygiene is the primary theme here.
Remember, leaving the state with these products can have a profound effect on regulatory requirements. The rules before us depend intimately not only on farm location and processing type, but also which community houses our final to-the-consumer act. Little can be stated for certain, for very long, when it comes to rules. One item can. We are liable for our actions and inactions in the farm food business. Please seek council from an informed insurance representative, a legal professional and a useful accounting expert before getting very deep into many farm enterprises.
Thank you. I am also here to help. John Berry, Penn State Extension Educator.
Contacts: For produce, dairy, and eggs contact PDA, Bureau of food safety and laboratory services, http://www.agriculture.state.pa.us/. For poultry and meat contact a USDA, FSIS veterinarian at a local slaughter facility, or: Mr. Jan T. Behney, District Manager, U.S. Dept of Agriculture Phone: (215) 430-6301