On-farm Poultry Processing at Healthy Hen Farms

by John McAuley, Healthy Hen Farms
photos provided by Healthy Hen Farms

Editor’s note: CFSA member John McAuley shares his experience going through the on-farm poultry processing inspection to help other NC farmers who intend to do the same.  If you have questions about your particular situation, please contact NCDA – the definitive experts on requirements!

Things have changed a lot in the last 20 years regarding the raising of poultry!  Back in 1996, I left NC State and my wife left Meredith College to pursue a dream.  We moved from Raleigh to a small town called Swoope, VA, nestled in the Shenandoah Valley.  The guy who introduced my wife and me ended up being Joel Salatin’s first apprentice, and he somehow convinced us to quit college and do the same.  We spent 6 months on Polyface before many people knew anything about pastured poultry and then started our own farm in Youngsville, NC, where we raised about 5000 birds for the next two years.

As you know, life has a way of throwing curve balls to throw you off course.  For us, it was the allure of a career in technology with great paying jobs.  I could work a lot less, make a lot more, and this would make us happy.  For the past 15 years we’ve moved all over the country from NC to CA to GA and back.  Both Betsie and I always dreamed about farming again and as the interest continued to build in local food systems, we always felt bad that we gave up on our farming dreams.

Mid-way through 2013, we decided to give this one more shot.  With 5 kids now in tow, we purchased an old 50-acre dairy farm near Oxford, NC, with a lot of potential. We set off to once again take all the things we learned from Joel and apply them on this farm, in hopes of sustaining ourselves and our customers through the production of wholesome, organic, local, great tasting food.

Joel used to always tell me to start out by picking one thing and doing it really well.  Become an expert and let that system drive and fund everything else you think you want to do.  Knowing pastured poultry and having run that operation previously, it was a logical choice for us.

As we began to ramp up our operation, one of the biggest questions was whether we were going to again do on-farm processing or outsource it.  Your options are few and far between if you want to outsource.  Many farmers know this all too well with the recent announcement about the Chaudhry poultry plant, and they are scrambling to figure out what to do with their chickens.  I spoke to them back in the fall and even at the prices charged, it was obvious that he wasn’t getting enough volume to make it profitable.  They seemed like great folks, but I didn’t want to end up with birds on pasture if or when they decided to close.  We decided to process on-farm again.

As I began to plan our operations and facility, I tried to figure out the regulations.  There was very little information that would help you gain approval for on-farm poultry processing.  It has taken several long paragraphs to get here, but this is the purpose for this article – to share my experience with others who I know have the same questions about what it means to process poultry under the exemptions.  In the end, we were approved to process up to 20,000 birds per year on the farm, and here are the top 10 things we learned.

1. Read the actual exemptions.  There are two exemptions that will interest most small farms.  The 1000 bird exemption is covered in Meat & Poultry Inspection Division (MPID) notice 14-12.  Read it here.  The 20,000 bird exemption is covered in MPID notice 15-12, and requirements are here.  There doesn’t seem to be much difference and it’s hard to decipher what they are aiming for with the tighter restrictions under the 20,000 bird exemption.  According to the NCDA Compliance Officer we dealt with, the main difference is that with the larger exemption you need to own the equipment and it can’t be rented or shared among multiple farmers.

2. Register your operation. There is a significant omission in both exemptions – you can’t simply read the exemptions, decide which one is right for you, start following every letter of the law, and be on your merry way.  You actually have to register your operation with the NC Meat and Poultry Inspection Division.  I found this out by trying to get our farm listed on the NC Farm Fresh website.  They approved my listing with the stipulation that I register with MPID.  For the record, I communicated this to our NCDA officer.  He brought it up internally and said they would work on fixing that.  I suspect there are at least a handful of farms thinking they are processing under exemption, but in fact are not due to this omission.

3. Schedule an inspection by the MPID.  Once you declare that you want to process under exemption, your NCDA compliance officer will set up an appointment.  This is a no cost inspection, and it was actually very beneficial to our farm.  Our inspector had several suggestions that weren’t requirements, but had the potential to make our operation much more efficient.  We found our inspection to be enjoyable and genuinely felt like the NCDA was on the small farmer’s side, trying to help however they could.

4. Study guidelines and best practices to prepare for your inspection. Good luck! Finding these was really like finding a needle in a haystack.  I could not find a single document, article, or notice that told me what I could do to prepare or what to expect.  It turns out there are a lot of assumed practices and some that the NCDA says are requirements but they sure aren’t documented in the exemptions.  For starters, I would highly recommend reading this publication by Oregon State University.  It is meant for their small farm producers, but it is by far the best document I’ve found that covers general best practices for each stage of processing.  Another good resource, put out by our own NC Choices, covers good practices for safe handling, which is a lot of what the NCDA is looking at of course.  It can be found here.

5. If you’re selling birds, you really must register. There are a lot of people, including some farmers who process on their farms, who will tell you that as long as you don’t process over 1000 birds a year you don’t have to let the NCDA know, and they don’t have a right to inspect.  In the eyes of the NCDA, those people are wrong.  Our officer told us that if you sell a single bird, you are required to register under one of the exemptions.  If you don’t, you could subject yourself to significant penalties.  I understand people have different views about what the government should be controlling, but this is our law as it is today. Honestly, we did not feel intimidated in the least bit by this process.  We would have liked more information, but we figured it out.  As I said before, we actually learned a lot that helped make us better.

6. Standard label, no claims. During inspection, your officer will want to see your label that has your name, address, exemption notification, and safe handling instructions.  We had printed 5000 full-color vinyl labels with all the required information.  However, we also added, “In addition to fresh pasture, our birds are only fed 100% certified organic, soy-free, non-GMO feed.”  We were not claiming that our farm or birds were certified organic.  We simply stated what we feed our birds.  Our inspector thought that because we were just stating what we feed our birds, it would be ok.  However, after running it through chain of command, they said no.  I’m not sure what the theory is behind this.  It does not bring integrity to the local food movement.  Getting to know our customers and establishing the relationships between farmer and consumer brings integrity.  My customers can come out any time to look at what I’m feeding the birds, how I’m treating them, and even the respect we show the birds throughout the processing.  If I took my birds to an NCDA-inspected facility, I could put that label on them even though nobody validates those claims.  Why burden the small producer with a limitation that says he can’t put any information about his birds on the package like the big guys do?  This one I do not get, but it is an easy fix.  Standard label.  No claims.  Make all the claims you want directly to your customer as you shake their hand and thank them for their business.  They’ll be back.

7. Document your operation.  I used my technology background and put together a Standard Operating Procedure (SOP) for my farm.  I cover every detail of processing from three days before processing through packaging and customer handoff.  This was helpful as I was able to articulate and organize the mountain of information I gathered on best practices.  It also gave me a nice reference document to hand to friends/employees/family/whoever-we-can-get to help us on processing days.  Having everything documented allows you to demonstrate to the NCDA that you are familiar with best practices, safe handling, and proper techniques to produce a quality product right there on your farm.  You can’t lose by taking the time to do this, and I can’t overstate the importance.

8. Monitor operations and log the results.  This should be covered in the SOP guide.  Make sure you recognize what should be monitored and put a system in place to capture the results.  Daily temperature checks on your freezers and refrigerators.  Regular chill tank temperature checks on processing days.  Internal bird temperature checks as they cool down.  How often your equipment gets clean and sanitized.  You get the idea.  These things can and should be monitored, and it is easy to set a clipboard in various areas to check and document.  This will also demonstrate the integrity of your operation because you’re doing the right things when no one is watching and you are keeping proof.

9. Read everything you can about safe handling and safe poultry processing recommendations.  Know that the recommended sanitizer is a 200 parts per million (ppm) bleach solution, which is made up of 1 tablespoon of food-grade bleach per gallon of water.  Know that most agencies recommend a bleach-based, anti-microbial spray before the birds go into the chill tanks.  If you are like us and don’t want to use bleach on your birds, it’s ok to use a 2.5% acetic acid spray, which is a 50/50 mix of distilled white vinegar and water.  Look folks, no one wants to get anyone sick.  As a small, quality-focused producer, chances are you have a far superior product leading up to processing.  You are hand eviscerating on the farm, which can mean a higher quality finished product because you can take more time and care not to spill feces on your carcasses.  You don’t want to bring a high quality product into your processing facility only to screw it up because you didn’t practice basic sanitary guidelines.  Know this stuff and be prepared to walk your inspector through it, telling him why you do what you do.  He will appreciate it.

10. Look professional.  This can’t be overstated.  I spent a lot of time at restaurant auctions trying to find used equipment that worked for us.  I put in a drainage system that allowed us to keep our viscera for composting, while taking all the water away from the processing facility so we didn’t have standing poultry water.  We got the vinyl warehouse separators that you can pick up through U-Line so we could separate our clean from dirty areas without having to build walls.  We installed food grade hose anywhere a water hose would be used.  We converted the old milking parlor to our processing facility – a great way to bring that building back to life.  It looks nice, and we are proud to show our customers and partners.  It also looks great to your NCDA inspector.  People can tell when you went above and beyond the bare minimums.  It goes a long way in presenting a professional image of your farm.

There are some things we didn’t do 20 years ago because we didn’t know about them; the anti-microbial spray is a great example.  That one small step cuts down significantly on potential pathogens that could be harmful to your customers.  I feel like we produce a much safer product than we would otherwise.  Would we have sought out all of these details had we not had NCDA coming to visit the farm?  If I answer honestly, I’d say probably not.  I did this 20 years ago and it worked just fine then.  I’ll do the same thing now, right?

In reality, we’ve learned a lot in that 20 years that can help small farmers continue to produce quality products that are sustainable for their farms, their customers, and our environment.  It’s simply a matter of seeking out that information – sometimes it may be better to be pushed from behind to make that happen.  We’d be glad to help others in finding out more information for their own farms.

In the end, we felt good about the whole process.  We learned a lot through it.  We were able to give honest, constructive feedback to the NCDA and felt that they wanted to help fix the issues.  And finally, we felt like it brought a level of integrity to our operation.

To learn more about Healthy Hen Farms – including production practices, where to find their products and how to join their mailing list, please visit their website: http://www.healthyhenfarms.com/