The beautiful thing about social media is all of the wonderful people you will come across. If you pay attention these people will teach you all kinds of things. One of these people, who has taught me a lot, is Hal Kreher. When I need to know something about poultry, Hal is my go-to source. I asked him to guest post a couple months back, this is the finished product.
The other day it was suggested to me that farms need more regulation and oversight. In particular, large farms need more regulation (apparently small farms are of higher integrity just by being small).
I think that there is a knowledge gap that this person and many others fall into. Not only is the knowledge missing but often a value judgment is made based on this poor knowledge. Many people do not have the first hand knowledge of the subject, have not questioned someone directly involved, yet have already formed an opinion based on what little knowledge can be gained from one or two inflammatory articles. How unfortunate.
So I have decided to write what I hope to be an enlightening article on what really happens.
First a little background. My family has what most would consider a fairly large egg business. We have been fortunate and successful through a period of history where the number of egg producing companies in the US has decreased from 10,000 in the 1970’s to a few hundred left today. We achieved our success through perseverance, customer service, a great team of workers, luck, etc. We did not achieve success by cutting corners, ignoring safety, breaking the rules, intimidation, etc (although the assumption that you are big because you are bad seems to be made sometimes).
Most people do not understand that to supply a grocery chain – you have to have a certain sized business. Grocery chains do not want to have to deal with a different farm for each store. They want one supplier that can handle the business. Also it is not a good practice for one of your customers to be too large of a percentage of your sales because if something (like a bankruptcy) happens to that customer, you are in trouble. This, the advances and mechanization and automation of poultry husbandry and economies of scale are what led to where we are today.
So, getting back to the regulations – the following only pertains to egg farms. There are probably a whole bunch of other regulations that apply to broilers or pigs or dairy or beef or crops or vegetable/ fruit production.
Here is the list of audits that we have mostly on an annual basis:
FDA Food Facility Registration – registers our facility with the FDA so they know where we are, this was put into place by the Bioterrorism Act of 2002.
FDA Shell Egg Producer Registration – similar to above but particular to shell egg facilities (as opposed to Egg Breaking facilities)
FDA inspection – this is where they come out and walk through your facility and look through your paperwork (a two day visit per farm, minimum). What they are looking for here is that we are following the FDA Egg Safety Rule – this means that we have a Salmonella Program – we buy chicks that come from Salmonella free breeders, test the growing and laying houses at the appropriate times for Salmonella, have a biosecurity program (which includes limiting visitors – we are required by law to limit visitors!), and have an effective pest control system and are keeping the eggs properly refrigerated (at 45 deg). There is a lot of paperwork and training of personnel involved. This is a new program that started in 2010 for farms with over 50,000 and in 2012 will extend to farms with 3,000 or more hens (there are some exceptions, for farms that sell all their eggs directly to the consumer for example.)
You can find out the results of the inspections of all the egg farms in the US if you know where to look. All three of our farms passed with no problems.
NYSEQAP – this is the NY State Egg Quality Assurance Plan (we haven’t had an audit in a couple of years but are still following this program) – another paperwork audit to make sure you are following the program. Very similar to the FDA inspection and will probably be replaced by it. This voluntary program has been in place since the ‘90’s. Several states have similar programs. This program and a preceding HAACP program that we needed in order to supply McDonald’s (we were a supplier to them in the 1980’2 and 90’s) helped us to have very high quality standards in respect to production and packaging. One of the key things that happened on our farms during this was the elimination of rodents on the farm.
Eggland’s Best – a thorough facility inspection. Eggland’s Best has a very high expectation that the farms producing product for them produce the best quality possible. In addition to following the FDA Salmonella program, EB requires additional salmonella testing of incoming baby chicks and at the end of the flocks cycle. The inspector for EB is one of the pickiest persons that I know. He has a very critical eye and we really try to make it so that he doesn’t find anything to report. Our poultry care attendants and packing room folks work very hard to keep things in good shape and as clean as possible.
Kosher Certification – a visit by the Rabbi to make sure you are following those rules. Inspection is not very rigorous as eggs are basically Kosher, you just have to use the proper soap when washing them. He does not bless your eggs. Only certain labels pay to have this on their label.
UEP Animal Care – a paperwork audit (which means a review of the records kept in respect to daily inspection and monitoring of the hens) They also inspect buildings to make sure the cages have the correct number of hens. This program also requires animal care training. Hens are housed at 67 sq inches per hen. The cages contain 5 – 7 hens depending on the size and shape. The chickens are much calmer than you usually see on videos – bright lights and strangers can trigger the flight response – to view live video on a California farm go to HYPERLINK “http://www.jswest.com” www.jswest.com and view the “hens live tab”.
NYS Dept. of Ag & Markets (animal ID) – to make sure we properly report our chickens so the state knows who has chickens and where they are sourced and where they eventually end up.
American Humane Certification – of our organic farm – to make sure we follow their program. This is an incredibly detailed program that requires proper space allowance, drinker, feeder and nest space. There is an incredible amount of detail that has to be documented daily.
SQF – Safe Quality Foods – egg packing plant food quality program inspection. This extremely comprehensive program was billed as the audit that was supposed to replace all others. Well, it hasn’t done that (obviously) but it is an extremely detailed food safety program and inspection by a third party auditor. This inspection covers the packing plant, warehouse, and egg cooler, inside and out.
2 customer audits – inspection of our egg packing operations by QA people from the customer office. They do this to make sure that we are doing things properly to minimize their exposure to a food safety problem.
Quickfire Reg. # – Our SQF registration where we interact with the certification body and SQF.
iCiX (International Compliance Information Exchange) - a repository for audit reports and other certification documents where suppliers can obtain all your information from one secure spot. Auditing bodies post their results here so that we are not posting our own audit report (to prevent falsification of documents).
Organic Certification – Crops – one day paperwork and field inspections to make sure we are following the National Organic Program rules on our crop farm. There is a stack of paperwork about 8 inches deep because we have 2,800 acres in the program and most of the fields are not very large (I would say an average size field would be in the 20 – 30 acre range).
Organic certification – Egg Production – combined with handler – paperwork and egg farm inspection to make sure the chickens are being taken care of in accordance with NOP rules. This includes documenting ALL inputs.
Organic certification – Handler – paperwork inspection and check of our egg packing operation
CAFO – DEC – Concentrated Animal Feeding Operation – check of our environmental monitoring system to make sure our manure and waste water are being handled properly. This includes accounting for all manure (we sell 2/3 of our manure and use the other 1/3 on our crop operation). Required for farms with over 37,500 laying hens if using a dry manure handling system. A farm is a large CAFO if it has over 80,000 laying hens.
Petroleum Bulk Storage – we have some fuel stored on the farm and this is an audit of the tanks where they make sure we are inspecting them and watching for leakage/spills. Any spill over 5 gallons must be reported to the DEC. I don’t know when the last time we had a spill like that on our home farm, if we have ever had one.
This is just a portion of the regulations that we fall under. For instance there is a lot of regulation with respect to grading of the eggs that I did not get into (both state and federal). We produce fertilizer so we have recently had to get a fertilizer blender license (if it was just the product we make from our own manure we would be exempt but we bring in some other ingredients to supply blends that our customers want). There are trucking regulations on our delivery and grain trucks. There are regulations on employing other people (tons of rules! And a lot of reporting/tax filing). Regulations on grain storage, purchasing, etc. Regulations on our Feed Mill. OSHA Regultions. I wonder what I am leaving out…
So, still think we are under- regulated??
You can e-mail Hal at firstname.lastname@example.org