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Showing posts with label exemption. Show all posts
Showing posts with label exemption. Show all posts

Tuesday, March 10, 2015

Homegrown Ontario

Local food is becoming a hot topic.  Ontario has its Local Food Act, and is slowly adjusting local (ie. Ontario grown) food preferences for all public institutions in Ontario.

Leading the way, Ontario Pork Producers’ Marketing Board (OPPMB), the Ontario Veal Association (OVA) and the Ontario Sheep Marketing Agency (OSMA) came together to form Homegrown Ontario in 2006.  OIPP gives a detailed account, and is now the owner of this important trademark.  Unfortunately, I haven't seem too many of these logos at retail meat counters.

In 2005, spouses Smith & MacKinnon started to exclusively eat foods that were grown or harvested from within a 100 mile radius of their home. It was a challenge, and they shared stories about their adventures with family and friends.  This lead to a few magazine articles, which lead to the book 100 Mile Diet in 2007, then a documentary film.

"Local Food" is a complex issue with no clear definition accepted by all.  Most stakeholders seem to include:


  • DTC (Direct to Consumer), where the farmer sells food directly to a member of the household that will be cooking and eating the food.
  • CSA (Community Supported Agriculture), where one or more people will "hire" a farmer to grow specified foods for them, often paying in advance, and the consumer shares (or fully owns) the risk & benefits of bountiful harvests, or crop failure.
  • FM (Farmer's Markets), where farmers gather at proximate locations on a semi-regular basis (eg. every Saturday) to sell their crops to interested buyers (personal, business, wholesale, etc.).


CFIA has adopted the interim policy that "Local Food" is:
  • food produced in the province or territory in which it is sold, or
  • food sold across provincial borders within 50 km of the originating province or territory
The inter-provincial "local food" would seem to assume a 50 km radius on each side of the provincial border, for a total diameter of 100 km centered on the provincial border,  This would allow settlements near provincial borders to continue inter-provincial economic ties, including "Local Food".

Ontario has adopted the definition that "Local" is food raised, grown, or produced within Ontario.

A big name consultant did up a report for Ontario on best practices for local food, directed at municipalities.  Is your municipality on board?  If no, why not?  What are you going to do to help get them there, and keep them there?

USDA's Economic Research Service has a nice detailed report on local & regional food in the USA.

Small Flockers support these definitions and initiatives.

We believe that poultry can and should be grown "locally", as in a neighbourhood.  Backyard chickens meet this definition.

The challenge will be access to the necessary infrastructure.  Requiring a backyard chicken farmer to ship his 4 chickens half way across the Province so that he can get a OMAFRA approved slaughter just doesn't make sense.

We have suggested mobile abattoirs that seem feasible in all aspects.

Long term, there seems to be a need for relaxed regulations that allow backyard chicken owners to kill their own birds on their own property (or perhaps at some shared community site), provided they have limited quantities of production, it is done with full disclosure to those receiving &/or eating the birds, and they follow a standard, pre-approved slaughter process.

This could be achieved by one or more of the following choices:


  • Backyard chicken grower ("BCG") visits OMAFRA site, does on-line course, passes comprehension test, and becomes certified on standard OMAFRA process for slaughtering birds.  Local health unit receives a copy of the new certification so they can do inspections as required.
  • BCG clicks on link from OMAFRA's site to suppliers who sell standard kits of equipment and materials needed for slaughtering equipment, makes selection, and purchases.
  • BCG uses pre-approved slaughter process, self-tags resulting chickens for traceability.
  • If BCG desires, they can develop their own slaughter process, have it reviewed & approved by OMAFRA, who may require micobiology testing, or on-site witnessing and approval by OMAFRA, and possibly additional terms, conditions, or restrictions.
If anybody knows any reasons why this couldn't be made to work, I ask them to post their ideas here so we can discuss tem fully.


Friday, January 10, 2014

Aaron's Eggs Day in Court

I previously Blogged about a rebellious, but soft spoken small flock egg farmer in Nova Scotia who is in the gun sight cross hairs of the #ChickenMafia and their henchmen, the notorious #ChickenPolice (see Aaron's Eggs.

I subsequently wrote how SFPFC and thousands of NS citizens intervened on Aaron's behalf, so the Nova Scotia government decided to intervene, and finally the NS Egg Board relented by doubling the small flock exemption (100 birds to 200), and proposed an auction of 2,000 bird quota for small flockers, to be divided in 4 lots of 500 birds each.  If Aaron applied and was lucky enough to win, we would have an exemption for 700 birds, so he could keep his present flock of 700 (see Give Credit where Credit Due.

I received a call from Aaron today, saying the #ChickenPolice continued with their charges against Aaron, and he recently spent his first day in arraignment court pleading Not Guilty to all charges.  Aaron said he considered the ease and speed of pleading guilty, but he just couldn't do it.

I had previously offered all of SFPFC's legal research to Aaron in preparation for our Ontario rebellion against the #ChickenMafia.  WIthin a few minutes, I had an email off to Aaron, but the email server choked on the 38 MB of file attachment. Doing a compressed zip file wasn't much better.  I'm going to have to upload all these precious files to a Internet Cloud File Server, so Aaron can download everything.  I hope Aaron's Pro Bono lawyer finds it useful.

While I had Aaron on the phone, we quickly discussed strategy.  His parting remarks were that he obviously needed to learn a lot more, really quicky.

Indeed he does.  Just like Wiley E. Coyote, those #ChickenPolice are a nefarious bunch.  The advantage for the #ChickenPolice, they have the government to do their dirty work for them

Once the offense notice has been issued by the #ChickenPolice so as to protect their monopoly, the government steps in and takes over.  The power of the state and their bottomless pockets are now against Aaron, while the #ChickenPolice can sit back, relaxing in their front row seats while the brash Crown Attorney attempts to sink Aaron and his young small family on their family farm.

There ought'a be a law.


Tuesday, January 7, 2014

Connecticut Can, Why not Ontario?

Small flock poultry farmers in Connecticut ("CT") USA can now do on-farm slaughter and sell these birds at retail sales, such as farmer's markets, household consumers, restaurants, hotels, and boarding houses.

Somehow, the US system evolved so that there are neither State nor Federal inspected poultry processing plants in Connecticut.  That sad fact has hindered all Connecticut poultry farmers, both big and small, for some time, because the CT poultry was not an "approved food source".  That meant individuals could purchase their poultry meats for home consumption, but you couldn't sell them at retail, and they couldn't be used in restaurants and other food service establishments.

The Connecticut Public Act 10-103 "AN ACT CONCERNING FARMS, FOOD AND JOBS".  Now isn't that a novel twist.  Politicians who actually understand that local food production helps farms, and creates jobs.

Further on in the announcement, the Connecticut government states, "More and more consumers are demanding foods they perceive as more sustainable and local."  It is clearly evident again, that Connecticut politicians and bureaucrats are listening to their people.  Why or why do we have so many deaf and dumb politicians in Canada?  In Canada, they can't hear (or don't want to hear) what the people are saying, and they refuse to speak up on behalf of Canadians.

This Connecticut law includes "... livestock food products, including meat, milk, cheese and other dairy products..." and just about all other farm products of Connecticut, and baked goods derived from those Connecticut products.

For example, canning of farm produce can be done on-farm without public health inspection, provided the farmer has passed a safe food handling and/or safe food processing course, the farm house water used is fit to drink, the canning area is restricted during the canning process, and each container is labelled "Not prepared in a government inspected kitchen".

Small flock poultry operations are defined as farms that raise up to 5,000 turkey or 20,000 poultry of all species per year.  That certainly contrasts with Ontario, as well as every other province & territory in Canada where the mighty #ChickenMafia have a death grip on the throats of every Canadian; buy from the #ChickenMafia or die!

In Connecticut, if a small flock farmer wants to slaughter his own birds on-farm, then the Connecticut Department of Agriculture will inspect the on-farm slaughter facilities to the "Poultry Products Inspection Act ["PPIA"] and any applicable provision of the Code of Federal Regulations, including, but not limited to, any health, sanitary and safety related provision."

The Connecticut notice  states that:
"Participating facilities must have an approved plan for the disposal of liquid waste and an approved plan for the disposal of offal. The processor must have an approved water supply and test the water supply every six months, or, if operated seasonally, test the water supply no more than 30 days prior to the date processing starts. (Required water testing is not applicable to municipal water supplies.) Participants also must have an approved site bio-security protocol and have a written system of product labeling and record keeping facilitating product tracking and trace-back to the slaughter/process facility."
Seems like reasonable requirements to avoid complaints from neighbours, and from creating a food health hazard.

If you pass the State inspection, and you meet the exemptions from continuous USDA inspections during slaughter (per PPIA) , then your slaughter operation "shall be designated as approved food sources for household consumers, restaurants, hotels, and boarding houses."

That "approved food source" designation means no hassles from Public Health Inspectors who happen to see some of these products downstream in the food chain (eg. store shelves, restaurants, etc.).

The Connecticut note also states:

"The inspection follows the requirements of the PPIA, including an audit of the HACCP system and an evaluation of the sanitation, sanitary practices, food-handling equipment design and construction, handling of animals, record-keeping, and water supply."
OK, so you're a farmer raising poultry, and slaughtered your own birds for decades.  However, you're not familiar with government documents, or never heard of HACCP?

Again, no problem!  Connecticut has got you covered.  The State Ag Extension Office offers a safe poultry slaughter course to assist producers with designing and implementing a Hazard Analysis Critical Control Point (HACCP) system. A HACCP system is required under the PPIA and the Connecticut Small Poultry Processor Inspection Program.

Just to be sure that all State bureaucrats fully understand, the notice states: "Sales of poultry directly to the final consumer at the farm or at a farmer’s market via order are not affected by this program. Those producers who market directly to the final consumer are able to continue this practice."

What if a Connecticut farmer is too small or can't afford to run his own slaughter operation?

No problem!  Connecticut has thought of everything.

Connecticut is funding the designing and building a mobile poultry processing plant on wheels (ie. a highway transport trailer specially converted to a poultry abattoir) by the Connecticut Poultry Association ("CPA").  The CPA will identify two sites, one at the East and one at the West of Connecticut, where this mobile slaughter plant can be parked, and hooked up to local electrical and water supply.  The farmers bring their birds to this mobile site, the birds are processed, and the farmers return home with their birds ready for sale at their farm gate, Farmer's Markets, or at retail.

No fuss, no muss.

Even under-serviced areas and remote farms can get easily serviced by a poultry abattoir in CT.

Figure1:  Comparison of Connecticut USA to Ontario Canada
Is there a fair comparison between Connecticut and Ontario?  Let's see.

Ontario is about 64 times bigger on sq. km. basis that Connecticut ("CT"), and the dimensions are about 10.9 times greater on a geometric average of length and width.

On population, Ontario is 3.6 times bigger than CT.  However, population density of CT is 20.4 times bigger than ON.

With two mobile abattoir sites strategically located in CT, the farthest a farmer would have to drive would be 70 km., which seems reasonable.

Assuming the same sq. km per mobile site for Ontario, we would need 128 mobile site locations scattered throughout Ontario.

Assuming that the mobile abattoir crew would do all birds at a site in one day, a second day to clean up, and a third day on the road to travel to the next site & set up there, that is a 3 day cycle per site.

If farmers are doing the typical quota-based 6.5 poultry grow cycles per year, they will need the mobile abattoir to come by their area for each of those poultry grow cycles.  Therefore there are 6.5 cycles per year x 128 sites x 3 days/site= 2,496 days of work to be done in all of Ontario.  Assuming 350 work days per year for each mobile abattoir, we would therefore need 7 mobile abattoirs trailers for serving all of Ontario.

On a population basis, CT has one mobile abattoir for every 1.8 million people.  For a similar ratio, ON would need 7 mobile abattoirs to serve our 12.8 million population in Ontario.  Interesting that we get the same answer, no matter which way we calculate it!

So 7 mobile abattoirs for Ontario will do the trick.

Well, Premier Wynne, how soon do we get the Ontario Meat Regs. modified so it matches CT's new law?

When will OMAF's RED Rural Economic Development cheque for the 7 abattoir trailers be presented to newly formed regional CO-Op's who will be offered first opportunity to run these 7 mobile abattoirs?

How about putting out a RED Request for Proposals where any group can apply for a defined geographical region based on Census Divisions ("CD") and population with those chosen CD's which totals at least 5,000 sq. km. that they would service.

I suggest the following deal between OMAF and these 7 Co-Ops to be formed for managing the 7 abattoir trailers:
  • OMAF will pay for the trailer plus some startup funding and personnel training for each regional trailer and all of the 18 or so sites that each trailer will service.
     
  • In return, OMAF will get a share of the top-line gross revenue per bird processed until OMAF's costs are re-paid.
     
  • After that, the Co-op that runs each trailer is on their own.
     
  • If the Co-OP goes bankrupt, or fail to serve the area as promised, the trailer gets returned to OMAF, and a new RED Request for Proposal is advertised for that same CD district.
OMAF helps it get started, but it isn't a hand-out.

It's giving the farmers and the people of Ontario a temporary hand up.

I have already contacted the CT Poultry Association, asking for info on their mobile abattoir design.  I'll send you a copy when I get it, Premier Wynne.  Anything to help, eh?

*  *  *
P.S. A dip of the chicken wing to Dave & Brenda Linton who forwarded me the link to this interesting news item about the new law in Connecticut.  Thanks

We welcome all similar news items, rumors that need debunking, accolades, complaints, questions, etc. We're not proud, we'll take everything we can get.




Wednesday, July 3, 2013

If the US can, why can't Canada?

Small Flockers have proposed that poultry farmers be allowed to offer self-inspected, farm-slaughtered poultry at the farm gate to willing consumers, provided the farmer gives full disclosure to each customer.

When I explain this to people, some screw up their face, wince, or look at me in disbelief.  "It'll never fly!", they say, or "Where did you get a crazy idea like that?", or "Who would buy that when they can get inspected chicken in every grocery store?", or "That would kill all of our export markets, as international markets would be worried they were being shipped some of that un-inspected meat".

Admittedly, it's not for everyone.  If someone prefers what the commercial chicken factories have for sale, so be it.  However, why does this group feel a need to force their choice onto everybody else.

You may like chocolate ice cream.  You may like it so well that it's your favorite dessert. However, should you be listened to if you try to ban strawberry, vanilla, and the other thousands of flavours in favor of chocolate?  How fair would that be?  Why can't everybody be left to make up their own minds?  Of course, if any of these ice creams are unsafe, or use deceptive advertising, no matter what flavour, then the consumer should be protected, and the fraudster prosecuted.

There is precedence for this "crazy idea" of self-inspected poultry.

Pennsylvania State University describes the 1,000 bird limit for Poultry Product Inspection Act (PPIA), where we find:
"...there are limited provisions for poultry growers who slaughter no more than 1,000 poultry in a calendar year for use as human food. A person may slaughter and process on his or her premises poultry that he or she raised and they may distribute such poultry without mandatory inspection when the following six criteria are met [PPIA Section 464(c)(4) “Section 15 (c)(4)”; Title 9 CFR §381.10(c)].

Criteria:
1. The poultry grower slaughters no more than 1,000 healthy birds of his or her own raising in a calendar year for distribution as human food.

2. The poultry grower does not engage in buying or selling poultry products other than those produced from poultry raised on his or her own farm.

3. The slaughter and processing are conducted under sanitary standards, practices, and procedures that produce poultry prod-ucts that are sound, clean and fit for human food (not adulterated).

4. The producer keeps records necessary for the effective enforcement of the Act [Title 9 CFR 381.175].

5. The poultry products do not move in commerce.   Note: Commerce means the exchange or transportation of poultry products between States, U.S. territories (Guam, Virgin Island of the United States, and American Samoa), and the District of Columbia [PPIA Section 453; Title 9CFR §381.1(b)].

6. The shipping containers bear:
a. the producer’s name,
b. the producer’s address, and
c. the statement, "Exempt P.L. 90-492".
There is a similar exemption for farmers who want to do up to 20,000 birds per year, provided it's only for sale within the farmer's own State.


So if the US can do it, why not Canada?