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market-farming - Re: [Market-farming] Commercial Kitchen

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  • From: Robert Farr <rbfarr AT erols.com>
  • To: Market Farming <market-farming AT lists.ibiblio.org>
  • Subject: Re: [Market-farming] Commercial Kitchen
  • Date: Tue, 16 Dec 2003 08:53:33 -0500

Lucy may be right about baked goods not being regulated in Ohio, but
anything put in a jar as a "shelf stable" food is most definitely
regulated, either by a local health authority or by the FDA. Again,
refer to the FDA's Center for Food Safety & Nutrition web site:
http://www.cfsan.fda.gov

You must be most careful about packaging a food for sale that might make
someone sick - i.e., create botulins (the organisms that cause
botulism). And as a food professional, I can tell you - this is a very
serious issue.

In order to pack our Chile Man sauces and salsas, we had to take a
certification class from a USDA-approved school (the Better Process
Control School), get inspected by the Virginia Dept. of Agriculture (and
are inspected by VDACs at least once each year), register with the FDA,
file production and product processes and certifications with the FDA
(after having each recipe tested and approved by a Process Authority -
in our case, Virginia Tech), be inspected by the FDA, and submit to
random inspections by the FDA.

Note that some of these certifcations are not required for *all*
products. For example, many jams and jellies (and honey) are not
FDA-regulated items (but you should have all items tested by a food
science authority, at the very least to mitigate liability). But it is
true for most packaged, shelf-stable foods.

Note, also, that many refrigerated items - i.e, those not meant to sit
safely outside of the refrigerator ("shelf stable") - are not regulated
by the FDA, but are regulated by Federal Good Manufacturing Practice
standards (GMPs), many of which involve common-sense cleanliness, but
some of which offer details of food-processing work-spaces (one
example: aisles and pathways must be clear to offer easy inspection of
pest problems. Another: your refrigerator must have a thermometer
inside to monitor that the temp. is below 45 degrees. These are true
not only for factories but for home-based facilities.)

States have additional requirements. In Virginia, for example, one must
have two separate kitchens and separate utensils. And there are rules
for food handling outside of the kitchen. In Michigan, no sampling of
products may be offered at farm markets (I believe extension may fine
the farmer $500 - ridiculous (really!), but true).

To be safe, to keep your customers safe (and to avoid the problems of
litigation), you need to read and follow the instructions on the CFSAN
site.

I'm certainly no government apologist - government regulations are in
large part responsible for the decline of the American farmer,
especially when they are mis-applied, often in the support and
protection of agri-business. (BTW, for lots of good info on how unfair
many of these regulations are, read Joel Salatin's columns in Acres USA,
and look for his book coming out next year (?), "Everthing I Want to Do
Is Illegal (or something like that!)".) But, even as we fight against
them, and especially with the increased oversight of the food system in
the wake of 9-11, there is a real responsibility to know the rules and
to comply with them, or run the risk of penalization, of multiple kinds.

If that's not enough, consider this: even Sun Tzu preached the art of
knowing the "other side"! I leave you with lots of libertarian thought
here, but also with the firm suggestion of protection and practicality -

--
Robert Farr
The Chile Man
(540) 668-7160

* A sustainable farm producing hot sauce marinades, salsas, mustards,
and barbecue.
* Subscribe to our online newsletter at http://www.thechileman.com
* Check out this article about us from The Washington Post:
http://www.washingtonpost.com/wp-dyn/style/food/A8659-2001Jul17.html
* Open Houses and Farm Tours throughout the year. See our web site for
details!






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