Regulatory & permitting considerations
Regulatory and permitting considerations
· Applicable rules, regulations, and application processes
· Permitting considerations
· Mobile Processing Units
· Additional information
1. Applicable rules, regulations, and application processes:
· Before the facility can begin operation under USDA inspection, three written plans must be prepared (and approved by USDA):
§ SOP - Standard Operating Procedures (e.g., for Special Risk Materials).
§ SSOP - Sanitation Standard Operating Procedures (e.g., for facility cleaning activities).
§ HAACP- Hazard Analysis Critical Cotrol Point (a food safety program; pronounced "ha-sip").
·
USDA’s inspection activities (from http://pods.dasnr.okstate.edu/docushare/dsweb/Get/Document-1950/ANSI-3972web.pdf)§ “Inspection begins with the review of the plans for a slaughtering or processing plant. Plans for the facilities, equipment and procedures
must be approved to insure that the plant will have a safe and sanitary operation. The floor plans, water supply, waste disposal system,
lighting, and other parts of the plant must be approved either by the state inspection technical services office or the USDA Meat
Inspection Office.
§ The inspector conducts a pre-op inspection of the plant and equipment
before operations begin each day and continues this inspection throughout the day to see that sanitary conditions are maintained.
The inspector has the authority to stop the plant operation any time unsanitary conditions arise in a processing operation.
§ Inspection also checks the animals before slaughter to be sure they are not diseased. Any animal appearing sick undergoes a special
examination. No dead or dying animal can be brought into a slaughtering plant. After slaughter, each carcass and the internal organs
are examined for signs of disease or contamination that would make all or part of the carcass unfit as human food. In addition, government
inspectors regularly send tissue samples to their laboratories to determine the presences of illegal drug and chemical residues. If
illegal amounts of toxic residues are detected, the meat from that carcass is not permitted to enter the meat distribution system,
but will go to inedible rendering.”
· Applying for a federal Grant of Inspection for
Meat and for Inspection for Meat and Poultry Establishments:
§ An overview of
the steps required for obtaining federal meat inspection is available at: http://www.fsis.usda.gov/PPT/Applying_for_Grant_of_Inspection.ppt
§ Guam and CNMI fall under the jurisdiction of the Food Safety and Inspection Service regional office in
§ However, the primary point of contact for Guam/CNMI is
· An example of a SOP for Special Risk Materials (SRM) is available at: http://foodsafety.unl.edu/haccp/sop/BSE%20Slaughter%20SOP%20and%20Log.pdf
· An example of a SSOP plan and sanitation control records is available at: http://nsgd.gso.uri.edu/flsgp/flsgpe00001/flsgpe00001_part7.pdf
· A Hazard Analysis and Critical Control Point System (HACCP) plan must be developed and used by all USDA-inspected slaughter facilities, including small (less than 500 employees) and very small (less than 10 employees) operations. Refer to: http://www.meathaccp.wisc.edu/Model_Haccp_Plans/assets/pork/checklist_Slaughter.pdf andhttp://www.fsis.usda.gov/Science/hazard_analysis_&_pathogen_reduction/index.asp
A Generic HACCP Model for Pork Slaughter
· The Animal Health Protection and Disease Control Act was enacted in 1984 for the protection of animal and human health in the Commonwealth
of the
· Special Help from USDA for Small and Very Small Processing Plants
§ As defined in the
1996 Hazard Analysis and Critical Control Point (HACCP) regulations, "small" slaughter establishments have between 10 and 499 employees.
"Very small" slaughter establishments have fewer than 10 employees or less than $2.5 million in annual sales.
§ More than 90% of the 6,000 plants inspected by USDA's Food Safety and Inspection Service (FSIS) are small or very small. FSIS provides
a special website to help operators of small and very small meat, poultry and processed egg product facilities: http://www.fsis.usda.gov/Small_Very_Small_Plants/
· The role of USDA’s meat inspectors is described in this 4-page overview of “Meat Inspection and Grading” from
· The inspection and grading of meat and poultry are two separate programs within the U.S. Department of Agriculture (USDA). Inspection
for wholesomeness is mandatory and is paid for out of tax dollars. Grading for quality is voluntary, and the service is requested
and paid for by meat and poultry producers/processors. http://www.fsis.usda.gov/factsheets/inspection_&_grading/index.asp
2. Permitting considerations
· In addition to applicable permits for the slaughterhouse
operation, permits will be required for confined animal feeding operations providing livestock for the meat business.
· An overview of permitting requirements by CNMI DEQ can be found at: http://www.deq.gov.mp/article.aspx?secID=6&artID=32 ; relevant
excerpts from the home page include:
§ “This branch also responsible in reducing the
direct and indirect discharge of untreated animal waste to state water and groundwater through use of components and practices (such
as septic tanks, leach field, waste storage ponds, waste utilization, composting or other methods). A confined animal facility is
a lot or facility (other than an aquatic animal production facility) where the following conditions are met:
· Animals (other than aquatic animals) have been, are, or will be stabled or confined and fed or maintained for a total of 45 days or
more in any 12-month period, and
· Crops, vegetation forage growth, or post-harvest
residues are not sustained in the normal growing season over any portion of the lot or facility.
§ Facilities are requested to construct and operate an Other Wastewater Treatment System (OWTS) if they contain any of the following
number of head:
· 15 or more pigs
· 20 or more goats
· 10 or more cattle
· 100 or more chickens
· OR, any confined animal facility which had been found by the
Division of Environmental Quality (DEQ) to have caused, by evidence of direct or indirect discharge, in violation of the CNMI Water
Quality Standards or CNMI Drinking Water Regulations.
§ Large confined animal facilities
(more than 100 heads of pigs, 1000 chickens, or 50 cattle) may be required to meet more stringent requirements which is determined
on a case-by-case basis. Runoff includes any precipitation (rain or snow) that comes into contact with any manure, litter, or bedding.
Facility wastewater is water discharged in the operation of an animal facility as a result of any or all of the following: animal
or poultry watering; washing, cleaning, or flushing pens, barns, manure pits, or other animal facilities; washing or spray cooling
of animals; and dust control.”
3. Mobile Slaughtering Units
§ Mobile
slaughtering / processing units in use at several locations in the
§ Some of the mobile operations include on-going FSIS inspections, so the meat products
can be sold into commercial markets.
4. Additional information:
· Local Meat Processing information
§ A compilation of information regarding small meat processing facilities by ATTRA, the National Sustainable Agricultural Information
Service:
§ http://attra.ncat.org/newsletter/attranews_0910.html#story3
· Legal Issues for Poultry Processors
§ “Federal and State Inspection Requirements for
On-Farm Poultry Production and Processing”, by Dr Janie Hipp; December 2001; http://www.apppa.org/legalintro.pdf
§ Even though this article is focused on poultry, the report has relevance to small-scale red meat production in the
· “Overview of Aquaculture Environmental Permitting Issues in CNMI”
§ prepared by the
Center for Tropical and Subtropical Aquaculture,
§ http://www.ctsa.org/upload/publication/CNMI_Permitting_Overview632080439187139874.pdf
