>From: "P. Armstrong" <[log in to unmask]>
>Date: Wed, 25 Oct 1995 16:08:09 +0000
>Subject: Regulations requiring food processing license
>Do any of you know of regulations requiring a food preperation
>license requirement in other states? Here in New Mexico we are
>facing such a requirement. If anyone has any info on how we can
>scientifically, or otherwise, put up an argument that has worked
>elsewhere we would sure appreciate your help. We are having a
>meeting on Oct 31 to fight against this. Thanks. Nick Melancon
>New Mexico Bee Keepers Assoc.
Good Luck Nick, but it will take some work to kill such regulation
if it is well sponsored like by the state health department or some
organization. (It may also be someone within your own group that is
after his competition, you need to know.)
I don't know of any regulations requiring on farm honey processing
plants to be regulated as a "food preparation" site like say a Taco
Bell or even a Mexican tortilla factory . Realistic inspection's that
would include beekeeper's honey processing plants will take away from
the little inspection that is now going on in other areas. (Find out how
many time's the greasy spoon's in your town are being inspected. You may
be surprised that they are only checked once a year or less or if
someone complains enough, more often. Also find out the number of
reported illness from your state health department.)
To defeat this kind of legislation the first thing you have to do
is find out who is pushing it and why. If it is just another plan
to increase your taxes you many have a better shot at killing it
then if it's in response to people becoming ill or just concerned
because they found some bee part's in some honey they were given
by their neighbor who has some bee's. Or if there is some beekeeper
who is a neighborhood nuisance because bee's are robbing honey drums
or some other dumb stunt beekeeper's are know to pull.
Honey extraction is a specialized "on farm" or back yard seasonal event
and does not warrant the same degree of on site inspection as other
"food preparation" sites. The cost of such activity is high because of
the seasonal nature and isolation of these operations and would not be
covered by normal or reasonable licence fee's and would add to the
budget for inspection already mandated or reduce valuable man day's from
that important job. The number of complaint's of illness or food
poisoning from eating Honey processed on the farm does not exist and in
total is the lowest of all farm processed foods. In many medium to
larger operation's honey produced on the farm is further processed by
the first handler where inspection is mandatory, both local and federal.
Honey produced by producers who use the Farm Loan Program is covered by
USDA specialized Honey Inspections to qualify for government programs
and is inspected.
(check with your state health department to see what is going on if
anything, also find out who is pushing for the new legislation. You may
find some group or person that has a hard on for beekeeper's or just
some nut who think's all farmers should be regulated to the hilt since
you we all get so much help (cash) from the government.)
Today 99% of the time you are just facing a plan to increase government
income and not any realistic effort to clean up the honey producing
industry. (Find out what your state beekeeper's are already paying in
county and state taxes for being beekeepers.)
Most state legislator's will listen to beekeeper's, we are rare birds
and a interesting lot. Bee sure you have a small group of beekeepers who
are prepared to discuss the issue and have a FIRM position that they
are not afraid to "say it the way they see it". Ask to testify at
any public hearing and do that. Ask for more public hearings, make a
record to back your own position. Do not compromise your own position
leave that to the politicians they will do it to you anyway and any
weakening of your position will be taken advantage of.
Having some political sense can be very helpful, find out which side
is pushing the bill and what the leadership position is on it. You must
meet with member of both sides, but suck up to the one that is not
sponsoring it and if God is watching out for you they will be the
majority party and more then willing to help you kill any plan for
new laws. Legal help from one of the capital lawyers can be helpful but
will not get it done. They can open doors, and show you the process but
unless there are some big bucks involved you all are going to have to do
the work. Meet one on one with your own representatives. Get the support
of other farm group's, but do NOT let them carry your ball or you may
find you have one less.
Now if the honey producer's in your state contain more then a few people
who still extract in tent's or in old barn's with dirt floors you may
not want to do anything and let nature .err government take it tole.
Two states I have worked in have made different run's on cleaning up
the beekeeper's and normally these last one season and that's the last
you hear of them for years or never.Beekeeper's have cleaned up over the
years from what it once was, which was satisfactory at the time, but
is not today. Some of this was good and needed, but one thing that was
done that was bad was a crack down by the USDA that finished off the
portable and out yard extracting. I believe that if we were still doing
it it the field today we would be producing more for less and not have
the problems with our bee's we do have today. I also think we would be
doing it a van that would be just as clean as any permanent site, but
those day's are gone and I don't think that is your problem.
Over the year's my honey house has been targeted for inspection by
every government agency there is. Some of this has benefited me and
some of it has been enough to cause any beekeeper to brake up and
roll on the floor. California several time's has got a wild hair to
inspect honey extracting plants. One such visit came when I was out of
state. At the time I had just installed the top of the line extracting
equipment, I was on the cutting edge then, not the bleeding one like
now. This included a wonderful flash heater and centrifuge that
separated out the honey and melted the wax. Had to add a new 200 amp
service for that one. This machine was the early stage of development of
the Cook & Beals Separator. Anyway the first tizzy the inspector pulled
was when he saw the lifelike rubber plucked chicken that hung over the
fancy imported Penrose uncapping machine. "You can't do that in here,
you need to get a different licence to do both chicken's and honey in
the same place." God's truth, he really believed that we were plucking
chicken's with the same machine we uncapped honey combs so my long time
help told me. This guy was so shook up he did not notice that at the
time all the honey from the two big Kelley extractors and the
cappings drained into a very large sump and that sump was covered by
boards that the man who loaded the extractor stood on, not a very good
set up that I changed the next season without any input from any
inspector.
Everything was A OK when he found a wonderful and well built screen
that fit over a 55 gal drum that he assumed we screened the honey
through. Actually we only used it when we were taking the tank's down
and wanted to salvage any wax or junk left in the tank that we did
not want plugging up the drain or septic system. The honey that went
in these tanks was ready for shipment and required no further processing
other then putting it in the drums and weighing it.
This guy did leave two legal size pages of suggestions, mostly
unrealistic thing's like fixing all the etching in the floor made
by the acid honey eating the cement. The only thing I could do was
take that chicken down. He never showed up again.
Mousses americanis, or just mouse droppings was found in the basement
of my three story honey house on the western slopes of the Rockies in
Colorado. Some federal money was received to do a Honey House inspection
in Colorado and I was targeted. A young collage kid was hired for the
part time job and showed up with a flash light and found 4 or 5 little
smart pills in the basement that was plugged full of 55 gal drums of
clover honey in storage for the winter and under loan. That was all
he could find but enough to make him understandably happy in his work.
With no help from me when inspecting the upper storage area he lost his
carefully packaged and labeled packet of smart pills. He had to use a
flash light as I already had shut this operation down for the winter and
turned off the utilities, including taking in the gas meter that were
know to bust from the very low temps when not in use. Anyway I did not
want him to go back to the eastern slopes and Denver without any smart
pills and wanted to see just how far they would go with evidence like
this that had to be sent out to a lab for identification when any dam
fool could see what it was so I took him back down to the basement and
moved a few drums around so he could find another sample of smart pills.
Months later I received this official looking letter from the state
and included was the lavatory report that the smart pill were indeed
the spore of the mousses americanis and not fossilized buffalo chips
which I had framed and hung on the wall in one of my offices.
The last time I was inspected was several years ago when a real
lawyer-doctor type state health department man showed up at my front
door about noon and demanded to inspect my honey house which is several
miles away from my home. After several hours of filling his head with
all the legal reason's he would do that over my dead body I decided to
let him do his job without further blood shed when he changed the
demand to a polite request much to the surprise and amusement of a
farmer friend who was visiting and enjoying every minute. The inspection
was a joy to watch, and the guy could not believe what he was looking
at and saw no reason for any more Honey House inspections as we were
not at all what he expected and only made one suggestion that I cover
the florescent tube's with plastic tubing and I did that as it was a
good idea having cleaned a broken one's out of a wax vat once. I
would have never know that these new at the time safety tubes were
then available if this guy had not shown up and it was a positive
experience, one of few and still not enough to open my door's to the
public or any government agent without the proper paper work and
introduction. I did have two county health people show up once in a fit
to inspect all honey houses but one call to the board of supervisor's
put them back on the right track. Thousands of people suffer from
improper food handling every year in my area, most of it from food
served at restaurants and gatherings. These place's are only inspected
once a year with prior notice because of budget and manpower
considerations that have not gotten any better over the years.
Beekeeper's and the Honey they produce should be so low on the list
of things that government should worry about as far as new laws that
no one should waste the time. If it ain't broke no reason to brake it
and it would not take much to do that as these are the hard day's for
many beekeepers.
Good Luck and I hope you will keep us posted.
ttul Andy-
(c)Permission to reproduce, granted.
Opinion is not necessarily fact.
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