The most direct interaction I have with the government in the dairy business comes through the New York Sate Department of Agriculture and Markets. Every month, the inspector comes to collect product samples to be tested for bacteria counts, and runs through the checklist to ensure we’re following cleanliness standards.
This spring, we took over an existing facility that had been inspected for over a dozen years. Therefore, we did not experience the headaches that like some start-up producers: misunderstanding the regulations, which could have been a communication break between them and their inspector, or the producers earnest effort to interpret regulations that resemble a foreign language…mistakes in designing the facility that can cost thousands of dollars!
Luckily, we have a great relationship with our inspector. Though there is a laundry list of state approved protocols to design and maintain dairy processing facilities, inspectors understand that some protocols are flexible depending on the scale of production. It turns out that much of the regulation and enforcement depends on trust.
Take, for example, pasteurization. We produce a few soft cheeses and yogurts, which require pasteurization (anything that is not aged at least 60 days must be legally pasteurized). There are two forms of pasteurization: “batch” or “vat,” holding milk at 145 degrees Fahrenheit for 30 minutes in a vat vessel, or HTST (high temperature short time), sending the milk through a pressurized tube at 191 degrees for less than a minute. Like most small facilities, we use a vat, but all facilities must legally prove that pasteurization has been achieved using a chart recorder, a piece of equipment with a rotating chart that records the time and temperature of the milk.
The previous owners chart recorder was one of the last remaining manual drive recorders, which resembled more a wind-up toy than a legal device. When it officially bit the dust this summer, we found out that no company any longer makes wind-up drives, nor do they manufacture mercury probe thermometers (all other facilities use digital). We got a replacement 120 volt drive, but after another month the recorder again rendered itself useless. Over a thousand dollars later, the refurbished recorder we received had its own blips, so the company sent us a temporary replacement recorder and thermometer while they fix the refurbished one we’d bought.
When our inspector came to check on the newest device we had been bequeathed, we noticed it was missing the clip that keeps the chart pinned to the recorder—I imagine he was feeling a little sorry for us at that point because he helped us jury-rig a rubber stopper to fasten down the charts. He went on to say that he appreciates our reliable (and sometimes constant) communication with him, and he fully realizes that the producer can fabricate these charts. We’re glad to have gained his trust and support, even though it would be relief not to be so regulated, and it would certainly lower our cost of production and stress level not to go through these hoops; his position was almost cut a year or two ago, so I’m curious to see what is funded by the state or federal government in the future and how it will affect small-scale agriculture.
As far as broader policy goes, we’re not as affected by the impending Farm Bill as the large agribusinesses. That’s not to say that it doesn’t affect us, but until policies are created that affect producers on our scale, our business isn’t holding its breath awaiting what shape the 2013 legislation will finally take. Subsidies are pretty out of our league from my understanding, but we are interested in taking out a mortgage with the FSA for a bomber low-interest rate. Their farm ownership loans can’t be refunded until the bill passes. I’m interested to know what will happen with SNAP, since such a great percentage of the Farm Bill historically supported food stamps and nutrition programs.
The federal government could impact our farm in a few other ways as well. If we decide to buy in milk to continue cheese-making this winter, we will be subject to FDA inspection if the farm we’re hauling from sells to an interstate delivery truck (it probably will). At the annual Processing Plant Supervisor meeting, the state government was criticizing and lamenting the federal infiltration of our small processing plants, commiserating about their cluelessness when it comes to dairy plant inspection. After all, the feds sent out “Food Safety Inspectors” who didn’t imagine that cheese ages in a real deal cave. Rumor has it that OSHA is going to start inspecting all of the small operations as well! I’m no Libertarian, but this level of regulation borders insanity.
Speaking of trust earlier—I wish they trusted that we farmers highly value the quality and sanitation of our products, and the health of our cows. To think that our business has gone through so much rigmarole when it all started because “I like milking cows…” At least I still love milking cows.
Thanks to Stonyfield, Profits for the Planet, for funding the 2013 Bootstrap blog series.