Expanded Opportunities for On-Farm Slaughter

March 27, 2021

In a meeting with Ministry of Agriculture staff on March 25th, the Small-Scale Meat Producers Association was informed of some new policies and regulations that will help producers by opening up more slaughter options and marketing opportunities. While there is a high degree of confidence that these proposed changes will be accepted by cabinet, they do still need to be approved.

The Ministry is proposing to refresh and simplify the current licensing categories.

An “Entry Level” category will allow producers to slaughter up to 5AU (an animal unit is 1000lbs) a year on-farm. The meat processed through this license may be sold within the operator’s regional district and within a 50km radius of their farm.

The “Mid-Range” category will allow producers to slaughter up to 25AU and essentially replaces the current Class E and D licenses. This license will be available in all areas of the province and the meat processed through this license can be sold anywhere in the province through retail, restaurants and farmers markets. Due to the volume of production and expanded market opportunities, there will be more inspections than producers have previously experienced when oversight of on-farm slaughter was under the jurisdiction of the regional health authorities.

With both categories of On-Farm Slaughter License, the operator must complete the new “Slaughter Right” training program and have an approved food safety plan in place. There will be a premises inspection required on an annual basis with additional inspections possible based on assessed risk. Cut and wrap must still take place at a licensed facility and unless the producer is located more than one hour from a provincially inspected abattoir, an explanation of why the inspected facility is not able to meet the needs of the producer must be provided.

Inspected “A” and “B” Abattoirs will fall under one single abattoir license and will not have any processing volume restrictions.

We are expecting cabinet approval of the new policies and regulations this summer and for producers to be able to be operating under the new licenses by this fall.

The Small-Scale Meat Producers Association has been working closely with the Ministry of Agriculture since 2018 to build greater stability and growth opportunities for small-scale meat producers in British Columbia. We are happy with the proposed changes and think they will help to alleviate some of the bottlenecks and lost revenue opportunities producers are currently experiencing. We will continue to work with the Ministry and other industry associations to create more opportunities for producers who want to expand beyond the current 25AU limits but not into a full scale inspected abattoir. We believe that it is within this area that the greatest opportunity lies to build a thriving small-scale meat industry that supports farmers and contributes in a significant way to food security in BC by offering well-raised, high-quality meat to BC markets.

Update July 20, 2021: The BC government has now legislated the regulatory changes described above. These come into effect October 1, 2021. See the government press release and licensing website for more information.

Summary of 2009 Risk Assessment

In the September 2020 Intentions Paper on Rural Slaughter Modernization, the Ministry of Agriculture made reference to a 2009 Risk Assessment:

“Ministry of Agriculture will undertake a risk assessment project to support development options for rural meat production. The work will update an assessment from 2009 and will inform all aspects of food safety policy to lower risk and improve efforts to prevent food-borne illnesses such as those related to salmonella in poultry.”

Ministry of Agriculture 2020 Intentions Paper

The Small-Scale Meat Producers Association requested a copy of the 2009 risk assessment to aid in the development of an informed response on behalf of our members. We were not able to obtain this document directly from either the Ministry of Agriculture or the Ministry of Health before the deadline for feedback and we proceeded without it. Following a lengthy Freedom of Information request process, we were able to obtain the document in February 2021. 

Link to full document: The Application a Risk Management Framework in Support of Policy Development for Meat Safety in Rural Remote BC

The 2009 risk assessment was undertaken by a veterinary epidemiologist using “Risk Ranger,” a food safety risk profiling tool. It is dated November 24th, 2009 but was never published and is marked “Confidential” on every page when we received it. 

The Introduction outlines the risk analysis process which is made up of three elements: risk assessment, risk management and risk communication. It details the application of a risk management framework in support of policy development for meat safety in rural and remote BC and includes two schematic diagrams. 

The Hazard Identification and Characterization section identifies Salmonella, E.Coli and Campylobacter as the most common causes of food-borne illness and provides more information about each of these pathogens including how infection presents in humans, transmission and key carriers. 

In Exposure Assessment and Risk Characterization, various factors are considered including:

  1. Slaughter scale
  2. Animal husbandry systems
  3. Pre-slaughter stress
  4. Machinery/equipment
  5. Hygiene and sanitation

The following key assumptions are outlined:

  1. Potable water
  2. Small scale slaughter in remote and isolated regions
  3. Some form of cooling system is available to cool the carcass
  4. Pest control is practiced
  5. Cleaning and disinfection of tools
  6. Personal hygiene

Risk Ranger was used to calculate the risk based on 3 scenarios: using Literature values (based on research conducted in big scale slaughterhouses), small scale on-farm slaughterhouses, and inadequate cooking (unlikely situation where cooking does not eliminate the hazard). The results are shown in Table 8 and show that the risk of illness due to eating well cooked meat is low given previously mentioned assumptions. In fact, the risk appears to be lower in small scale on-farm slaughter than in large scale facilities.


More detailed exposure assessment tables are provided for beef, pork and chicken under small scale, on-farm slaughter conditions including data for each processing step (rearing, transportation, lairage, stunning, dehairing/defeathering, bleeding/skinning, evisceration, splitting/trimming, washing, chilling, cutting/packaging, cooling/freezing and cooking) through an analysis of activity and equipment used, risk reduction process/comments, and Risk Ranger input. Schematic presentations are included for the processing of beef, pork and chicken. 

The Conclusion of the report states:

“Through the use of the data where it is available and the application of estimates based on conservative assumptions where it is not, we are able to ascertain that, with the incorporation of baseline expectations regarding sanitation, and the use of a defined slaughter process appropriate to small scale operations, we did not demonstrate an inherently increased risk associated with the meat produced through these methods of slaughter.”  

A list of 30 references is included. 

2018 – 2021 British Columbia Slaughter Capacity Work Snapshot

The Small-Scale Meat Producers Association (SSMPA) came together in 2017 when a group of farmers and ranchers identified that access to slaughter was the largest barrier to the growth of their businesses. 

The Association officially incorporated as a non-profit in early 2018 and has been actively working to build greater stability and growth opportunities for small-scale meat producers in British Columbia.

To date, the Small-Scale Meat Producers Association remains the only organization representing producers whose needs are generally otherwise unrepresented within the existing commercial and regulatory framework.

For the past three years we have participated in a number of Industry-led consultations and surveys. We have made presentations, provided feedback, lobbied for deadline extensions and greater inclusion in these conversations and continuously endeavoured to provide the government with critical information they need to make meaningful regulatory changes and support this emerging, but stifled, market. Progress has certainly been disproportionate to the amount of resources and time that have been expended throughout this process.

Following is a brief history of the work that has been done in this area and our contributions:

Government Consultations

2018 Class D and E Consultations

In March and April 2018, the Ministry of Agriculture, Food and Fisheries (then referred to as the Ministry of Agriculture) undertook a focused consultation in regards to the Class D and E (On-Farm Slaughter) License components to the Meat Inspection Regulation program. 

According to consultation documents, the purpose of this consultation was “to help improve food security in rural communities and help more British Columbians enjoy BC beef, pork, poultry and lamb…”

The following stakeholders were asked “for feedback and suggestions on how to improve rural abattoir licensing in BC:”

  • Current and expired Class D and E licence holders
  • Applicants who had been denied a licence
  • Applicants who had been approved by never followed through with licencing
  • BC Association of Abattoirs
  • BC Cattlemen’s Association
  • BC Sheep Federation
  • Small-Scale Meat Producers Association
  • Regional Health Authorities

The SSMPA was instrumental in having this consultation process extended and opened up to a wider group of stakeholders in order to improve the quantity and quality of responses. We filled out the survey and also submitted a written response for consideration including a number of recommendations.

In June of 2018, the Ministry of Agriculture (the Ministry) issued a press release release stating that “Small abattoirs and other stakeholders have provided their ideas about how to improve provincial abattoir licensing and food security in rural communities, through a consultation process led by the Ministry of Agriculture.” The responses are summarized in a 113 page document that was released to the public

2018 Select Standing Committee on Agriculture Consultations

In spring of 2018, concurrent to the Class D and E consultations, the Ministry re-assembled a Select Standing Committee on Agriculture and issued a Discussion Paper asking for public engagement on questions provincial meat inspection including the following:

Are there options for changing regulations and policy that could increase:

• Livestock production in B.C.?

• Processing in BC of animals raised in B.C.?

• Slaughter capacity, especially in rural and remote communities?

• Access to B.C. meat for consumers, retailers, restaurants, and institutional buyers?

• Access to specialized types of slaughter to meet cultural and market-based demands?

• Standards for food safety and the humane treatment of animals?

How can access to training and development be improved in order to support the meat production sector’s need for skilled workers?

Are the regulations with respect to provincial meat production, including those under the authority of the Ministry of Agriculture, the Ministry of Health and the regional health authorities, clear and effective?

How can the provincial inspection system more effectively align with the federal meat inspection system in order to strengthen B.C.’s meat production, including the licensing of slaughter facilities (The federal government is responsible for licensing slaughter facilities that sell products outside of B.C.)?

The committee traveled around the province for in-person meetings with stakeholders from May through June and several members of the SSMPA spoke at these hearings and/or submitted written submissions. 

SSMPA Recommendations to Select Standing Committee Consultations

The SSMPA submitted an extensive written submission after listening to and reading the transcripts from every public hearing.  Our written submission included the following recommendations:

  1. Improvements to On-Farm Slaughter Licensing:
    1. Bring all provincial abattoir licencing under the Ministry of Agriculture.
    2. Extend possibility of on-farm slaughter to all areas of BC.
    3. Increase AU limits, potentially on a by-species or case-by-case basis.
    4. Remove regional district restriction for sale of farm-slaughtered products.
    5. Adjust Feasibility Study process to reduce municipality bias against abattoirs and to consider reasons for on-farm slaughter beyond distance to existing abattoir.
    6. Improve oversight of small-scale slaughter facilities, including meaningful inspections and required test kills.
    7. Increase access to training for small-scale operators, including training that is available to A/B operators through the BC Association of Abattoirs.
    8. Introduce changes that make mobile abattoirs (slaughter trucks) a feasible and legal option for on-farm slaughter.
  2. Increased Opportunities in Supply Managed Commodities:
    1. Direct the Marketing Boards to increase the number of birds allowed for Small Lot Permit Grower / Direct Vendor programs 
    2. Carefully review New Entrant programs to assess the effectiveness and integrity of the process in meeting market demand for specialized local meat production.
    3. Determine whether changes are needed in order to encourage viable slaughter and processing options for Permit producers and small quota holders.
  3. Access to Funding:
    1. Promote existing funding sources that would benefit small-scale meat producers.
    2. Make funding available for projects critical to the goal of increasing availability of locally-produced meat, such as abattoir improvements, facility upgrades, and training programs.
  4. Enhanced Communications:
    1. Schedule consultations to coincide with the slower season for farmers.
    2. Utilize the newly-formed Small-Scale Meat Producers Association to gather feedback when needed and disseminate information of importance to producers.
    3. Facilitate improved relations between on-farm abattoirs, A/B operators and small-scale livestock producers to overcome challenges, improve operations and meet market demand together.
    4. Support the Small-Scale Meat Producers Association in organizing and becoming the voice of this promising emerging industry.

The Committee released its findings in a report including 21 recommendations on September 28: 

Recommendations from the Select Standing Committee on Agriculture, Fish and Food to the Legislative Assembly

Inspection and Enforcement

  1. Encourage the Ministry of Agriculture to look for ways to improve cross-ministry
    coordination, collaboration and communication to expand current meat inspection and enforcement services to realize efficiencies, minimize risks, ensure consistency, simplify practices for producers and processers, as well as share best practices and enhance skills.
  2. As a way of supporting small-scale meat producers and processors, require the Ministry of Agriculture (or their designate) to increase resources to enable engagement with Class D and E licensed facilities to ensure increased inspections at those facilities, including slaughter.
  3. Help Class D and E licensed producers reach markets closer to home by investigating alternative boundary restrictions for sales, other than regional districts.
  4. Work with relevant authorities to address the gap that currently exists in inspection and enforcement related to livestock sales or auctions to enable provincial inspectors to enter a public livestock sale yard to test animals on a regular basis.
  5. Investigate options to expand use of current technologies to extend or implement virtual inspections in communities, where available.
  6. Confirm that regular reviews of the inspection system occur, in consultation with producers and processors, to ensure ongoing opportunities for assessment and improvement of the current system.

Food Safety

  1. Provide ongoing training and education opportunities, including during inspections, to producers and processors with respect to food quality and safety, as well as the humane treatment of animals, to share knowledge and awareness of current best Practices.

Humane Treatment of Animals

  1. Ensure there are sufficient resources available for enforcement to ensure compliance in relation to regulations regarding the humane treatment of animals by those engaged in all aspects of meat production and inspection.

Education and Training

  1. Offer additional opportunities for professional or post-secondary training programs to encourage new entries into the meat production and processing industries, and to provide upgrading or new skill development for those already working in these industries to promote career longevity.
  2. Ensure that information regarding safe slaughtering techniques, safety standards and best practices is made available in a variety of formats (including online or through a correspondence course model), is kept up to date, and is supported with in-person training and slaughter opportunities.

Recruitment and Retention of Skilled Labour

  1. Look at options to develop or enhance existing apprenticeship, mentorship and co-op training programs, including opportunities at the high school level, to help build workforce capacity and transfer valuable institutional knowledge. [See recommendation #16 under Slaughter Capacity]

Access to Farmland

  1. Ensure that sufficient productive agricultural land is and remains available for livestock grazing in order to encourage increased livestock and local food production capacities.
  2. Strongly promote the availability of productive Crown land within the Agricultural Land Reserve for livestock grazing purposes in an urgent manner, particularly in light of the devastation caused by wildfires and other natural disasters.

Marketing and Promotion

  1. Make sure that the “Buy BC” promotional marketing campaign highlights the benefits of purchasing local meat products to encourage British Columbians to support local producers and retailers.

Financial Considerations

  1. In partnership with the federal government, investigate options to develop a three- to five-year averaging formula in relation to natural disaster compensation for those who derive less than 50 percent of their income from farming.

Slaughter Capacity

  1. Provide additional training for finishing of meat products to producers to help alleviate capacity issues by extending the slaughter season. [See recommendation #11 under Recruitment and Retention of Skilled Labour]
  2. Reduce current travel time restrictions to one hour between Class A/B licensed facilities and Class D/E licensed facilities to help alleviate local slaughter capacity challenges and increase local livestock production.
  3. Review mobile slaughter regulations to look for opportunities to make mobile slaughter more accessible to small producers in B.C. without compromising food safety or the humane treatment of animals.
  4. Cooperate with producers and processors to address seasonal capacity issues by expanding business opportunities to maintain a viable living, including increasing the production of value-added specialty products and services

New Farmers

  1. Through the Ministry of Agriculture, work with community and industry organizations, such as 4-H, Young Agrarians and Farmers Institutes, to continue to promote interest and engagement in the industry through local agricultural fairs.
  2. Create a comprehensive and accessible reference, to be made available through the Ministry of Agriculture in a variety of formats, to highlight existing educational and other programs to ensure that those interested in entering the industry can find the information they need.

    The Ministry accepted all 21 recommendations of this report.

Key Findings

The following are the key findings in the Select Standing Committee on Agriculture, Fish and Food report relating to on-farm slaughter:

  • No slaughter facilities in B.C. are currently classified as high risk, and only 20 percent are assessed at moderate risk.
  • Regional Health Authority representatives informed the Committee that they were not aware of any disease outbreaks related to public health that had been traced back to a Class D or E licensed facility.
  • The Enforcement Officer noted that five files have posed health risks, all of which were illegal, unlicensed operations.
  • Committee Members acknowledged that the systems in place to ensure food safety and product quality appear to be working well and they are proud of the work currently being done.
  • Committee Members acknowledged that allowing more farm-gate sales (currently Class D and E) could be beneficial in permitting producers the opportunity to diversify their products, realize additional income in slower seasons, and build relationships with local customers, either through sales at local farmer’s markets or through direct consumer transactions on their farms.
  • The Committee discussed various options to identifying opportunities to approach mobile slaughter differently, to make this service more affordable and accessible to small producers. This could potentially relieve variable pressures on the system, without compromising food safety and the humane treatment of animals.

2019 Local Governments Class D Consultation

In 2019, the Ministry announced that they would be consulting with local governments for a six- week period starting on June 3rd. They were looking for “proposals for new class D regions or sub-regions; and designation of new regions or sub-regions.” 

The SSMPA learned of this consultation and lobbied for an extension of the timeline given that many municipal government workers were on vacation and/or unfamiliar with Class D licenses. The deadline was extended to October 1st. 

2020 Intentions Paper on Rural Slaughter Modernization

In September of 202, the Ministry issued an Intentions Paper on Rural Slaughter Modernization as “part of the ongoing work to assess opportunities for improvement and positive changes that will strengthen our provincial food system and ensure a strong and growing local meat industry in B.C. for many years to come.” 

The Intentions Paper indicated that a number of regulatory and policy changes were being considered and solicited comments and submissions.  The deadline for comment was October 19th. 

The Intentions Paper made reference to a 2009 Risk Assessment. SSMPA requested a copy of this document and after a five month process through Freedom of Information, was finally granted access to this document in Feb 2021.

The following recommendations were submitted by the SSMPA:

Adopt and strengthen an extension model in line with the stated goal of ‘education before enforcement’, and ensure that the level of oversight, including inspections and reporting requirements, matches the risk level of a given operation.

We have seen the negative impact that regulatory change can have on our sector with the tremendous loss of meat processing capacity and livestock production beginning with changes introduced in 2004.  An update of the Code of Practice that will “establish higher standards” must create opportunity rather than restrict it, and improve systems without adding excessive costs and burdens.  It is critical to remember that though there are many reasons to change our regulations and policies, including mitigation of risk, there have not been food safety issues or negative public health outcomes as a result of our current system.  SSMPA looks forward to participating in the update of a risk assessment, which will help ensure that oversight matches risk at different scales of production.

Create maximum flexibility in the methods of providing oversight to slaughter facilities.  

Video inspections, tele veterinary consultations, contracted inspections and periodic slaughter inspections are all good opportunities.  The type of inspection could vary based on the scale of the facility, the booked volume and availability of inspectors.  As more slaughter facilities are developed around the province, especially remote and low-capacity facilities, the cost of the current inspection system will become overwhelming, and the cost per head of inspection at these facilities cannot be justified given the low risk to consumers.

Replace Class E licence with a broad Farmgate Slaughter Exemption.

Contrary to information presented in the Intentions Paper, most other provinces and territories allow uninspected on-farm slaughter of animals sold whole and directly to a single end consumer, typically by exempting this type of arrangement from the applicable regulation.  In our research, possibly notable in disallowing any sale of uninspected meat are Ontario and Prince Edward Island. Some jurisdictions have additional caveats or requirements: require the animal to have been owned by the producer for a length of time (e.g. Nunavut), only permit the sale of uninspected poultry (e.g. Manitoba), or require licensing and reporting (e.g. Alberta).  Exempting single-customer farmgate sales would recognize the right of an informed consumer to choose farm-slaughtered meat, and would provide an opportunity to provide resources and oversight to operations currently happening illegally and underground.  Some requirements in terms of premise registration or reporting would be reasonable, and restrictions on further processing by the producer could be warranted, but this is a low-risk and high-transparency arrangement that requires minimal oversight.

Redevelop the Class D uninspected slaughter licence into a more flexible, more useful Limited Custom Slaughter Licence.

Producers who wish to sell portions of carcasses, sell products at retail or to other users such as meat shops or restaurants will need to slaughter livestock in a licenced slaughter facility.  A category of licensed facility with less requirements and less oversight than a Class A or B reduces the barrier to entry for lower volume and lower risk slaughter operations.  This can be an important step in the growth of new facilities, allowing operation at an economically viable scale without excessive costs.  It also reduces the cost of administration and oversight for the Ministry, avoiding unnecessarily high per-head inspection costs for these low-volume operators, many of whom would be located in rural and remote areas.  

The redevelopment could include expansion beyond on-farm slaughter, and include the flexibility to address different levels of risk.  Facilities slaughtering for multiple producers could be allowed on a case-by-case basis in areas where there is a demonstrated need for additional capacity, or where producer needs are not being met.  Additional oversight requirements could apply to operators slaughtering livestock for multiple farms.

Candidates for this class of licence include the following:

  • Producer slaughtering their own livestock on-farm 
  • On-farm abattoir slaughtering for multiple producers
  • Off-farm abattoir slaughtering for multiple producers
  • Existing operating Class A or B facility that falls below a risk threshold
  • Non-operational facility that is not economically viable as a Class A or B
  • Mobile slaughter operation

As the Ministry improves oversight of these facilities, opportunity should increase.  Availability of this class of slaughter licence should be expanded to all areas of the province, and all sales area restrictions should be removed.  Risks to public health will be mitigated by the improvements to the Rural Code of Practice, development of individualized standard operating procedures and food safety plans.  Risk will also be mitigated through limits to the volume of animals slaughtered, which should be assigned on a case-by-case basis by the Meat Inspection Team upon review of the individual application, with an opportunity to reassess annually.

Facilitate the development of new abattoirs and the growth of existing facilities where appropriate.

Bringing oversight of all slaughter facilities under the Ministry of Agriculture is a welcome step that simplifies and clarifies the system and will improve communication.  It is our hope that this will also streamline the path to growth for enterprises that see opportunity in increasing their volume or serving other producers.  However, we must recognize that the goal is to right-size a facility within a framework that matches oversight and requirements to the level of risk, not to climb a regulatory ladder.  A federally-inspected plant is not better than a provincially-inspected plant, and likewise provincially-inspected slaughter is not better than inspection-exempt farm slaughter.  This is a continuum of oversight across varying levels of risk based on volume and distribution, type of manufacturing and facility-specific factors.  With the responsibility of regulation comes the responsibility to facilitate the growth of this sector.  The Ministry should allocate resources to support the development of the infrastructure and human capital required to realize these goals. 

Investigate and discuss possibilities for increasing access to meat processing (cut and wrap, value-adding).

The increase in local production and slaughter of livestock must be matched by an increase in the capacity for further meat processing in order to meet the growing consumer demand for local meat products.  Consideration should be given to whether the Ministry of Agriculture could provide the necessary oversight to meat shops primarily handling meat slaughtered under provincial licensing, such as the processing side of meat shops associated with slaughter facilities or those receiving carcasses directly from farms.  The Ministry should provide information, assistance and funding to this effort.

Assist the SSMPA and aligned groups in efforts to attain liability insurance coverage for businesses engaged in licenced and legal slaughter, processing and sale of meat.

Many of our members struggle to obtain liability insurance despite following all regulations and operating legal businesses.  This is primarily due to a lack of understanding of the level of risk from the perspective of underwriters.  The SSMPA will need assistance in providing the relevant information to potential insurers as we attempt to rectify this situation.  We hope that this restructuring and the upcoming risk assessment will be useful in this regard.

Government Actions That Have Increased Slaughter Capacity

  1. Allowing Class E establishments within one-hour travel time of a licensed Class A or B facility, instead of the two-hour limit that was in place before May 2019.
  1. Designating three new areas for Class D rural slaughter licensing: Alberni-Clayoquot Regional District, Electoral Area D in Regional District of Central Kootenay and Electoral Area H in Regional District of Fraser-Fort George.*

*Impact on slaughter capacity unlikely to be significant given that the total population of these regions combined makes up 0.003% of the population of British Columbia. Total Population Data for these regions:

  • Alberni-Clayoquot Regional District outside of the City of Port Alberni: 13,303
  • Electoral Area D in Regional District of Central Kootenay: 1413
  • Electoral Area H in Regional District of Fraser-Fort George: 1586

Government Actions Related to Meat Production That Have Not Increased Slaughter Capacity

  1. All slaughter activity licensed under the Meat Inspection Regulation for Class A, B, D and E meat-slaughter licences will be regulated under the Ministry of Agriculture effective Dec. 1, 2020. Previously, regional health authorities had responsibility for Class D and E licences.
  1. Delivering a series of food safety and animal welfare training workshops for rural producers and existing Class D and E license holders.
  1. Highlighting local meat products through the Buy BC program.
  1. Funding food safety and traceability programs for meat producers.
  1. Implementing a mandatory Premises ID Registration
  1. Introduction of a revised mandatory training program for Class D and E licensees. 

References


2009 Risk Assessment
https://drive.google.com/file/d/1MH_eEn92iITx-E9r6XP-Em-W9-vViFx7/view?usp=sharing

2018 Class D & E License Consultation: Summary of Survey Responses
https://www2.gov.bc.ca/assets/gov/farming-natural-resources-and-industry/agriculture-and-seafood/food-safety/meat-inspection/delicenceconsultation2018.pdf

2018 Response to Ministry of Agriculture’s Class D/E Survey/Consultation Process
https://smallscalemeat.ca/2018/04/11/response-to-ministry-of-agricultures-class-d-e-survey-consultation-process/

2018 Select Standing Committee Report on Local Meat Production and Inspection in British Columbia
https://www.leg.bc.ca/content/CommitteeDocuments/41st-parliament/3rd-session/aff/Rpt_AFF_LocalMeatProductionAndInspection_2018-09-28.pdf

2020 Intentions Paper on Rural Slaughter Modernization
https://engage.gov.bc.ca/app/uploads/sites/121/2020/09/ministry_of_agriculture_intentions_paper_rural_slaughter_modernization.pdf

2020 SSMPA Public Response to Intentions Paper
https://smallscalemeat.ca/2020/11/15/ministry-of-agriculture-intentions-paper-response/

2020 SSMPA Feedback to Ministry of Agriculture in Response to Intentions Paper
https://smallscalemeat.ca/2020/11/16/recommendations-to-ministry-of-agriculture-in-response-to-september-2020-intentions-paper/

Recommendations to Ministry of Agriculture in Response to September 2020 Intentions Paper

Thank you for the opportunity to provide feedback on the Rural Slaughter Modernization Intentions Paper.  The Small-Scale Meat Producers Association formed in 2018 to act as a voice for a group of farmers and ranchers lacking in formal representation through other sector organizations.  Our mission is to build greater stability and growth opportunities for small-scale meat producers in British Columbia, and rural slaughter capacity is critical to this goal.  Our members are located throughout the province and operate a wide range of enterprises, but we share one thing in common — in order to start up, remain in business and grow, we need reliable, consistent, affordable access to slaughter and meat processing services.

The SSMPA is broadly in support of efforts by the Ministry of Agriculture to improve the efficiency and efficacy of the provincial meat inspection program.  We have contributed our perspective throughout the previous rounds of consultation and worked to disseminate information about the process to our membership.  Our primary concern is that we do not see the urgency of the situation facing many of our members reflected in the pace or tone of the Ministry’s work on these issues.  Farmers and ranchers throughout the province are responding to increased demand for local meat, but the existing system was inadequate even before the current crisis.  The slaughter and processing bottleneck reduces the potential for growth and recovery of the sector, reduces availability of local meats for local markets, creates inefficiencies for producers and increases unregulated slaughter with no oversight or guidance.

We recommend that the Ministry support recovery of the agriculture sector and improve the security of our local food supply by immediately introducing measures to accommodate producers whose needs are not being met by the existing network of provincially-inspected abattoirs or the available licences.  The COVID-19 crisis grants us an enormous opportunity to make changes that will support our producers through the pandemic and beyond.  This should be the first item on the Action Plan, and should be implemented immediately.  SSMPA believes that the Ministry has enough information and a clear mandate to introduce these changes.  Examples of changes that could help mitigate the acute issues are included among our recommendations below.

Recommendations

Adopt and strengthen an extension model in line with the stated goal of ‘education before enforcement’, and ensure that the level of oversight, including inspections and reporting requirements, matches the risk level of a given operation.

We have seen the negative impact that regulatory change can have on our sector with the tremendous loss of meat processing capacity and livestock production beginning with changes introduced in 2004.  An update of the Code of Practice that will “establish higher standards” must create opportunity rather than restrict it, and improve systems without adding excessive costs and burdens.  It is critical to remember that though there are many reasons to change our regulations and policies, including mitigation of risk, there have not been food safety issues or negative public health outcomes as a result of our current system.  SSMPA looks forward to participating in the update of a risk assessment, which will help ensure that oversight matches risk at different scales of production.

Create maximum flexibility in the methods of providing oversight to slaughter facilities.  

Video inspections, tele veterinary consultations, contracted inspections and periodic slaughter inspections are all good opportunities.  The type of inspection could vary based on the scale of the facility, the booked volume and availability of inspectors.  As more slaughter facilities are developed around the province, especially remote and low-capacity facilities, the cost of the current inspection system will become overwhelming, and the cost per head of inspection at these facilities cannot be justified given the low risk to consumers.

Replace Class E licence with a broad Farmgate Slaughter Exemption.

Contrary to information presented in the Intentions Paper, most other provinces and territories allow uninspected on-farm slaughter of animals sold whole and directly to a single end consumer, typically by exempting this type of arrangement from the applicable regulation.  In our research, possibly notable in disallowing any sale of uninspected meat are Ontario and Prince Edward Island. Some jurisdictions have additional caveats or requirements: require the animal to have been owned by the producer for a length of time (e.g. Nunavut), only permit the sale of uninspected poultry (e.g. Manitoba), or require licensing and reporting (e.g. Alberta).  Exempting single-customer farmgate sales would recognize the right of an informed consumer to choose farm-slaughtered meat, and would provide an opportunity to provide resources and oversight to operations currently happening illegally and underground.  Some requirements in terms of premise registration or reporting would be reasonable, and restrictions on further processing by the producer could be warranted, but this is a low-risk and high-transparency arrangement that requires minimal oversight.

Redevelop the Class D uninspected slaughter licence into a more flexible, more useful Limited Custom Slaughter Licence.

Producers who wish to sell portions of carcasses, sell products at retail or to other users such as meat shops or restaurants will need to slaughter livestock in a licenced slaughter facility.  A category of licensed facility with less requirements and less oversight than a Class A or B reduces the barrier to entry for lower volume and lower risk slaughter operations.  This can be an important step in the growth of new facilities, allowing operation at an economically viable scale without excessive costs.  It also reduces the cost of administration and oversight for the Ministry, avoiding unnecessarily high per-head inspection costs for these low-volume operators, many of whom would be located in rural and remote areas.  

The redevelopment could include expansion beyond on-farm slaughter, and include the flexibility to address different levels of risk.  Facilities slaughtering for multiple producers could be allowed on a case-by-case basis in areas where there is a demonstrated need for additional capacity, or where producer needs are not being met.  Additional oversight requirements could apply to operators slaughtering livestock for multiple farms.

Candidates for this class of licence include the following:

  • Producer slaughtering their own livestock on-farm 
  • On-farm abattoir slaughtering for multiple producers
  • Off-farm abattoir slaughtering for multiple producers
  • Existing operating Class A or B facility that falls below a risk threshold
  • Non-operational facility that is not economically viable as a Class A or B
  • Mobile slaughter operation

As the Ministry improves oversight of these facilities, opportunity should increase.  Availability of this class of slaughter licence should be expanded to all areas of the province, and all sales area restrictions should be removed.  Risks to public health will be mitigated by the improvements to the Rural Code of Practice, development of individualized standard operating procedures and food safety plans.  Risk will also be mitigated through limits to the volume of animals slaughtered, which should be assigned on a case-by-case basis by the Meat Inspection Team upon review of the individual application, with an opportunity to reassess annually.

Facilitate the development of new abattoirs and the growth of existing facilities where appropriate.

Bringing oversight of all slaughter facilities under the Ministry of Agriculture is a welcome step that simplifies and clarifies the system and will improve communication.  It is our hope that this will also streamline the path to growth for enterprises that see opportunity in increasing their volume or serving other producers.  However, we must recognize that the goal is to right-size a facility within a framework that matches oversight and requirements to the level of risk, not to climb a regulatory ladder.  A federally-inspected plant is not better than a provincially-inspected plant, and likewise provincially-inspected slaughter is not better than inspection-exempt farm slaughter.  This is a continuum of oversight across varying levels of risk based on volume and distribution, type of manufacturing and facility-specific factors.  With the responsibility of regulation comes the responsibility to facilitate the growth of this sector.  The Ministry should allocate resources to support the development of the infrastructure and human capital required to realize these goals. 

Investigate and discuss possibilities for increasing access to meat processing (cut and wrap, value-adding).

The increase in local production and slaughter of livestock must be matched by an increase in the capacity for further meat processing in order to meet the growing consumer demand for local meat products.  Consideration should be given to whether the Ministry of Agriculture could provide the necessary oversight to meat shops primarily handling meat slaughtered under provincial licensing, such as the processing side of meat shops associated with slaughter facilities or those receiving carcasses directly from farms.  The Ministry should provide information, assistance and funding to this effort.

Assist the SSMPA and aligned groups in efforts to attain liability insurance coverage for businesses engaged in licenced and legal slaughter, processing and sale of meat.

Many of our members struggle to obtain liability insurance despite following all regulations and operating legal businesses.  This is primarily due to a lack of understanding of the level of risk from the perspective of underwriters.  The SSMPA will need assistance in providing the relevant information to potential insurers as we attempt to rectify this situation.  We hope that this restructuring and the upcoming risk assessment will be useful in this regard.

Public Response to Ministry of Agriculture Intentions Paper

Click here to read the Rural Slaughter Modernization Intentions Paper.

These intentions outlined in the paper do not appropriately reflect the urgency of the current situation with regards to slaughter/cut & wrap capacity in British Columbia. We are facing a serious crisis that will continue to evolve and be exacerbated in the coming months. Abattoirs, stretched beyond capacity, are already cancelling bookings that were made months ago with their next available dates being well into 2021. Producers are being left with literally nowhere to process their animals legally. The Government has an opportunity here to provide relief and oversight during a global pandemic that could be a catalyst for long-lasting, progressive change in the future.

The time to “undertake a risk assessment project to support development options for rural meat production” was years ago. It is too late for that now. Many operations simply cannot survive another round of consultations.

Exploring opportunities for alternative inspection methods is a step in the right direction. If we have learned anything from the COVID-19 pandemic, it is that a lot of what we previously thought could only be accomplished in face-to-face settings can actually be accomplished virtually. 

It is our expectation that this could be implemented fairly quickly. Virtual technology could also potentially optimize the limited time inspectors have as they would be able to inspect more carcasses in a shorter period of time if travel is no longer an issue.

If slaughter capacity is expanded, cut and wrap capacity will need to grow proportionally. Rural abattoirs without cut and wrap facilities will need somewhere to send their carcasses for further processing. Many small, rural butcher shops are already operating at capacity and will need support/incentives to accommodate increasing demand for custom cutting services. Encouraging these businesses to scale will ultimately pave the way to greater regional food security and economic growth. Programs such as the Off-Farm Food Safety Program are well positioned to provide this kind of support but may need some adjustments and more funding to meet demand. 

Alberta has recognized the crisis and addressed it with their new On-Farm Slaughter Operation License. British Columbia was already far ahead of Alberta in terms of consultations, research and experience with on-farm slaughter. Surely we are in a position to implement meaningful change to address this crisis in a more timely manner.

The intentions paper indicates that “Consumer demand has increased for local meat due to national meat supply chain disruptions” but this doesn’t really capture the true picture. Consumer demand for local meat was already increasing long before the national meat supply chain disruptions. We were already struggling to meet the growing demand before COVID-19 became a global issue. This isn’t a new or unexpected problem. It has been on the table for a long time and there have been multiple/ongoing consultations with regards to these issues. With all the information already gathered, we should be able to act more quickly than this.

Saying “Developing a resilient and diverse food supply chain for British Columbia can help to mitigate large scale production disruption” does not fairly acknowledge the significant contribution this type of production can make towards local food security and the local economy. A resilient and diverse local food supply chain isn’t something we should have just in case the “real” food supply chain breaks down. It should be the norm and we need appropriate infrastructure and regulations that reflect this.

“Late fall 2020” is too late to “begin regulatory and policy change.” We need it now. September was not the appropriate time of year to initiate meaningful consultation with the farmers and ranchers. We need to implement some emergency measures now to get us through this crisis. The Ministry could continue to consult through the winter when producers have more time to devote to this important process and new regulations and policies could be introduced in the spring. With an election taking place in the middle of the public consultation period, we fear further delays.

We need to act now to increase access to rural slaughter and butcher services. There is tremendous opportunity for the development and growth of a thriving local meat industry in British Columbia but too many regulatory barriers to realize this potential. The Union of BC Municipalities has passed numerous resolutions in support of expanding access to slaughter and processing for small-scale livestock operations since 2010, including 2018-B35 asking government to “give farmers the ability to slaughter their livestock on farm premises” and 2018-B75, which asks the government to “facilitate expansion of safe, local, slaughter and meat processing”.   The BC Chamber of Commerce took a position on this in 2015, recommending “that the Provincial Government expand D and E licenses throughout the province to include the 18 non-designated areas”.

It has been frustrating for small-scale meat producers to see so many government resources going into programs such as Grow BC, Feed BC and Buy BC when it is impossible for these producers to scale their businesses to even meet the current demand. Local meat production could be a cornerstone of our province’s agricultural economy. Instead, it is more often than not a financial drain on the families who continue to operate these farms and ranches, often subsidizing the cost with off-farm income and great personal sacrifice in order to provide some level of food security to their communities. These producers need real, meaningful support and regulatory change now.