Question about Polyface and out-of-state Buyers Clubs

[Sylvanaqua]

Hi everyone,

I've noticed that Polyface Farms delivers chickens to buyers clubs outside of Virginia. But I'm wondering, since Polyface processes all its poultry at the farm under an inspection exception that doesn't permit exempt poultry to cross state lines... how are they doing this legally?

Does Polyface actually process all its poultry on-farm, or do they send some to a USDA-inspected facility to sell across state lines? I know Joel Salatin owns T&E meats, but from what I can tell they don't process poultry. It's difficult to imagine there's a loophole that allows exempt birds out of the state; the exemption regs specifically forbid it. The farm is so high-profile that I can't imagine they're just thumbing their nose at the law.

Anyone have a clue how they're doing it? My farm is in Virginia and close to Washington, D.C., and there are several folks in the city who want to set up buyers clubs for delivery. I refuse to turn over my birds to a standard USDA facility that butchers 17+ birds a minute in a manner so unethical they refuse to disclose their procedures.

Thanks in advance for any help/advice.

Chris

 

[my sunwolf]

Hm, this is a good question. I know he's had issues with the laws in the past. If they're under 20,000 birds a year, they can still be under an exemption. If it's above 20,000 birds a year, they may have had their on-farm processing facility USDA inspected, which would allow them to process more and then transport across state lines. There are other licenses you can get as well that enable you to be a distributor of poultry. Polyface may be claiming exemption, but then selling birds to a third party who is a licensed distributor to sell the birds to out-of-state customers. If you want, I'll see if I can dig up the paperwork I have on general exemption info. I think that Polyface, at this point, is definitely complying with all regulations as they're so huge.

I will say that I am pretty familiar with USDA processing as one of our extension agents used to work inspecting a Perdue factory. They rough handle the birds into leg shackles, quick electric shock, quick cut throats, dip in a scald, machine pluck, eviscerated by workers, dumped in a GIANT chill tank with certain chemical baths depending on the facility (this is the part where the birds are released from the shackles). Chemicals in the bath range from bleach to potassium compounds to lactic acids and unknown chemicals. Cornish X carcasses can absorb up to 10% of their weight in water (including what's in the water). So it is kind of unpleasant.

 

[Sylvanaqua]

You brought up something that I'd thought about - that maybe Polyface was selling the birds to a distributor that had the right to take them across state lines. There were two things I saw, though, that made this seem like it's not the case. First, buyers clubs make out their checks directly to Polyface Inc. rather than the distributor. Second, the exemption regs mention the poultry rather than the point of sale:

"The poultry products produced under the PGOP Exemption are distributed solely by the manufacturer and only within the State or
Territory or the District of Columbia in which the poultry product is produced."

That would seem to indicate that the birds would both have to stay inside Virginia and be sold directly by the farm. But maybe his processing area has been USDA inspected. I'm trying to figure out if that's the case, or if he perhaps processes some of the birds at T&E meats, which is a USDA facility and that he does own. Their website doesn't mention anything about poultry, so maybe he just does it there for his own farm.

I'm kicking myself for not thinking to ask Joel about this when I was at his seminar in July

 

[Buster52]

You could call and ask them.

Or, you could pm Thriftyfarmer, who works closely with Salatin.

https://www.backyardchickens.com/u/234922/thriftyfarmer

 

[Sylvanaqua]

Thanks Buster, I just PMed Grady. I haven't been able to get anyone at Polyface on the phone yet, but I'll keep trying