Q.

What are the slaughter options for sheep/goats?

A.

Meat is heavily regulated by federal, state, and local authorities. In the US, there are four levels of meat inspection: federal (USDA), state, custom-exempt, and personal exemption.

Federal (USDA) is the highest level of inspection. The meat from sheep/goats processed in a federally-inspected facility can be sold without restrictions, if the meat is properly labeled. Federal inspection includes both a pre- and post-mortem inspection of the animal. There are daily inspections of the facility. A HACCP plan is required for all stages of processing. Recall plans are required.

State meat inspection is usually a partnership between states and USDA. It must be "at least equal to" federal inspection. Despite this requirement, most state-inspected meat cannot be sold across state lines. There have been numerous efforts to change this, including the DIRECT Act which would allow retail quantities of meat to be sold across state lines via e-commerce. About half the states have state meat inspection. The rest of the states have turned meat inspection over to the federal government.

Custom-exempt slaughter is exempt from continuous inspection. There is no pre- or post-mortem inspection of the animal. Only the facilities are periodically inspected. The carcasses and meat from custom-exempt slaughter cannot be sold commercially. The meat must be stamped "not for resale" and returned to the owner. Custom-exempt slaughter is sufficient for the "freezer" trade as a live animal (or share of) is being sold, with the customer providing cutting instructions and paying for processing. To sell meat by the cut, you must have animal processed in an USDA or state-inspected facility.

The final level of meat inspection is the personal exemption. This is the most controversial one, as it is open to interpretation. The personal exemption allows the farmer to process an animal of his/her's own raising. Similar to custom-exempt meat, this meat cannot be sold commercially. It can only be shared with household members and non-paying guests and employees.

Some states restrict on-farm slaughter to the person who raised the animal or they stipulate ownership requirements. Other states allow the buyer of a live animal to slaughter the animal on the farm where it was purchased. In actuality, there is no language in the federal regulations which permit or forbid on-farm slaughter by the customer. Some states argue that by allowing the customer to slaughter the animal on the farm where it was purchased, the farm is a processing facility and must meet the requirements as such. Other states (or inspectors) disagree and allow on-farm slaughter to occur, so long as a live animal is bought/sold.

On-farm slaughter is considered essential to selling to some of the ethnic markets. Many ethnic customers prefer to do their own slaughter. Many have requirements that cannot be met by local processing plants, e.g., need for Halal slaughter. Legal on-farm slaughter is preferable to the black market. States should come up with reasonable regulations that allow it. For example, Vermont allows onfarm slaughter for up to 40 sheep/goats.

Mobile units are another slaughter option, though there are fewer than 20 red meat units operating in the US (according to NMPAN). A few are operated by universities, e.g., Virginia State University and Delaware State University. Mobile processing units are subject to the same regulations as other slaughterhouses. In fact, sometimes it's harder for a mobile unit to get approvals.

The lack of USDA inspected facilities is often cited as a limitation to direct farm marketing and profitability of small farms. The PRIME Act was proposed as a means to allow meat from state and custom-exempt plants to be sold commercially. It is opposed by "Big Ag" and some advocacy groups because it would allow uninspected meat to be sold to consumers. The RAMP UP Act would provide funding to help state and custom-exempt facilities meet USDA requirements.

Covid-19 exposed the some of the weaknesses of the US meat supply chain, as just 50 plants process 98 percent of the meat in the US. There has been a very strong demand for local meat during the pandemic, with many backlogs in processing. The current "one size fits all" meat safety regulations put small producers and processors at a disadvantage.


05/10/2021

Additional reading
Meat Processing Laws in the United States: A State Compilation
In Defense of On-Farm Slaughter - Maryland Small Ruminant Page
Niche Meat Processors Assistance Network (NMPAN)
Onfarm slaughter: what you need to know - Rural Vermont
Infographic: Direct, Prime, and Ramp-Up Acts