View Full Version : This year could be it for me. Thanks FDA
I am seriously thinking of just selling sap after this season. Supposedly by next year, since I sell over 50% of my syrup wholesale, I will have to comply with FDA regulations. Now, my equipment is top notch, as is my sugarhouse. However, there is no way I will be investing in a new septic system, restaurant compliance bottling area, worker washrooms, and all of the other bs that I hear will be required. Another option will simply be to downsize my ro , tap less trees, and sell retail. However, I hate to retail syrup.
Parker
02-11-2018, 05:45 AM
We were all supposed to be registered and 100% compliant last year.....
I made the boneheaded move of registering a couple years back when I thought we had to.
karl evans
02-11-2018, 08:27 AM
I am seriously thinking of just selling sap after this season. Supposedly by next year, since I sell over 50% of my syrup wholesale, I will have to comply with FDA regulations. Now, my equipment is top notch, as is my sugarhouse. However, there is no way I will be investing in a new septic system, restaurant compliance bottling area, worker washrooms, and all of the other bs that I hear will be required. Another option will simply be to downsize my ro , tap less trees, and sell retail. However, I hate to retail syrup.Let's keep hopiñg common sense will win out. There's to many voices in the maple industry now, with no knowledge of the maple business. This is one time when experience making syrup should Trump what some big gov't supporter has to advocate. Such a safe product.
maple flats
02-11-2018, 09:03 AM
Retailing everything is not that bad. Get a good website and then give it time. I retail everything except any commercial I may get at the end of the season generally.
I now sell about 40-45% off my website and the rest is sold from the sugarhouse mostly in season and from my home (to repeat customers, my city won't even let me put up a sign because I'm in a residential zone). I do not do farmer's markets anymore, only did one for a year in the past and decided it was not worth the cost for the space and my time.
A workable plan might be to just make enough to retail what your demand is and as the demand grows increase the amount you produce, and sell the rest of the sap to another producer.
Once you get the retail end working for you your profits will be higher, that's why I do it.
I did cut down on my production, only because I lost my help, but I now essentially run out just as the new season arrives.
I do retail on avarage 60-75 gallons out of 300 a year. I would need a better bottling setup. I only have a propane fired 7 gallon bottler, and would need to step up to a 16 gallon electric water jacketed bottler I guess.
Sugarmaker
02-11-2018, 09:32 AM
Jason,
We make a food product. If it goes to the public your concerns are valid. It may or may not be soon but regulations might drive out the small maple producers due to the cost of improvements to meet all regulations. I thought 20 years ago maple was going to die out due to lack of interest. Now I think it could be doomed by government regulations which are intended to protect us.
Time will tell. I have had similar thought as you. Don't give up yet!
Regards,
Chris
buckeye gold
02-11-2018, 03:10 PM
heus, where did you get your information from? This is the first I have heard of this. I did not attend Maple days this year to see what Regulations had changed, but I did check Dept of Ags web site and did not find any changes. It really doesn't affect me as I retail everything. who's checking what percentage you sell where?
Thompson's Tree Farm
02-11-2018, 03:42 PM
I am seriously thinking of just selling sap after this season. Supposedly by next year, since I sell over 50% of my syrup wholesale, I will have to comply with FDA regulations. Now, my equipment is top notch, as is my sugarhouse. However, there is no way I will be investing in a new septic system, restaurant compliance bottling area, worker washrooms, and all of the other bs that I hear will be required. Another option will simply be to downsize my ro , tap less trees, and sell retail. However, I hate to retail syrup.
Please, before everyone goes off the deep end, check on what is required. I see nothing about a restaurant compliant bottling area or worker washrooms. Let's be sure we know what is truly coming down the pike before we go by what we have "heard" Are you a member of your state association? What are they telling you? Maple is a "low risk" product and as such is way low on FDA's radar.
You need to check, but I believe that they have put implementation of the rules on hold for now.
It was in the Maple News recently
buckeye gold
02-12-2018, 07:12 AM
Here is a link to current information from ODA and OSU ext
https://s3-wp-lyleprintingandp.netdna-ssl.com/wp-content/uploads/2018/02/01190032/Ohio-Maple-rules-regs-2018-FINAL.compressed.pdf
Buckeye thanks for the link. I have no problem with the Ohio regulations. The federal FDA regs, however, are as clear as mud to me. I tried looking through some of it, and yes, employee washrooms were in there. As well as approved septic systems. I didnt look hard enough to find the restaurant bottling area regs.
markcasper
02-12-2018, 07:01 PM
Buckeye thanks for the link. I have no problem with the Ohio regulations. The federal FDA regs, however, are as clear as mud to me. I tried looking through some of it, and yes, employee washrooms were in there. As well as approved septic systems. I didn"t look hard enough to find the restaurant bottling area regs.
I think your reading far more into this than needs be! I read a part in the link about "floors must be concrete, wood, or gravel." If this is true as I read it, I can't imagine being able to have a employee washroom and septic......and being able to have that while having a gravel floor. For the government to crack the whip this hard and fast seems unlikely. They know they have to roll this out very, very slowly without people catching on, or they will have a revolt on their hands. (With that being said, there is no lack of information reporting that the purpose of the FSMA of 2011 is designed to shut down the small producers.) You can choose to believe or not believe, but personally I think it holds some water. The government is known for wanting fewer, bigger, and consolidated everything....easier to control.
Wisconsin has been the strictest state for inspections as far as
I know....and has been for years.
I could never figure out how Vermont and other states were able to skirt food safety inspections as long as they have. In Wisconsin its pretty cut and dried, you have always needed a license (food processing license) if you sell to another party for reselling, (not including bulk sales to packers until about 8 years ago when this also started.) There is no "exemption" for producers that tap 75% or more of their trees as was stated in the summary. You guys are lucky!
Mark the link you mentioned (gravel floors, 75%...) applies to ODA rules. I am more worried about the federal (FDA) rules. There is something called national supremacy. Federal law supersedes state law when in conflict with each other. It doesn't matter what Ohio's regulations are if the federal government wants to supersede them. Yes, I m probably overreacting. On the other hand, I also wonder why people are not reacting enough.
markcasper
02-12-2018, 07:36 PM
Mark the link you mentioned (gravel floors, 75%...) applies to ODA rules. I am more worried about the federal (FDA) rules. There is something called national supremacy. Federal law supersedes state law when in conflict with each other. It doesn't matter what Ohio's regulations are if the federal government wants to supersede them. Yes, I m probably overreacting. On the other hand, I also wonder why people are not reacting enough.
I can't comment on the national supremacy, you may be right, maybe not? All I can tell you is what happened here in Wis. Two years ago the state inspectors really started to crack the whip, actually it was in 2012, and then they didn't come for an inspection for three (3) seasons! All the while I was getting the yearly license (sent them the $95) without having an actual inspection done. Seriously!!?? In the just of all this, it became apparent to many producers that the consistency between inspectors, and even the consistency with the same inspector between different producers was very much different. (favoritism) IMO.
In the summer of 2016, the state Dept. of Ag held forums around the state.....primarily because of the new grade issue, but also for the public to comment on the force that seemed to be in the barrel of the inspections. A big part was not being able to keep and use RO water for anything, even cleaning the membrane. In a nutshell, ADCTP 87 was born out of this which relaxed many of the brute force requirements that were required for say a cheese plant. Where this is all going? I don't know? I do know the state is and has been charged with carrying out the FDA guidelines. The problem is neither organization is staffed enough to get all the inspections done. Two springs ago when I questioned the inspector as to why no inspection had been done at my facility for the past 3 years before, even though I sent in my money, his reply was to blame Scott Walker for cutting too many government employees and benefits, and not replacing retirees within the department..
buckeye gold
02-13-2018, 06:02 AM
Ohio Dept of Ag has the contract with FDA to do inspections for them. They are actually on our side (ODA) and will be reasonable. I got that right from the horses mouth. I see no mass sweeping action in the near future, when it happens it will be much like Wisc., I suspect.
Powered by vBulletin® Version 4.1.7 Copyright © 2024 vBulletin Solutions, Inc. All rights reserved.