Do-it-yourself poultry processing made easy -- sort of
A Texas couple negotiates the permitting requirements for on-farm, small-scale slaughtering--including a commercial kitchen.

By Skip Connett

Advice on starting a farm business, from Ruth Noel:

• Start out small and grow gradually. Issues intensify with a full-time farming business, especially when you expand as fast as we did. Everything happens faster than you think it will.

• Before you expand, go through at least two seasons and establish a loyal client base.

• Build bigger up front. Anticipate you will grow and do better than you think.

• Have at least one full-time employee. You can't do it all yourself.

(For more information, Ruth can be reached at:

Commercial kitchen advice from Austin's Sustainable Food Center

Step 1 -- Investigate your market. Check out the markets you would potentially like to sell at. Would your product be a good fit? Would you fill a niche? Talk to the managers and see what kind of vibes you feel. Do your homework. Research is an entrepreneur's best friend.

Step 2 -- Find out what permits you need. The permits you need depend on the kind of product you are selling. Most food products are divided into two categories -- perishable and non-perishable -- and require different permits. Eggs and meat don't fall under these categories and have separate requirements.

Step 3 – Design your labels. You need proper labels on all your food items, regardless of whether they are cold or hot, perishable or non-perishable. Labels must include name of business, name and address of kitchen, and ingredients. You have two options:
• Individually label each item with ingredients and prices, or
• Create a "blanket label" for all items, using a menu. In the menu, each item must list the ingredients in order of highest to lowest quantity. Spices must also be included, especially salt.

Step 4 -- Call the County Health Department
Call the health department for permits and set up an interview. Be prepared to go over everything you are planning to sell and the process you will require. They want to see what you are making, how you are transporting, what containers you are using, how you will keep it cold or hot at the market…etc.!

June 16, 2005: Ruth and Denny Noel have agriculture degrees from Texas A & M, but no degree--except perhaps one in regulatory bureaucracy--could have prepared them for building an on-farm poultry processing facility and commercial kitchen.

As Ruth described it at the Texas Organic Farming and Gardening Association's 4th annual conference, building the facilities for their fledgling grass-fed poultry business required a lot of sweat equity and do-it-yourself ingenuity. Then came the hard part -- breaking through the red tape of state and local government regulations that keeps so many small farmers from trying.

Ultimately, the Noels built a state-certified meat processing facility and commercial kitchen for less than $10,000. In less than two years, they were processing up to 800 broilers a month, and had created such a strong demand at farmers markets and restaurants that they couldn't keep up with it. Indeed, interest in what they accomplished was so strong and the maze of licensing and code requirements so confusing that Ruth has nearly completed a how-to book to save others from the headaches they experienced.

"We couldn't believe what we accomplished," she says. "We had no one to guide us and there are so many farmers who want to do this but there is so much government intervention. What we found out is that anybody really can do it and it doesn't have to cost a fortune."

Gradual diversification; then going whole chicken

Twelve years ago, the Noels bought 23 acres about an hour south of Austin. Despite the credentials to call themselves "Aggies," the Texas A & M graduates had no farming experience. Ruth's childhood passion for outdoors and taking care of small creatures only intensified after college. Denny, who worked in the industrial equipment industry, was a handyman eager to apply his carpentry skills to creating their dream -- Tesoro Tierra Farms.

They built their house and barn mostly by themselves, and gradually added livestock -- grass-fed cattle, hogs, chickens and goats -- primarily for themselves and their friends. Three years ago, despite having two young children to home school, they decided to incorporate and create a full-time pastured poultry business. Having an on-farm processing facility would allow them to cut out the middleman and sell directly to farmers markets and restaurants at premium retail prices. A commercial kitchen would allow them to expand their markets by selling roasted birds, as well.

"It took off faster than we ever expected . . . When everything suddenly kicks in and you can start doing all this stuff, it can be overwhelming."

"It took off faster than we ever expected, especially after Denny lost his job -- that was something we hadn't figured into the plan," she says. "When everything suddenly kicks in and you can start doing all this stuff, it can be overwhelming."

Putting most of their eggs in the processing basket was a big risk, but they were determined to make that basket as cheaply as possible. There was just one problem. They knew no one who owned a state-certified production facility, much less a small, do-it-yourself kind. And the advice they received from state and local inspection officials could be confusing and contradictory.

"When we first started, everyone was so vague because no one was doing what we were doing and no one wanted to be liable," Ruth explains. "We heard everything. Some said you couldn't do a processing facility even if you were processing for someone else because that was considered customer processing. Others said we could only sell on-farm and not at farmers markets."

Fortunately, they met a state meat inspector who helped them map out the shortest route through the regulatory maze. "He saw the need for a small local facility and really led us through all the different steps and procedures -- what to say on the paperwork, who was responsible for what and in what order," she explains. "You've got to understand the different jurisdictions and the retail food hierarchy and you have to break it down."

As they quickly learned, a processing facility required one set of permits while a commercial kitchen required another set. Which ones you need depend on what county you live in and where you do business.

In Texas, the state's meat safety assurance division oversees meat processing facilities. Most commercial chicken processing facilities are high-output operations that must follow strict safety standards and a rigorous inspection process. Small, community-based processing facilities have become few and far between; too much competition and too many regulatory hoops discourage most small farmers from trying. And yet, as the Noels learned, there are exemptions that make it feasible. Facilities with less than 10,000 birds a year, for example, aren't required to have on-site inspectors to check each bird. The Noels also learned that they could get exemptions for handling effluent and waste by draining water back into the pastures and composting chicken remains rather than rendering them.

"You've got to understand the different jurisdictions and the retail food hierarchy and you have to break it down."

Meeting certification and inspection standards for both the slaughtering facility and the kitchen were just half the battle. Individual inspectors interpreted each jurisdiction's requirements differently. For example, one inspector told them it was against the law for a farmer to sell meat at a farmers market in his county.

"I told him I was already doing it, and he said I must be doing it under the table," Ruth recalls. "I called his office the next day and another inspector answered and confirmed that I could sell it. I don't know if he was new or just didn't know, but I was so mad I decided I needed to build a commercial kitchen, too."

A commercial kitchen, however, would require them to pursue another set of permits that relate to manufactured foods and retail sales.

Adding to the confusion, inspectors seemed to be arbitrary about what they focused on. Because they were selling at two different places in Austin, they were required to have duplicate permits. "The inspector yelled at me right in front of my customers," Ruth recalls. "He didn't check the temperature of my coolers or anything. He just wanted to see that piece of paper."

Selling the dressed chickens in surrounding counties was just as confusing. Because the Noels' county has no health department, they had to get a permit through the state. In nearby Travis County, the county's food licensing permit covered the city of Austin as well. But that wasn't the case two counties over, which Ruth learned the hard way when they tried to sell at a farmers market in the tourist town of Wimberly.

Building up the system -- from chicks to drumsticks

Based on their research and local customer preference, the Noels stayed away from heritage breeds (too many people believed their meat was tough, Ruth noted). Instead, they chose the fast-growing White Cornish Cross broilers, the industry standard meat bird that averages about 3.5 pounds by seven weeks.

They also selected the grass-fed model, using a mobile coop system popularized by Joel Salatin in his 1993 book, Pastured Poultry Profits. Denny built the mobile coops himself out of rebar instead of plastic pipes. The sturdiness allowed him to build them larger and withstand the daily rotations in the pastures. To accommodate the hot summers of central Texas, he built them taller than typical designs for the North, wrapping the hoops in chicken wire and covering the tops with plastic. Plastic skirts on the sides could be lowered during bad weather while an 80 percent shade cloth covering the roof protected them during the hot season.

Each of the seven hoop houses could hold up to 150 full-grown chickens, which resulted in a peak stocking rate of about one square foot per bird at full maturity. A brooder trailer wrapped in metal and outfitted with a ramp was a big labor-saver for raising the chicks until they were big enough to transfer to the mobile coops at about three weeks.

The birds were rotated on about four acres of pasture planted in a mixture of bahia and Bermuda grass. In late fall they also planted winter rye. The hoops, which measured 20 feet long and 12 feet wide, were attached with skids instead of wheels. Once a day, they were moved with a tractor another 20 feet so the chickens had access to fresh grass daily. Each section of grass fully recovers in about three to four weeks during the growing season, and their cattle feed on the lush grass that comes up through the chicken manure. The coops aren't returned to the same area for at least three months.

The Noels supplemented their birds with feed rations twice a day. They switched from an expensive national brand and made their own ration after Ruth got help from a nutritionist and found she could purchase the same essential minerals locally and much cheaper.

"We went round and round on the feed ration but at $35 for 60 pounds of supplement, we had to find something more economical," she says.

Ruth designed the 12 by 16 foot processing facility on her home computer, and Denny went to work building -- a cement foundation with proper drainage, metal roof, and wooden frame. State codes required separate rooms for slaughter and cleaning. They were constantly looking for ways to cut costs—from small items, such as using orange highway markers as killing cones, to converting a washing machine into a plucker and buying a sink from Habitat for Humanity. Ventilation and lighting requirements were easy to meet (they installed window-unit air-conditioning but no heating.) Although in retrospect the facility was too small, it was built for under $3,000, equipment not included.

Click on image for larger view.

Keeping track of all the sanitation steps required an elaborate checklist -- from sterilizing knives (they used standard restaurant ones) to cleaning drainage mats. Workers couldn't eat or smoke in the facility and had to wear head covers and smocks.

"The killing room is unpleasant, blood and mess everywhere," she said. "But it worked remarkably well."

Disposing of innards, legs, feathers and other unused parts requires expensive rendering facilities at big commercial processing plants. Here, they simply carried offal buckets out to large, fenced-in compost piles and mixed them with moldy hay. The state also approved their system for draining processing water into a nearby pasture.

Hitting their stride, then a bad spell…

At the peak of their business, the Noels were processing 800 chickens a month. Their main customers were restaurants and farmers markets in Austin, where they were charging up to $2.50 a pound. They were so busy that they never had time to start roasting the chickens in their kitchen. "We took the birds to the farmers markets and it worked incredibly well," she says. "The demand was greater than we could keep up with."

Unfortunately, so was the work.

After getting hit with a wave of bad luck, the Noels decided to scale back late last year. Ruth's father, who lives with them, fell ill and had to be hospitalized. Denny needed surgery for a double hernia. A death in the family and multiple bouts of flu were enough to force them to stop and consider their options. For the first time, their farming business had broken even (annual sales included about 6,000 broilers, 4,000 dozen eggs, 100 turkeys, and 40 head of cattle) but the pressures of farming and caring for family weren't sustainable.

"We took the birds to the farmers markets and it worked incredibly well. The demand was greater than we could keep up with."

"Our biggest mistake is we didn't have enough operating capital," Ruth says. "We really needed at least one full-time employee."

Neither she nor her husband regrets their attempts to battle government bureaucracy. Just proving that a small farmer can raise, kill, and sell broilers themselves -- and do it legally -- was a major accomplishment in itself. "Anybody can do it," Ruth says. "People say the government won't let them, but I came to realize that the government isn't the enemy."

Steve Bridges, president of the Texas Organic Farmers and Gardeners Association, invited Ruth to speak at the TOFGA conference this year because the Noels showed that this gap in local poultry production could be filled.

"Their ability to get this processing facility built and licensed was remarkable and something we wanted to share," he says.

This month, the Noels have put their farm up for lease and are moving to nearby San Marcos to regroup and simplify their lives. "We'll be getting back to farming when our kids are older and the timing is right. This isn't over. We love farming too much."