Visit from Department of Ag
We had an unexpected visitor on the farm yesterday. An inspector with the Department of Agriculture Division of Weights and Measures came by to do an egg inspection. This is a first for us. Although we’ve always had an egg retailers license, we’ve never been inspected.
Of course we passed inspection but I was informed that we need to have a second license, a dealer’s license, since we’re selling our eggs at a location other than the farm. This was news to me. The license application states that a dealer is someone who buys eggs from a producer in order to sell to another dealer or retailer. That doesn’t apply to us. We are a retailer which, by the application definition, is a producer who sells direct to consumer. But, as I discovered, buried in the Missouri Egg Laws and Regulations publication is one little line I had never seen. “A producer, who sells to consumers at a place other than their residence, needs to purchase a dealer’s license in addition to a retailer license.”
Okay, fine, I can deal with that. With the small volume we sell it’s only an extra five dollars a year. The inspector also informed me that in addition to having our name or license number on the cartons (our name is already on our labels), we have to mark the “packed on” date. Okay, no problem. He said I could hand write it on there. That will only take a few seconds more when putting the eggs in their cartons. But then came the kicker.
“You also have to put the size and grade on each carton,” he said. Excuse me? For those of you not familiar with what it takes to size and grade an egg, here’s a brief explanation.
The size of eggs range from Peewee to Jumbo. It really doesn’t have as much to do with the physical size of the egg as it does with the weight. Each size has it’s own weight requirement. Generally this is done by the dozen or, in the case of large producers, by the case. So a dozen Peewee eggs will weigh a minimum of 15 ounces while a dozen Jumbo eggs will weigh 30 ounces. An experienced egg person can package eggs by size pretty much by sight and then weigh the whole dozen to be sure it’s in the right class. Most of our eggs are considered Large; some are Medium, some are Extra Large. We have a scale and can weigh each carton to be sure it meets the minimum requirements for each class, but that’s an extra level of sorting and weighing that we don’t currently do. We could also buy an egg scale that will weigh each individual egg to tell us the size, but I’m undecided on that at this point.
Now for the grading part. Grading an egg involves candling. Candling is when you shine a light through the shell of the egg to check for the quality of the egg. Generally we choose eggs at random to candle to be sure we don’t have any major imperfections. I also candle the eggs we are incubating to check the progress of the chicks. But, when you are candling to grade eggs there are many more things you are checking for. For grading purposes, you are checking the interior quality of the egg as it is twirled in front of the light. The first thing you check for is the size of the air cell. Each egg has an air cell which gets larger the older it gets (in the case of Jumbo eggs, it starts out a bit larger than other eggs). For example, for grade AA eggs – the highest quality according to the USDA - the air cell cannot exceed 1/8 inch. Most of our eggs will candle at grade AA because they are so fresh. Some eggs are layed with a larger air cell naturally and those would be considered grade A.
When grading eggs you are also checking for the viscosity of the white, the firmness of the yolk and the quality and condition of the shell. Needless to say, having to grade each of our eggs is going to add a significant amount of time to our daily routine. I’m all for food safety and accountability. But for a small producer this is really going to affect how we do things. Weighing and candling the eggs will require me to have a set up in our kitchen with a more sophisticated candling device and a scale. Our counter space won’t allow me to leave this out all the time (nor would I want to stare at it all day) so it will need to be set up and put away each afternoon. It’s going to triple the amount of time I spend each day packing the eggs. And is it going to affect the quality of the eggs we sell? Not in the least, since our eggs are already very high quality.
Unfortunately, this means we may have to start charging more for our eggs. I think it’s ridiculous, but in order for us to recoup the time spent on these extra steps I may not have any choice. We’ve never raised our egg prices – they’ve always been 3 dollars per dozen – but the Department of Ag may leave me with no choice. In addition, I can’t sell any eggs at farmer’s market until we get our new additional license. 
I have mixed feelings about all this. Again, I’m all for food safety and accountability. However, this is one more example of why it’s so hard for small family farms to survive and still be able to provide healthy, wholesome foods to their customers. I think if you sell less than a certain number of eggs per month there should be some exceptions. As long as your containers are clearly marked, so the health department can track you down if someone gets sick or has a complaint, then I don’t see why they need to be graded. Most customers who buy eggs at farmer’s market or straight from the farm don’t expect to see a ‘Grade A’ label on their eggs. Well, you’ll see it now.
~Karin