This is something that ALL Missouri Beekeepers need to be concerned about.
At the fall Missouri State Beekeepers Association meeting we had a breakout session titled “Keeping Bees and Selling Honey in Missouri:
I was not in this session as I was in a Queen rearing class.
The following is a part of a report in the news letter about this session.
(( First came a spirited discussion about the definition of “food processing”, which a couple of questioners defined, in the conventional
way, as the making of a food product by mixing or modifying ingredients - leading them to wonder what it has to do with the
bottling of pure honey. The Health Specialist however, defined the term much more broadly to include virtually any handling of a food product.
As such, she said, “honey processing” is subject to state regulations requiring an “inspected kitchen” - except in cases where the product
is to be sold directly, and in person, to the end user. What difference does it make, someone asked, whether it’s sold directly or indirectly, when it’s the same honey, in the same bottle, with the same label? The Health Specialist responded that if you sell directly to the consumer, he or she can ask you questions about the product. But even then, she added, the law requires the product to contain a label stating that it was not inspected by the state.
As for honey processing, it isn't just bottling, said The Health Specialist; it begins at the point when a frame is uncapped. “So it doesn't apply to comb honey?” one man asked. Actually it does, she clarified, as you are cutting the combs out of the frame for packaging.
“So Ross Rounds are okay?” someone else asked, noting that these are self-contained and would thus fall outside that definition. Nope, came
the reply - just removing it from the hive counts as processing, as that exposes it to an environment where it could become contaminated.
All stages of the operation, therefore, need to be conducted in an inspected kitchen.
She was then asked about picking apples from a tree; isn't that food processing too? No, she said, as the apple is still the same as when it
was on the tree. Packaging of uncut fruits and vegetables does not fall under guidelines on food processing; only once they are cut do they
become subject to regulation.
Regarding the criteria for such an “inspected kitchen”, The Health Specialist did say that it was not the same as the “certified kitchen” required in a restaurant or bakery. Through a series of questions, we established the following stipulations: The kitchen can be located in one’s home,
but must be separate from the primary home kitchen, and must include a separate hand-washing sink, washable walls and ceiling,
and a floor drain. If a separate building is used, it must include its own bathroom, and all sink and floor drains must be connected to a proper sewer or septic system.
Someone in the audience asked the same question I had asked during my first phone conversation with The Health Specialist: Why the distinction between the product I sell direct and what I sell through a third party, when it’s the same honey? She gave him the same response she’d given me that the direct buyer can ask the seller questions about that honey. I didn't get it then, and I don’t get it now. ))
This is NOT the complete report only parts, there is allot more.
This means I cant extract my honey at home and sell it in containers for resale or bulk with out having to pay someone else to do it.
( All stages of the operation, therefore, need to be conducted in an inspected kitchen. )
According to what was stated they are wanting us to move our hives to the kitchen to remove suppers.
I don't know were to go with this but it has me concerned!
I am going to start by contacting some of our state reps but I'm not sure how to go about what to ask or say?