Small Scale Meat Processing

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**Update**

A reminder: If your facility processes deer, be aware of potential Chronic Wasting Disease (CWD). Privately owned landfills will not accept deer carcasses in areas affected by CWD unless confirmed the carcass is not infected with CWD. TWRA has more information on CWD as well as updates for areas (mostly West TN currently) that are impacted by CWD. If any processor needs additional information on CWD carcass disposal, please contact Jeremy Hooper with Solid Waste Management.

Poultry Specific Resources

As poultry is a significant small business in TN that is very widespread, even to the point of people having backyard chickens, UT-Agriculture Extension requested the SBEAP develop a more condensed synopsis for poultry processers. Please note that this would be in relation to a facility designed to do custom or retail processing of chickens as a business and does not necessarily cover all potential topics nor areas outside of environmental rules and regulations nor does it apply to household level processing of poultry for personal use.

Environmental Permits for Small Scale Poultry Processing
December 2015 publication from UT-Agriculture Extension on Managing Risks for On-Farm Poultry Processing
 

Small-Scale Meat Processing

Small meat processing facilities are generally regulated at the Federal level by the U.S. Department of Agriculture (USDA) and at the State level by the TN Department of Agriculture (TDA). However, there are several items to consider with relation to the environment in order to either start or operate a small meat processing facility in compliance with environmental rules. Some of these items may need planning or permit applications submitted several months in advance of beginning
construction. This page will outline some of the items as well as provide common resources supplied by TDA to meat processing facilities looking to get started in TN.

New facilities or existing facilities that may need renovations and/or new construction for conversion into a meat
processing facility may need to consider environmental impacts regarding:        

Construction of a New Facility or Expansion of an Existing Facility

  • Initial construction or renovation of a site
  • Construction of sources at the facility (boilers, incinerators)

Operational Activities

  • Drinking water
  • Wastewater disposal
  • Solid waste and / or offal disposal
  • Boilers, incinerators, other air sources

The planning stage for a new facility is the best time to determine what permits are required and allow time for applications to be processed and questions/concerns to be addressed. This will expedite your process so that when construction does start, it will begin in compliance. TDEC's Small Business Environmental Assistance Program (SBEAP) and Environmental Field Office staff are available to assist. Permit applications need to be submitted with certain lead times depending on the permit needed. For example, permit applications for beginning discharge or sewer system operation would need to be submitted 180 days prior to beginning the discharge. Public notice is part of the permit application process and is required before construction can begin. Some agricultural activities may be exempt from permitting.

A New Livestock Meat Processing Facility guidance document (updated 9/14/2021) has been developed to cover most of these topics, which also provides more in-depth details regarding  some areas.

In addition to State regulations, a facility would need to present the proposed project to their respective County planning and permitting department to comply with local ordinances. These ordinances can result in additional requirements or restrictions for a new facility. In particular, Davidson, Hamilton, Knox, and Shelby Counties tend to have more direct regulatory authority relating to environmental rules. If you are locating a facility in these counties, be especially aware of local requirements and rules.

Construction of a New Facility or Expansion of an Existing Facility

Authorization under the Tennessee Construction General Permit from the Division of Water Resources is required for soil disturbance greater than 1 acre or less than 1 acre if part of a common plan of development (ex: commercial or residential subdivision). Total soil disturbance includes, but is not limited to, the building footprint, landscaping, parking, driveways, and haul roads. General permit issuance by the Division of Water Resources may take up to 30 days after receipt of a complete application.

Authorization under an Aquatic Resources Alterations Permit from the Division of Water Resources is required for applicable alterations to streams and wetlands. Examples of application alterations include stream crossings for roads, an outfall to a stream, or filling in a wetland. General permit issuance by the Division of Water Resources may take up to 30 days after receipt of a complete application. Individual permit issuance by the Division of Water Resources may take up to 90 days after receipt of a complete application. The scale of alteration to streams and wetlands determines whether a general or individual permit is required.

An Asbestos Notification should be submitted to Division of Air Pollution Control (or delegated county’s air pollution program) if an existing structure will be demolished or renovated. This notice should be submitted at least 10 days prior to beginning work that would disturb asbestos containing materials. The Division will contact the applicant within 10 days of receipt ONLY IF the application is deemed incomplete. This notification should be submitted, even if there are no asbestos containing materials present to notify Air Pollution Control that the materials have been evaluated and found to be free of asbestos.

If the facility will have an air emission source, then an Air Quality Construction Permit application would be needed. Some common air sources that might occur at a meat processing facility are:

  • Wood or oil-fired boilers,
  • Natural gas boilers greater than 10 MMBTU/hr.,
  • Incinerator for leftover carcasses (as mentioned above in Solid waste/offal disposal),
  • or Potentially a smoking/curing operation.

The air emission source may be determined to be an insignificant source of air pollution, but this could only be determined if the information is sent to the Air Pollution Control Division (or delegated county’s air pollution program), usually in the form of a permit application with a request for determination letter. Air Pollution Control Construction permits should be applied for 90 days prior to beginning construction of the source.

Operations - Drinking Water

Drinking water may be sourced from the local municipal water supply or obtained from a well on the property.

If new drinking water lines are being constructed from the municipal water supply line to the facility, the Division of Water Resources must be notified of and approve this construction.

If drinking water from the local municipality is not available, a drinking water well may be installed on the property by a licensed well driller. The Division of Water Resources must be notified of the installation of the well. The licensed well driller typically completes and submits these forms to the Division.

Operations - Wastewater / Disposal for Sanitary and Process Water

If available, wastewater should be sent to the local municipal wastewater treatment plant. Contact your local municipality to learn if any pretreatment is required.

If connection to the local municipal wastewater treatment plant is not available, the facility can discharge sanitary and/or process water through a subsurface sewage disposal system (i.e., septic system) – provided adequate, suitable soil is available and an appropriate system is installed. Two applications should be submitted to the Division of Water Resources to use a subsurface sewage disposal system in this manner: an application for a Septic System Construction Permit is required to install a new system or modify an existing system, and an application for an Underground Injection Control Permit – Class V is also required.

A Septic System Construction Permit from the Division of Water Resources is required to construct a new or modify an existing subsurface sewage disposal system (i.e., septic system) to dispose of wastewater, either sanitary or process. Due to the biological composition of blood and offal, TDEC discourages sending these waste streams to the septic system. A Septic System Construction Permit application would be needed 45 days before beginning construction.

The Underground Injection Control Permit – Class V is required for anyone discharging industrial and/or commercial waste into a subsurface sewage disposal system. This application should be submitted prior to or in conjunction with the Septic System Construction Permit.

Subsurface sewage disposal systems are site-specific, and functionality and effectiveness are dependent upon a variety of factors, including soil type and amount of land. To determine what type of subsurface sewage disposal system would be most effective for your operations, contact your local TDEC Field Staff. A soil map may be required to assess the feasibility of a septic system on your site. Be prepared to inform TDEC Staff of all types of animals that will be processed, the proposed number of animals to be processed per day, and an estimate of how many gallons of water will be used per day for both sanitary and process water. Systems designed to support more than 750 gallons of wastewater/day require an engineered design. To assist with installation and soil mapping, here are links to the list of Permitted Installers and licensed Soil Scientists.

Operations - Waste / Offal Disposal

Similar to the process water, offal and carcass disposal will remain an issue following construction of the facility. Some options are:

  • Composting: The Division of Solid Waste Management can provide information on composting correctly.
  • Service provider: These would be services that haul off collected offal for proper disposal. TDEC does not provide recommendations for specific potential service providers. Often these could also do a pump and haul system for blood and process water.
  • Incineration: Installing an incineration unit may allow for disposal of offal and carcasses. An Air Quality Construction Permit application would be needed 90 days prior to installing the incineration unit.

Operations - Boilers, Incinerators, and Other Air Sources

Air emissions sources should have a construction permit prior to beginning construction on the source. Sources include boilers, incinerators, meat curing, and potentially others. If an air emission source requiring permitting receives a Construction permit, read the permit carefully. Some items to remember concerning construction permits:        

  • Construction permits are only valid for about a year or until start-up of the air emission source, whichever is earlier
  • A start-up certification may be required. It will be specifically listed in the construction permit if needed and what needs to be done to comply

Following construction of the source, an Operating Permit is required for air emission sources.

  • Operating permits should be applied for within 30 days of start-up of the source to replace the Construction permit with an Operating permit
  • Operating permits should be applied for 60 days prior to the expiration of the current operating permit 
  • Any required recordkeeping and reporting will be outlined in the permit

If your facility is a source that has not been permitted previously, even though it is an existing source, it would still need to go through the Construction Permit application step. Also, if a facility is expanding a source (such as replacing a boiler with a larger boiler or one that uses a different fuel), that would constitute reconstruction and require a new construction permit application. 

Additional Resources