My husband, a beef jerky afficionado, tells me that C & I Jerky, Ltd. makes some of the best he’s ever tasted.
Ileene Nodland and Cheryl Knutson produce it themselves in Dunn Center, North Dakota, which had 170 residents during the 1980 census and has fewer now. Knutson started out making her special venison jerky, and then the two neighbors began using one or the other’s kitchen: spicing the meat, drying it (originally in an oven, later in a dehydrator), cutting it into strips with scissors, and giving it to family and friends. They perfected their recipe, and people loved it.
Then they got the idea of making a little more and selling it—starting a small business that wouldn’t cut into the hours they spend working their ranches with their husbands.
“We thought we’d probably need a license,” says Nodland. They called a lawyer, and he told them that since there was no sales tax on such food in the state and they wouldn’t need a sales tax license, they wouldn’t need any other kind of license, either. They called another lawyer, and he told them to call the State Health Department, and they said to call the U.S. Department of Agriculture—but the man they needed to talk to was on vacation. By that time they had decided to just go ahead and sell some jerky. “We figured that if we needed a license, they’d tell us and we’d get one,” says Nodland.
All this happened in the summer of 1984. In September of that year, after Knutson and Nodland had about $1,000 worth of jerky in 39 bars and stores spread over several counties, a USDA inspector called to say that their jerky was illegal because it hadn’t been inspected or approved by the USDA. Nodland and Knutson met with him and were told that they could get 10 years and a $10,000 fine for selling jerky outside the law. “They said we could give away all we wanted, but if we sold just one stick to a neighbor, we would be breaking the law—and they made it clear that they would prosecute,” says Nodland. The two were told to remove their jerky from the establishments that were selling it and advised that it would take from $50,000 to $100,000 to set themselves up in business correctly—figures that Nodland says are pretty close to the truth.
Here’s a short-form version of what C & I had to do, once they decided to take the plunge. First, they had to kiss goodbye all that companionable kitchen manufacturing and build a plant to government specs. Their building, finished in January 1987 after two years and a thousand miles of red tape, is 30 X 40 feet, and by law had to contain 11 steel doors. The building also had to include a meat inspector’s office of at least 70 square feet; just to be on the safe side, they gave him an extra two square feet, which means that his office takes up 6 percent of their floor space. They had to put in a men’s bathroom for him, even though he’s there for only a few hours a month, and their only employee is a third woman. His office had to contain a file and locker, both kept locked against Nodland and Knutson, and a desk.
“We put in the locker,” Nodland says, giggling a little, “and then one day the inspector that was over him came to inspect and told him that regulations say we also have to put up a coat hook, so he came and told us, and we had to put one up. We’ve also had the inspector over that inspector [i.e., the inspector’s inspector’s inspector], and I understand that we may soon be paid a visit by his inspector [the inspector’s inspector’s inspector’s inspector].”
One day the inspector told C & I that they needed a rodent-proofing plan. Nodland reminded him that their foundation went down eight feet into the ground, four more feet than the law required, and that Dunn Center had no rodent problem. He told her to draw up a plan showing where she would put rodent traps. “He said I had to put an ‘x’ on the blueprint wherever I would put a rodent trap, and that I could never put a rodent trap where I didn’t have an ‘x’ on the blueprint. So I cover that blueprint with ‘x’s, trying to be safe. Then he told me that I had too many traps on it,” Nodland sighs.
C & I is usually open from 8:00 a.m. to 10:00 p.m.; the hours after 5:00 p.m. are spent cleaning up. Business is terrific, and Nodland would like to hire a second shift. “But,” she says, “the law reads that if we’re actually processing the meat outside of eight-to-five weekday hours, we have to pay the inspector ourselves for his time.” At $24 an hour, that could really eat into their already small profits. C & 1 hasn’t had to pay the inspector yet because they don’t do any actual placing of jerky strips in jars after 1,700 hours or on weekends or federal holidays.
The meat they use has already been approved at the approved slaughterhouse, but “they also make us use approved products for everything connected with the processing, and that includes paper products, like waxed paper,” says Nodland. “We have to get a letter from the product manufacturer guaranteeing that the product is USDA-approved for use in food processing. But it’s very hard to find companies that are approved, and the USDA won’t give us a working list because they say they don’t want to ‘endorse’ any companies. So we have to use trial-and-error to find manufacturers that are USDA-approved and will go to the trouble of getting us a letter of guarantee from their home office.”
Beef jerky is what cowboys on trail drives used to carry in their saddlebags to snack on; by definition, it doesn’t need refrigeration. Still, the law said that C & I had to have a walk-in cooler in which to store their jerky in jars before they delivered it to the bars and stores to sit at room temperature. They installed a cooler but didn’t put the labels on the jars until they were ready to ship, because the humidity in the cooler made the labels wrinkle. (The saga of designing the label to government satisfaction is a story in itself) The inspector told them that they had to put the labels on before the jars went into cold storage, because the label shows that the jerky has been inspected.
“Except that it hasn’t,” says Nodland. “He never actually looks at the jerky. When we first opened for business, he sent some of our jerky away to be tested to make sure it was dry enough that it wouldn’t spoil, but he hasn’t looked at the jerky since then. I know he’s only following the rules,” she continues, “and I do believe that meat inspection is important. But if the USDA is trying to make sure of the quality of our jerky, wouldn’t you think they’d look at it once in a while?”
C & I goes through about 600 pounds of ground beef a week, less than is in the average supermarket meat section. Have Knutson and Nodland ever seen the bible of regulations that runs their lives? “Oh, yes, it’s about four inches thick,” Nodland says. “And when we complain about any of this, our inspectors say, ‘This is the law, and if you don’t like it, go to DC and get it changed.'”
I called the local office of the meat inspector in question, and he told me to call the USDA in Billings, Montana, and talk to a Dr. Bowman (I’m not sure of the spelling). Dr. Bowman answered all of my questions carefully, politely, and with skillful bureaueratese, explaining why all of this was necessary: basically, because the regulations say so. When we had covered everything, I asked him for his full name and title so that I could quote him. “Oh, you don’t need to do that,” he drawled. “I usually spell my name U-S-D-A o-f-f-i-c-i-a-l.”
Leave a Reply