Massachusetts Regulatory Issues

We've learned a lot about what it takes to create a CSF in the Commonwealth of Massachusetts.  Here's what we know:

• First and foremost, you need to be working with a federally permitted facility that can unload the fish and do all the necessary federal reporting to the National Marine Fisheries Service.  If your community doesn't have such an entity, getting that process started is a good first step.  This is one of the ways to start creating the infrastructure in your community that you may have lost.  It also allows the fishermen who have left the community to land their fish elsewhere to come back home.  Get in touch with the regional office of the National Marine Fisheries Service to find out what you need to do and go from there.  

• Although there is no statewide board of health requirements in Massachusetts, each community does have its own board of health.  In fact, before you do too much work identifying a site for delivery you should contact the board of health in the community you are interested in to hear about their regulations and needs. They will likely want to inspect the truck and issue you a mobile food vendor permit or the equivalent.  Some boards of health may not even need to permit you, but most likely will.  Never take this for granted, though, and call to be sure. So far, most of the boards of health we have become familiar with have required that the base of operation - the dock where the fish is landed, bagged, iced and put on truck for delivery - is properly permitted.  In addition, they want to make sure you have a seafood dealer permit for the operations and truck used to transport the seafood from the Department of Marine Fisheries.  They also want to know what the general procedures are for handling, storing and distributing the fish once it leaves the dock.  If you want some help thinking this through, get in touch with us.  We have included the application for the Town of Ipswich board of health on the bottom of this page for your reference.  We're suggestion you at this application because it seems to be a pretty universal one used by most towns.

• Once you get your first board of health permit, you need to get a seafood dealer permit from the Division of Marine Fisheries to transport the seafood from the dock to your shareholders.  The permit will allow you to transport anything but shellfish. This is a relatively simple process that will cost $65. You can download the application for a retail truck permit by clicking on this link.

• NOTE: A board of health representative might tell you that a retail truck permit is required to get a board of health permit.  But the retail truck permit requires that the truck be inspected by a board of health official first.  So it's a bit of a chicken or the egg situation.  Our recommendation is to contact the board of health first, explain to them that you are in the process of getting your retail truck pemit but need a board of health permit first.  It's likely they will accommodate you, but we can't guarantee that.  If they do, however, you need to make sure to get a copy of your retail truck permit to them as soon as you get it.  DON'T FORGET!

• Because a CSF allows shareholders - or customers - to pay in advance for shares of fish delivered in the future, no hawkers or peddlers license is required.  The Massachusetts Division of Standards treats a CSF like the Girl Scouts.  This doesn't mean you shouldn't contact your local community for any local permits they may require - including boards of health.  The beauty or agony of a Commonwealth is the freedom of each municipality to set their own rules and requirements.

The following is contact information for agencies we mentioned above:

Division of Marine Fisheries, 251 Causeway Street, Suite 400, Boston, MA 02114, Phone: (617)626-1520

Division of Standards, One Ashburton Place, Room 1115, Boston, MA 02108, Phone: (617) 727-3480

National Marine Fisheries Service, 55 Great Republic Drive, Gloucester, MA  01930, Phone: (978)281-9363