Protect Small Farmers and Healthy Food
Congress is debating new legislation that would give the Food and Drug Administration (FDA) wide-ranging new authority over farming practices and food production. The House has already passed a bill, HR 2749, and this month the Senate will take up its version, S 510, which is co-sponsored by NC Sen. Richard Burr. With or without a new law, FDA is moving forward with rules on produce safety on the farm, and already has authority to require food producers to register with the federal government. These initiatives treat small farms, organic agriculture and local food businesses as if they are giant corporate food processing companies, an approach that will crush the community food movement.
Pathogen contamination in food has been making regular headlines for four years now, beginning with the2006 E. coli O157:H7 outbreak in California spinach. The tragic deaths that have resulted from these incidents, while relatively small in number, have caused deep public anxiety because they threaten assumptions about the security of the "Food Inc." system that Americans depend upon.
The impacts of these incidents on agribusiness have been substantial. Sales of California spinach have yet to recover to their 2005 levels. Seeking to win back trust, large food processors and retailers have allied with consumer groups to promote a framework for pathogen control that relies heavily on paperwork, inspections, and limited knowledge about where pathogens come from in the first place. That approach is embodied in the U.S. SenateÕs current "food safety" bill, S 510.
Healthy Food Should Be the Goal:
To be truly healthy, food must be more than merely free of toxic bacteria and viruses.
As documented in films like Food Inc., large corporations dominate our food supply. One consequence is that a contamination incident at one point in the long industrial supply chain can cause widespread pathogen exposure, affecting thousands of people in communities nationwide. Just one mistake anywhere along the line from vast vegetable farms in California or Mexico, through packers, distributors, processors, reprocessors and onto store shelves becomes magnified into a multi-state crisis.
Local food systems mitigate food safety risks because they shorten the supply chain and emphasize fresh, unprocessed foods, which translates into fewer opportunities for food to become contaminated in the first place. Organic farming practices establish healthy soils and living buffers between livestock, waterways, and crops that have been shown to naturally limit pathogen transfer to foods.
The benefits of local, organic-based food systems go beyond pathogen control. They promote better nutrition and community food security by providing fresh, naturally-raised foods to combat epidemic obesity and chronic disease; they reduce dependence on costly and toxic agrochemicals; they provide income security to farmers and rural communities; and they protect the resiliency of agricultural crops by preserving biological diversity.
Why S 510 Would be Bad for Healthy Food:
The proposed federal legislation would crack down on abuses at large-scale food processing companies, such as the egregious health code violations uncovered last year at Peanut Corporation of America. Unfortunately, the bills apply the same standards to corporate soft drink manufacturers and community-based farm food entrepreneurs alike, imposing costs that the small business cannot survive.
Small and Organic Farms.
The bills give FDA authority to establish and enforce "safe" crop production and harvest practices. FDA already publishes voluntary Good Agricultural Practices (GAP) guidelines, which will be the starting point for new food safety regulations. Unfortunately, many key GAP protocols lack scientific basis, and the economic cost of complying with those unfounded mandates are devastating to small and organic farms. In some cases they even contradict organic certification rules.
One major problem area is that wild animals are treated as a risk for contaminating produce in fields. Proof of this claim is lacking, but that does't stop GAP inspectors from penalizing growers who don't install costly fencing to keep nature out of fields. Redundant paperwork, useless water tests, production lost to irrational field border requirements, elimination of natural fertilizer options- the cost quickly skyrockets for the small family farm.
Local Food Entrepreneurs.
The bills would require every "food facility," including on-farm food processing and start up local food processing and distribution businesses, to establish and maintain a Hazard Analysis and Critical Control Point (HACCP) plan. The financial costs of such plans are easily borne by large corporate processors. Small businesses would be smothered. One small farmer estimated the cost of the HACCP mandate to his on-farm creamery at over 100 hours of labor, plus at least $15,000 per year. For comparison, over 90% of the small food businesses that use one shared-use commercial kitchen facility in Asheville, NC gross under $50,000 a year.
These threats are unjustified when the science of food borne illness is so incomplete. Researchers have not adequately addressed the role of contamination along the supply chain, leaving a major gap in our understanding of food safety risks. And S 510 places the burden of that uncertainty on small farms and businesses instead of the industrial food supply chains that are implicated in most food-borne illness incidents.
What Farmers and Small Businesses Need:
Farmers and small food entrepreneurs want to protect their customers. Indeed, they have very direct, personal links with the communities they serve. Being linked to a food-borne disease outbreak puts a small business out of business. These producers do not want to be exempted from the food safety system, they want knowledge and training on how to do the best job they possibly can, and we must make sure they have that information.
What We Can Do to Protect Small Farms and Local Food:
We need to amend S 510 before it goes to the Senate floor for a vote. Contact your U.S. Senators and Representatives and ask them to defend small farms and local food with these key changes:
Require FDA to write new, more flexible rules for small businesses. Producers with gross profits under $750,000 are small businesses, and already subject to state and federal regulation. S 510's new on-farm and HACCP rules should not be applied to these local food businesses.
Establish USDA training programs for small farms and food entrepreneurs. Ask Senators to include S 2758, the Growing Safe Food Act, into S 510, and fund programs to get critical food safety information into the hands of small food producers. This is the best way to ensure the safety of local food.
Eliminate pointless traceability rules for farmer-marketed products. Foods sold by farmers directly to consumers, restaurants and retailers should be exempt from national barcoding systems or other schemes meant for tracking products through the "Food Inc." supply chain.
Focus on real animal risks, not wild animals and working farm dogs. FDA should use proven science to identify animal vectors for pathogens and appropriate control mechanisms, instead of the current approach of treating all "animal encroachment" as a food safety threat.