When I first heard the term “food safety” I knew that even the term itself was a problem, representing an approach to our food that calls lettuce bathed in chlorine “safe” and lettuce with a speck of dirt on it “contaminated.” Now, a few years later, years during which we have been trying to develop a reasonable Full Belly solution to the “food safety” demands, it is still easy to characterize “food safety” discussions using opposites and absolutes — industrialized, chemical-laden, sterile approaches to the food system on the one hand, and agrarian, biologically-based, ecological approaches to the food system on the other.
Family farmers knew that the discussion was going to be a difficult one when it started in earnest several years ago and they saw many of the organizations that should have been their friends melting away and coming out in favor of the chlorinated-food approach. Saying that you didn’t want to bathe your food in chlorine was held to be tantamount to saying that you wanted to kill young babies with their spinach smoothies. No one wanted to be critical of “safe food.”
After the E. coli O157 outbreak on bagged spinach, produce handlers, insurance companies and produce buyers became a united front, clamoring that the food coming to them from farm fields was “contaminated” and that the farmers needed to clean up their operations. Packing operations, being much more controlled environments than farm fields, were purported to be less “risky.” An army of consultants grew up to advise farmers on everything from “food-safe” toilet etiquette to correct produce picking techniques.
So, with support pretty much across the board, except for notable exceptions and qualifications from family farmers and their organizations, in January 2011, the Food Safety Modernization Act (FSMA) was signed into law. The FSMA gives the Food and Drug Administration new powers over farming operations — they can arrive unannounced, they can seize your computers and records, they can bear arms, they can arrest you. All this being necessary in case you, the farmer, are endangering the “safety” of the public, with supposedly sloppy farming practices.
After a two-year wait, the proposed regulations to implement FSMA have been released for public review. Overall, we may be better off with the FDA’s attempt at a measured approach rather than the unbridled arrogance of the produce buyers and handlers whose auditors continue to tell farmers to remove all native vegetation, pull out trees that might harbor birds and eliminate bat and owl habitat.
We encourage others to join the discussion since what it may boil down to is a balancing of tradeoffs. Potentially deadly pathogens do exist in the food system, most of them born and bred in concentrated animal feeding operations where antibiotic use runs rampant. Once released into the environment, these pathogens must be managed, but at what cost? If the hoops and hurdles are too expensive, they will result in an even more bifurcated food system in which middle and small-scale farmers absolutely cannot contemplate the audits and requirements of the big buyers.
At Full Belly, we have complete confidence in the “safety” of our ecosystem approach. We think of a sterile soil and a sanitized surface as an invitation for microbial invasion. We view a healthy soil as one that contains a diversity of microbial activities that can resist pathogenic organisms time and time again without repeated chemical treatments. We protect against plant diseases first with diversity and attempts to enhance the beneficial microbes that may be present, before spraying poisons.
Again, the public should weigh the tradeoffs. A war on microbes with a battery of antibiotics, sanitizing chemicals and poisons? Or faith in the integrity of natural processes that remain a mystery to science, so diverse and complicated that they don’t yet submit to generalizations. A review of the science that does exist reveals that it is uncertain on many questions that farmers have about how to approach “food safety.”
The FDA-proposed rules, while generally reasonable, have potentially wrong-headed sections on compost, water testing for pathogens, and grazing animals. Fact sheets, an overview, and the full text of the proposal (547 pages) are available on the FDA’s website, with public comments due 5/16 (possibly later, since this deadline may be extended). Full Belly will be submitting comments, and participating with CAFF (Community Alliance with Family Farmers) in the development of a general letter to the FDA. We will keep you informed!
— Judith Redmond
