Please submit comments on the proposed FDA Produce Rule
During the last year, we have written about the proposed “food safety” regulations many times. Now we ask every single one of our members to please submit your comments to the FDA. The deadline is November 15th. If these proposals go forward, they will require costly changes in production practices with little scientific justification and doubtful reduction in food poisoning outbreaks. Based on previous history with implementation of “food safety” regulations in the 1980’s, many family farmers will go out of business, and others will stop growing certain crops once full implementation takes place. Please take a few minutes to submit comments! We have been to FDA hearings and we do think that they might pay attention. The FDA is staffed by people who know little about agriculture. Those of you who are in touch with a local farm may have more expertise than many of them, especially if you read this newsletter regularly!
The web site of the Community Alliance with Family Farmers (http://caff.org/programs/foodsafety/fsma/) has all the helpful information that you might need, including instructions on How to Comment. There are two proposed rules. The rule that we have been writing to you about is the “Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption.” If you want to go straight to the comment site: (http://www.regulations.gov/#!submitComment;D=FDA-2011-N-0921-0199).
Here are some of the problems with the Proposed Produce Rule:
It is too expensive. In their analysis, the FDA admits that the cost of the Rule will reduce the ability of new farmers to start farms and will require some farmers to seek off-farm jobs to offset the financial burden. Weekly microbial water tests and the need for consultants and new staff on farms like Full Belly will mean lower wages for productive crew members and more employment for expensive consultants.
The Rule makes it more difficult to use compost. This is in direct conflict with the established federal Organic Program, even though Congress ordered that the new Rule should not conflict with it. The rule would require farmers to implement a 45-day interval between the application of compost on a field and the harvest of produce from that field. This is despite the fact that the compost would already have been required to be tested pathogen free. This burden on farms that use compost flies in the face of scientific data showing that soil treated with compost is more suppressive of human pathogens than soil not treated with compost.
The Rule makes it impossible to include grazing animals in a crop rotation. The Rule appears to require a nine month waiting period between the time when grazing animals have been on a field and the time that crops are harvested from the field. Full Belly has developed a rotation that includes grazing sheep and pastured chickens that are moved around the farm. The soil is tilled and a 120-day waiting period is observed after the animals leave the field and before a crop is harvested. We have been practicing this rotation for 25-years and believe that it results in highly fertile soil that is suppressive of human pathogens. Please tell the FDA that grazing animals are an important part of a healthy crop rotation. Taking all the farm animals off the farm and putting them in concentrated animal feeding operations was the reason that many of the serious human pathogens like E. coli O157 developed in the first place!
The Rule requires excessive water testing. Farmers using water from streams and lakes will be required to pay for weekly water tests, regardless of risk or cost. Water from wells will have to be tested every 3 months. The standard of water testing being proposed is not based on relevant scientific data.
The Rule should encourage conservation practices. Please tell the FDA that the Rule should encourage the use of conservation practices to address food safety issues. No more habitat should be destroyed in the name of “food safety.” The Rule should protect practices like installing native plant buffers for pollinator habitat that benefit both wildlife and food safety.
A large portion of the food grown on Full Belly Farm goes direct from our fields on one day to you, the consumer, the next day. You know where it comes from and there are no intermediaries. This limits any food borne risk to the general public. The short interval between harvest and sale limits the growth of pathogens after harvest. Because the produce is harvested by professional crews, by hand, if there were animal intrusion or quality problems, they would not harvest it. This is very different from leafy greens harvested mechanically from large fields.
Thank you for commenting to the FDA!
— Judith Redmond
