Hard at work for several years, regulators at the US Food and Drug Administration (FDA) have been writing rules and regulations that some say are the most sweeping reform of our ‘food safety’ laws in 100 years. ‘Food Safety’ in this context refers to prevention of food borne illnesses, and the Produce Rule (finalized in 2015) sets on-farm standards that will apply to all farms growing fruits and vegetables.
Many farm-based organizations like National Sustainable Agriculture Coalition, and California’s Community Alliance with Family Farmers, mobilized volunteer and community leaders to advocate standards that were realistic on the ground and consistent with principals of sustainability. These groups argued that there was too much focus on keeping wildlife off of the farm; too great an effort to eliminate the use of animal-based soil fertility (like compost); and unrealistic requirements to document every detail of vegetable production.
On the other hand, California’s large handlers and processers advertised to the public that their food was the safest in the world. They cut down wild plants along farm borders and spread poison to make sure that wildlife would never get near their lettuce and fresh cut greens. They limited visitors on their farms. They eliminated the use of animal-based fertilizers (composts for example) for fear that the bacterial contaminants that originated in confined animal feeding operations and now make people sick, might somehow still be present in heat-treated or composted animal waste.
But the sustainable agriculture groups pushed back, citing research that proves that soil rich in microbes are the best line of defense against food-borne pathogens, while the bleach-treated plastic-bagged-fresh-cut-salad-greens industry is in fact a frequent cause of food-borne illness outbreaks. The sustainable agriculture movement declared that treating produce with chlorine bleach is actually not a path to health!
The FDA (now the arbiters of how produce should be grown in order to be ‘safe’) listened to scientists and famers, and removed the prohibitions about compost from the Produce Rule, saying that they would conduct additional studies. They made other improvements and then finalized the new standards.
The burdens of the Produce Rule are falling heavily on family farms. The processors and handlers have successfully shifted responsibility away from themselves convincing the public and the regulators that the farm with its dirt and dust and on-the-ground logistics, is the place where the ‘food safety’ problems all start. Even consumer groups were caught up in the rhetoric, with some suing the FDA to hurry up and get the Produce Rule implemented in order to (supposedly) prevent future illnesses.
Now that the Produce Rule is law, one would hope that the produce industry would pay some attention to the improvements won by the hard work of the sustainable agriculture groups. But the dye was cast years ago. The wholesale buyers want every farm that they purchase from to get audited by a third-party to make sure that the farmer is up to snuff. The audits still treat compost like a dangerous substance, requiring onerous procedures before it can be used.
At Full Belly Farm, we want to be a community-based farm. We want people to know as much as they can about the food that they eat. We invite people to the farm regularly. We farm in relationship to the people that have an economic, environmental and community stake in our activities. Here are some of the questions that our auditor will ask us:
“Are you taking measures to control access to your growing areas?”
“Have you posted ‘No Trespassing’ and ‘Restricted Entry’ signs?”
“Are entrances to farm roads restricted by gates, chains and guard stations?”
“Are grounds and facilities monitored by contracted personnel?”
We are going to answer “NO” to each of these questions and we will lose audit points each time. But we are not going to fundamentally change the philosophy of our farm model in order to satisfy misguided marketing efforts by the produce industry. The auditors are enforcing standards developed by the “industry” rather than standards developed by the FDA.
Farm-based organizations will continue to monitor these developments and will certainly continue to keep farmer friends as informed as possible. Stay tuned! We thank you, as always, our CSA members, for your support of our farm.
–Judith Redmond
