Wednesday, October 23, 2013

Good Local Food and the Food Safety Modernization Act by Bill Duesing

The growth of the good, local food movement has been a real bright spot in Connecticut for at least a decade. Vibrant farmers markets have been growing in number and lengthening their seasons.  More Community Supported Agriculture farms (CSAs) connect consumers directly with farms and seasonal food.  College and school farms and gardens are expanding and new farmers, young and old, are looking for a meaningful life producing our fundamental need.  

We have a common interest in feeding ourselves and our communities with fresh, healthy, beautiful and safe produce. There is very little that has so many positive effects- economic, social, health, environmental, aesthetic- as the blossoming and vital local food movement.

But watch out:  Here comes the Food and Drug Administration (FDA) with Food Safety Modernization Act (FSMA) to slow all that down, maybe even stop it, if the proposed rules are allowed to stand.  We all have an interest in commenting on these rules. 

As currently written, the rules will:
• put many farms out of business;
• reduce the supply of fresh, local produce in schools and hospitals;
• push farmers to tear out wildlife habitat; and
•  increase the use of chemicals rather than natural fertilizers.
Remember in the 1990s when USDA said organic could include GMOs and use sewage sludge and irradiation?  Over 250,000 people commented and those proposals were withdrawn.

We need the same kind of response to FSMA. 

These regulations say that sewage sludge is fine, but if you use manure, you can't harvest for nine months, two to three times what USDA organic standards require.

The FDA estimates that its regulations will cost small farms an average of $13,000 and very small farms an average of $4,700 annually. Annually!


Of course we want food to be safe.  That is why for 40 years NOFA has been promoting organic methods which build health and prohibit synthetic pesticides and genetically modified inputs even though they are approved by the FDA. 

However, the same rules needed so that greens from a giant California farm can be processed, packaged in plastic, shipped across the country and still be "safe" (if a bit travel weary) to consume a week and 3000 miles later may be extreme and actually suffocating for local food.

FSMA is now the law of the land. We can influence the regulations.

The FDA is in charge of implementing this act and has proposed two rules to do that, the "Produce Rule" and the "Preventive Controls Rule." 

The "Produce Rule" is for growers and the "Preventive Controls Rule" is for food handling facilities.  However, a farm may be treated as a facility if it does certain things to what the FDA rule calls RACs - Raw Agricultural Commodities.   A CSA farm that offers produce from another farm as part of its share may become a facility and then be subject to the Preventive Controls rule, even if it is exempted from the Produce Rule by having less than $25,000 average annual sales for the last three years.  Farms between $25,000 and $500,000 sales are subject to modified requirements.

Although this is all complicated, dull, arcane, boring and it might be more profitable for us to be making compost, caring for our soil or harvesting in this climate-changed season, IT IS VERY IMPORTANT THAT LOTS OF US, FARMERS, CONSUMERS AND FOOD BUSINESSES, TELL THE FDA HOW TO IMPROVE THEIR PROPOSED RULES.

One of the best sources of information and links is the National Sustainable Agriculture Coalition or NSAC. (NOFA is a member of NSAC.) 

If you believe that the threat to local food is as great as has been expressed in hearings and meetings all over the region and are ready to comment, go straight to the NSAC site.  There you can learn more about the proposed rules and find helpful tools for making effective comments. 

The Summer 2013 issue of NOFA's The Natural Farmer is all about Food Safety.  Find that  TNF here.

Happily, the Produce Rule doesn't apply to home gardens, food consumed on farm or to food that is rarely consumed raw. 


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    Arnold Brame
    Health And Safety Consultant Peterborough

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