Please read this important leather from my friend Judith Redmond of CAFF We are writing to you about an issue that is very important for all of us -- farmers and community members -- to understand. We are asking you to help by submitting comments to support your local family farmers. The Food Safety Modernization Act (FSMA), passed by Congress in 2010, gives the Food and Drug Administration (FDA) broad powers over how farmers grow fruits and vegetables. We think there are some very serious problems with their proposals and since the deadline for submitting comments is November 15, we are writing to you now. The FDA Proposed Rule seeks to reduce food safety problems, but their proposals dont get anywhere near the heart of the matter. The regulations are being developed by buyers, manufacturers, processors, handlers, auditors and now the FDA and all of them are trying to place 100% of the responsibility for food safety on the farm. The proposed FDA Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption have a number of problems that sustainable agriculture advocates, including both farmers and consumers are very concerned about. The website of the Community Alliance with Family Farmers has all the helpful information that you might need, including instructions on How to Comment or you can go straight to the comment site. There are two proposed rules, make sure that you comment on the Produce one. If the proposed Produce Rule goes forward, it 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 1980s, 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! 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 them! Here is an example of comments that you could submit directly onto the government website: It would be best if you could personalize the comments to reflect why you think they are important. The proposed Rule is too expensive. The cost of the Rule will reduce the ability of new farmers to start farms and will require other family famers to seek off-farm jobs to offset the financial burden. Weekly microbial water tests and the need for consultants and new staff will mean lower wages for productive crew members and more employment for expensive consultants. The proposed 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 FDA should eliminate the requirement for a 45-day interval between the application of compost on a field and the harvest of produce from that field. The waiting period is unnecessary because compost used on farms is already required to be tested pathogen free. This burden on farms that use compost is unscientific, especially considering the wealth of data showing that soil treated with compost is more suppressive of human pathogens than soil not treated with compost. The proposed Rule makes it impossible to include grazing animals in a crop rotation. The Rule appears to require a 9-month waiting period between the time when grazing animals have been on a field and the time that crops are harvested from the field. This should be clarified and the 9-month waiting period should be eliminated because few, if any farms, can fallow their fields for 9 months. Farms that use animals in their rotations till the soil after the animals leave and organic farms generally observe a 120-day waiting period. This results in highly fertile soil that is suppressive of human pathogens. 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 0157 developed in the first place. The proposed Rule requires excessive water testing. Weekly water tests for surface irrigation water is unrealistic and the science isnt available to support either this frequency or the test for generic E. coli. The standard of water testing being proposed is not based on relevant scientific data. Until better science and data are available, the FDA should reconsider this prohibitively expensive requirement. The Rule should encourage conservation practices. The FDA should explicitly 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. Tell the FDA that short supply chains are best. Food from many local farms goes direct from the fields on one day, to the consumer the next day. The consumer knows 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. Short supply chains from local farms do make a difference. ~ Judith
Posted on: Sun, 27 Oct 2013 04:25:27 +0000
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