Tell the FDA: Don’t Impose Unfair Burdens on Local, Organic & Sustainable Vegetable Farms
Love your local farms, farmers markets and CSAs (Community Supported Agriculture)? They could be in trouble thanks to burdensome new rules proposed under the Food Safety & Modernization Act (FSMA).
Unless the U.S. Food & Drug Administration (FDA) agrees to some key changes in the FSMA, the law will erect new barriers for small and mid-scale farmers and processors who have been successfully creating local markets – restaurants, co-ops, groceries, schools – for their locally grown produce. And if the rules don’t drive local growers out of business, they will surely drive up the price of local food.
Please sign our letter by November 15. Tell the FDA: FSMA puts small and mid-scale farmers and processors at a competitive disadvantage against corporate farmers and producers who can more easily absorb costs, fees and fines. Please revise the FSMA to level the playing field for small growers. We need to encourage local, organic and sustainable agriculture. As written, the FSMA promotes the corporate, industrial food and farming model that is a hazard to human health and the environment.
The FSMA was signed into law in 2011. But only recently has the FDA proposed new rules that create requirements for every aspect of growing and harvesting fruits, vegetables and nuts – requirements that include costly and burdensome reporting and hazard analysis controls.
The FDA is accepting comments on the proposed new rules until November 15. Please submit your comments today!
Background: Small, local growers are not the problem
The organic fruits, vegetables and nuts you buy from local farmers have never created a food safety problem. Most food safety disasters have originated from large-scale, industrial farming and processing operations – the very operations that stand to benefit from the FSMA!
For example, the 2006 outbreak of E. coli that sickened more than 200 people in 26 states was traced to spinach sourced from an industrial grower, Natural Selection Foods, in California’s Salinas Valley.
Ironically, after the 2006 spinach scandal, food writer Michael Pollan predicted the FDA would come up with new regulations that would likely hurt small, local producers:
“So what happens to the spinach grower at my farmers’ market when the FDA starts demanding a Haccp plan — daily testing of the irrigation water, say, or some newfangled veggie-irradiation technology? When we start requiring that all farms be federally inspected? Heavy burdens of regulation always fall heaviest on the smallest operations and invariably wind up benefiting the biggest players in an industry, the ones who can spread the costs over a larger output of goods…
“It’s easy to imagine the F.D.A. announcing a new rule banning animals from farms that produce plant crops. In light of the threat from E. coli, such a rule would make a certain kind of sense. But it is an industrial, not an ecological, sense. For the practice of keeping animals on farms used to be, as Wendell Berry pointed out, a solution; only when cows moved onto feedlots did it become a problem.”
The FSMA gives the FDA sweeping new powers over fruit, vegetable and nut production. But it doesn’t address meat and dairy farms, which are covered by the U.S. Department of Agriculture. Wouldn’t it make more sense to crack down on factory farms, which pose known threats to human health and the environment?
Instead, the proposed FSMA rules threaten basic, time-honored organic and sustainable agriculture practices – practices that farmers have used for hundreds of years, including:• The use of natural fertilizers, like compost and manure
• Raising vegetables and animals on the same farm
• The use of natural water sources for irrigation
The FSMA also proposes a Preventive Controls rule that requires any business that packs, holds, processes or manufactures food to create a Hazard Analysis and Risk-based Preventive Control plan, which can cost up to $20,000 for a small operation in the first year alone. Who would be affected?
• Any farm that dehydrates, pickles or mills its produce
• Two or more farms that run a joint CSA and handle or store each other’s produce (even if they do no processing)
• “Food hubs” that distribute food from multiple local producers
Sign our letter today. Tell the FDA: Please protect our local farms, farmers markets and CSAs. Revise the FSMA to level the playing field for small growers. We need to encourage local, organic and sustainable agriculture.