LocalHarvest Newsletter, February 29, 2016|
Safe Food or Regressive Regulations?
Welcome back to the LocalHarvest newsletter.
Our LocalHarvest staff member John Gethoefer just wrote this letter to his congressman, Earl Blumenauer, regarding the challenges facing small farmers, in particular the new food safety regulations and requirement for food safety certification by many buyers. Once the Food Safety Modernization Act (FSMA) is fully implemented (most farmers have until 2018 to comply), it will be required for nearly all vegetable, fruit, and nut producers to follow these rules and pay for certification. Only those that gross under $25,000 a year in produce sales will be categorically exempt. I can think of no other set of regulations that is going to discourage new farmers from getting started and existing farmers from scaling up than the FSMA rules. The results could be horrific for the advancement of a sustainable food system and do little if anything to reduce deleterious pathogens in our food supply.
Here is an except from John's letter:
My name is John Gethoefer. I am on the staff of LocalHarvest, which is an organization that provides support for small, family farms throughout the US. Congressman Blumenauer's latest email to constituents piqued my interest in regards to "Equitable & Sustainable" agriculture policy. We see first hand every day how difficult the practice of small, local family farming has become in America. It is a commonly felt view among the many farmers that we advocate for that federal agricultural policy usually does more harm than good for small, family farms. In turn, there is growing skepticism among these farming families that any legislation introduced will likely do more harm than good for their livelihoods and viability.
One example that we have seen recently in the struggle to promote local food systems is that large, institutional buyers of agricultural goods typically require vendors and producers to follow the USDA GAP (Good Agriculture Practices) or GHP (Good Handling Practices) standards. We have worked directly with both institutional buyers and farmers local to them and while we have tried to develop training programs that are cost-effective for the farmers, more often than not, the program is too costly for these farmers to adopt. As a result, very few local farming operations qualify to sell agricultural goods to these institutional buyers. While the intentions of GAP/GHP program are to increase safety for the general public, there exists many challenges in terms of equity and ultimately sustainability for the small, family farmers to adopt and therefore compete in the local marketplace.
To comply with the new FSMA rules, a farm has to get each crop certified as food safety compliant. Imagine what a diversified farm with over 10 crops will have to do to certify each crop. The compliance costs vary widely based on how many actions a farm has to take to pass the inspection. On the lower end I found compliance costs of $50/acre up to $13,000/acre if larger infrastructure renovations are required. These include costs such as water testing, testing compost materials, installing deer fencing, building an enclosed packing house, switching to all plastic harvest bins, renting port-a-potties with hand washing stations and the most time-consuming task of endless record-keeping. The record-keeping of organic certification will pale in comparison with food safety record-keeping. Things like daily temperature checks, recording when you pump, clean, and restock your bathrooms, recording when your employees wash their hands, how many deer footprints you found in a particular field, lot numbers for every box of produce you harvest, etc. One farm studied in Vermont had to actually hire a food safety manager to develop all of the plans, implement them, and do the record-keeping (that's a whole other salaried employee on the payroll just for food safety). Like many government regulations, the burdens fall disproportionately on the smaller-scale businesses. A 2010 study (Paggi et al) found a substantially higher GAP compliance cost per acre for small and medium-size operations than for their larger counterparts. It also demonstrated that, extended over time, these higher costs for smaller operations adversely impact a number of important financial variables that can be expected to affect their ability to compete and survive. In plain English, the high costs of food safety compliance and certification could put these smaller farmers OUT OF BUSINESS.
I participated in a mock audit many years back while working on an organic farm in California with some USDA GAP inspectors in training. It turns out those inspectors had no background in biology at all. They literally made up issues on the spot and deducted points from our audit at random. I remember one of the inspectors insisting we cut down a tree that was next to our irrigation well because birds could land on the branches of the tree and then poop on the well head. Even though it was a fully submersible well, they thought that bird poop might somehow make its way into the water. They also pointed out that we had too many hedgerows which may harbor birds and rodents. We told them they were to block dust, wind, and attract beneficial insects and pollinators. They didn't understand those benefits. The last thing they said that really shook us all to the core was that we would have to get rid of the farm dog, who was also our farm mascot. Despite being a gopher and ground squirrel killing machine, they thought she might go poop in some of the fields. In fact, this dog always pooped in the same area and never in the farm fields. We debated between having more rodent pressure in our fields or having this amazing farm dog. How many auditors are out there deducting points or telling farmers they have to get rid of their domesticated animals, livestock, or poison/fence out wildlife in the name of food safety? How about a little common sense and understanding of ecology instead?
If you want to understand more about the Food Safety Modernization Act and who it affects, check out this detailed flowchart from the National Sustainable Agriculture Coalition. We need to insist that smaller farmers are exempt from these expensive one-size-fits-all regulations and give them a longer window of time to comply. There should also be whole farm/multi-crop audits that are done in one visit and that certified organic farmers don't have to pay twice for essentially a similar inspection.
From the LH Store
It's that time of the year to start thinking about gardening. Have you ordered your seed yet? If not, it isn't too late to get your seed order for crops that you will start indoors or ones that will go directly in the ground once the last frost has passed. We have our onions seeded in a heated cold frame and will begin our tomatoes and peppers indoors in late March to be set out around Mother's Day. What are your garden plans?
Are you tired of managing multiple spreadsheets, keeping customer contact information in a Rolodex, and forgetting who has paid up and who still has an outstanding balance for your CSA? Our customer management software takes care of many of these things so you can get back to the growing and marketing of your beautiful food. Schedule an appointment today to get a tour of CSAware - You will love it!
Recipe: A Texan's Version of Peruvian Stew
If I were food I would be stew. I would be hearty and simple, and I would be nourishing and humble. But I'm really not any of those things, so I guess I'm not stew. That's okay, because I still get to make stew, and an especially tasty one at that.