On January 10th, I posted that the Food and Drug Adminstration (FDA) had issued a press release initiating public reviewwilliam and mary reunion 003 of the proposed rule for produce safety: Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption. The comment period was supposed to end in May but it has been extended to September 16th. Maryland farmers need to weigh in.

Food recalls are constantly in the news. The FDA press release noted that nearly 130,000 people are hospitalized and 3,000 die from their foodborne illness each year, but our global industrial food system has made it very difficult to track down the causes. A typical example is a recent one from Oregon where it was reported that “The U.S. Food and Drug Administration (FDA), Centers for Disease Control and Prevention (CDC), and State and local officials are investigating a multi-state outbreak of Hepatitis A illnesses potentially associated with Townsend Farms Organic Anti-Ox​idant Blend, a frozen blend containing pomegranate seed​ mix.”

Townsend Farms Inc. is not a small family farm. It is a full-service grower, processor and distributor of berries and other fruit. Its network encompasses farms across the United States and around the world. As I understand it, the outbreak was not caused by fruit grown in Oregon. It was grown in Europe.

The case illustrates how hard it can be to track down food borne illnesses in this complex,

CDC: Finding the Point of Contamination and Source of the Food

CDC: Finding the Point of Contamination and Source of the Food

industrial agricultural economy. The tracking often begins at the local  environmental health office and/or the  state environmental health specialists. For widespread or severe outbreaks, “They often involve state environmental health specialists or other state public health officials and investigators from the Food and Drug Administration (FDA), U.S. Department of Agriculture (USDA), and Center for Disease Control (CDC).”

In his April 8th blog post, Brian Snyder, Executive Director of  Pennsylvania Association for Sustainable Agriculture, pointed out the new Food Safety Modernization Act is a result of the the September 11th terrorist acts. The FDA realized that, considering the way food is now produced, terrorists might use food as another way to attack U.S. citizens.

How does all this relate to small farms? One would assume that food from small farms would not be the first place that terrorists would look to harm U.S. citizens. After all, targeting small farms would be difficult and inefficient. Likewise, any foodborne illness from food directly sourced to consumers or restaurants would be relatively easy to track. I follow the news pretty carefully, and I don’t often hear of cases of foodborne illness from small farms. Where is the data to show that food from small farms is a significant safety risk?

Small farms earning gross sales of less than $25,000 per year are not covered by the proposed rule, but that is hardly enough to earn a living. There is also a “qualified exemption” for farms earning gross sales of less than $500,000, which applies modified requirements. Maryland farmers should review this exemption and the modified requirements carefully.

For all farms with an annual food sales of $500,000 or more, the new rules cover the following major areas:

  • Worker training and health and hygiene
  • Agricultural water
  • Biological soil amendments of animal origin
  • Domesticated and wild animals
  • Equipment, tools, and buildings
  • Sprouts

The proposed produce rule covers “most fruits and vegetables while they are in their raw or natural (unprocessed) state. It would not apply to raw agricultural commodities that are rarely consumed raw, those produced for personal or on-farm consumption, and (with certain documentation) those destined for commercial processing, such as canning, that will adequately reduce microorganisms of public health concern.”

If you are not concerned or overwhelmed after reading the regulations, I will be surprised. No doubt, all food handlers must be aware of and practice good food safety procedures, but to what extent are small farms really part of the problem that the rule is trying to solve? Isn’t it really due to an anonymous global food industry where it is very difficult to trace the source of tainted food? Does the proposed rule get to the root of the problem? Where is the data to show the extent that foodborne illnesses are caused by agricultural water, biological soil amendments, domesticated animals, or tools and how much will it cost small farms to comply? Will the regulations actually reduce the number of foodborne illnesses or will they primarily deter the formation of small farms that are needed to supply a growing demand for locally-sourced food?

The paperwork proposed to improve food safety in what has become an international food system may never produce food as good and as safe as food that comes from a relationship between a local producer and  regular customers. Wendell Berry says it best, “As you shorten the distance between the consumer and producer, you increase the consumer’s power to know and influence the quality of food.”

Please take the time to comment on the regulations. Your input will provide an important perspective for those who will make the final decision. The National Sustainable Agriculture Coalition has great advice for making comments on the draft rule. Go to its Speak Out Today! page and weigh in.