This is a sober topic. In response to the  Food Safety Modernization Act the FDA has drafted new food safety regulations - flawed in that unless modified they will severely hurt family farmers. Tonight, Friday November 22, at midnight (Eastern) the comment period  will close on the FDA's worrisome and severely flawed new proposed regulations for produce farmers called "Standards for the Growing, Harvesting, Packing and Holding of Produce for Human Consumption." 

     The FDA has virtually no experience with farms and farmers. In these proposed regs, FDA has shown a drive to foist unnecessary, unreasonable regs and unjustified requirements onto farmers. In reality the regs were invented for factories aka 'facilities.' They are now aimed at family farmers - where there has never been a real problem with food safety - without demonstrating the regs will bring any reduction in food safety risk. Universally, family farm leaders have very legitimate concerns that this colossal regulatory effort will be so burdensome and costly to family farmers that many of us will be forced out of business. And FDA does admit this could very well happen. If family farmers growing good healthy local food are forced out of business, then your right of access to that good food will be severely limited. 

     If you are able to spend just ten minutes tonight, please send your brief comments to FDA urging them to modify their proposal. This link will walk you through the process and provides a simple, easy to modify template for submitting comments. Comments need not be lengthy: FDA simply needs to receive pressure from citizens in order for them to modify their plans.

Below are the comments written and submitted by Wood Prairie Farm last week, one morning prior to Arden Andersen's Soils course.

     We are organic farmers who have been growing organically for 37 years. We have been certified organic for the last 31 years including eleven years under USDA NOP. Your food safety regs are seriously flawed in that they are over zealous, are unreasonably burdensome and costly to implement and thereby jeopardize the ability of family farms such as ours to continue in operation. This is an untenable position and threatens the US food supply and the right of the American consumer to have access to good local food raised by family farmers. Importantly, your proposed regs fail to zero in on where the real problem lies: with large scale agricultural production and distribution. Because of their scale, mega operations which supply huge markets hold the potential to harm hundreds of thousands to many millions of consumers - this is where the nation's real food safety problem lies. And this is where the focus of your food safety effort must be directed. Going after small and family farmers is a solution looking for a problem. Small and family scale farms have never represented a threat to the American food supply. Our very definition as small conveys the reality that should a food safety problem befall a family farm, the impact will be minimal and limited because the number of potential affected customers is also small, geographically limited and easy to trace. Additionally, those of us who direct market, constantly understand the reality that survival of our business is predicated on quality and food safety. We practice the superior paradigm of food safety by design which is infinitely superior on our modest scale to that of food safety by regulation.

I wish to make the following specific points:

1. You must treat farms as farms and important biologically-based members of our community. Farms are not facilities and must not be treated the same as a facility. Family farms cooperating with one another are still family farms and are not facilities.

2. Certified Organic farmers already comply with USDA NOP regs. Each of us follows a highly detailed, annually updated written NOP Farm Plan. Any FDA food safety regs which apply to us MUST be an adjunct to our Farm Plan in order to be effective, avoid wasteful duplication, unreasonable cost and unmanageable burdens that would otherwise jeopardize our certified organic farm, our family's livelihood and our employee’s jobs.

3. An economic analysis must be performed by an independent panel which
proves that the value of your proposed regulations exceeds the costs which family farmers will incur.

4. You must acknowledge your absolute constitutional restraint and create a transparent system which includes due process so that any farmer receiving an action from your agency will be treated justly and has clear publically posted rights to appeal to an independent entity. This must include a clear publically posted procedure for regaining the ability to produce and sell crops after an FDA action.

5. To greatest extent possible FDA should allow food safety regulation to be performed at the state level by states wishing to do so.

6. For FDA to focus food safety concerns on small and family farmers and at the same time to completely ignore the documented dangers from genetically-engineered crops and farm chemical residues challenges your credibility and raises serious questions about your real motivations. You should review the research of Dr Seralini and the CRIIGEN group about GE crops and glyphosate, and Dr Donald Huber’s work on glyphosate and re-direct your food safety concerns in the areas covered in their important and other related research into the negative health effects of both chemical and GE crops.

7. Your current proposals represent a serious threat of unjustified over-regulation and unreasonable threat to our nation's food supply. It is not acceptable to make regulations so burdensome or costly that family farmers will be forced out of business. Most especially because there has never been a demonstrated food safety problem on small and family farms.

8. Farms are not facilities and therefore farms MUST not be held to the same standard as facilities. Farmers markets, CSAs, consumer-mail-order businesses, roadside stands and other direct-to-consumer vendors fall under “retail food establishment" and not facilities subject to additional regulation.

9. Certified organic farmers current use of manure is safe and scientifically proscribed by USDA NOP. Manure use is documented in our NOP Farm Plan. Before any more restrictive standard could be adopted there must be an independent cost/benefit review which demonstrates scientific justification for a more restrictive standard.

10. FDA must adopt the $1 million threshold for a very small business and base it on the value of “regulated product” and not “all food” so that small and family farms and businesses like food hubs fall under reasonable scale-appropriate requirements and are not subject to industrial scale regulation.

Thank you for this opportunity to weigh in on your food safety regs. They need a lot of improvement.

Jim Gerritsen

Wood Prairie Farm

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