[Market Farming] HACCP, GAP and Leafy Greens -- SANET-MG Archives -- December 2008 (#9) -- small farmer alert

Lawrence F. London, Jr. lflj at intrex.net
Wed Dec 3 21:22:22 EST 2008


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Subject:	 Re: Thoughts on Obama's Agriculture Transition Team?
From:	Douglas Hinds <[log in to unmask]>
Date:	Mon, 1 Dec 2008 18:01:19 -0600

Juli Brussell wrote:

> Am I mistaken or is he not the "gentleman" who also spent time at FDA
> and gave us the HAACP mandate for small-scale community meat
> processing facilities? If so, he has been quite busy...

HACCP (Hazard Analysis and Critical Control Points) has always
seemed like a logical approach to avoiding contamination, to me.

Can you tell me what it is that you don't like about it?

Is a third party certifier required, or is following the Processes
Guidelines enough?

On the other hand, Monsanto is about as dishonest, malicious,
sinister and conniving as they come, IMO. (Ask Percy Schmeiser).

Vanity Fair documented some of Monsanto's questionable practices in
an article published in May of this year:
<www.vanityfair.com/politics/features/2008/05/monsanto200805>

And wikipedia mentions quite a few of the most controversial
aspects of Monsanto's activities:
<http://en.wikipedia.org/wiki/Monsanto>

Personally, I would hate have to a Monsanto representative making
agricultural policy decisions during the next administration.

If you feel the same way, I suggest you visit www.change.gov to
make your position known!  (Select "About", then "Contact").

Douglas


http://lists.ifas.ufl.edu/cgi-bin/wa.exe?A2=ind0812&L=sanet-mg&T=0&O=D&P=5680
Subject:	 HACCP, GAP and Leafy Greens
From:	STEVE GILMAN <[log in to unmask]>
Date:	Tue, 2 Dec 2008 13:11:22 -0500

   Hi Douglas,

	I'm glad you asked -- this is becoming a major government regulatory
compliance issue for family farmers. HACCP ("Hass-up") stands for the
Hazard Analysis Critical Control Points food safety system. It's had
some success in the worlds of food processing and retail food
establishments because there are readily identifiable "control
points" where prepared foods can successfully be prevented from being
contaminated. The problem is that HACCP gives the assurance of food
safety, even when applied to other aspects of the food system, such
as agriculture-in-nature, where the control points are more amorphous
and harder to quantify or qualify.

	Instead, the FDA has moved to the GAP -- "Good Agricultural
Practices" program -- a certification program for farmers to supply
business -- which is being severely co-opted by the big industrial
food players. Right now GAP is "voluntary" -- unless you want to
supply your local school lunch program, for example -- or even Whole
Foods for that matter -- where you have to be GAP certified. And as
this approach gains steam at the state level many feel that MANDATORY
is just around the corner. Farmers everywhere beware -- this is a
wolf in squeaky-clean sheep's clothing.

	Based on farm assessments, GAP is a one-size-fits-all scoring system
where farmers have to score 80% in each area of the program and need
to come up with 132 out of 165 points to qualify for certification.
It'll cost you -- certification via USDA's Food Safety and Inspection
Service rings up at $75 per hour plus expenses. And, of course, the
fees, paperwork  and other burdens disproportionally serve the larger
entities plugged in to nation-wide sales, not to mention the
protective "government certified" cover they get assuring customers
at the supermarket who are still leery of their spinach, tomatoes and
burgers after the major outbreaks of E.coli, etc. that hit the fan
earlier.

	One immediate problem with GAP is that small scale, whole-farm
oriented organic and sustainable ag farmers start out with both hands
tied behind their back. And the good old monocropping conventional
farms get a free ride because here, "Good Agricultural Practices"
says nothing about the dangers of using toxic pesticide and
fertilizers, for example, but focuses solely on microbial
contamination. Well, OK -- we all want our food to be free of E.
coli, salmonella and the other virulent pathogens that are loose in
our food system, right? But wouldn't we also want to have any
governing standards based on sound scientific data and truly good ag
practices??

	This is where the influence of Big Ag comes in. As MOFGA's Russell
Libby so ably points out at:
www.mofga.org/Default.aspx?tabid=735 (and I quote:)
	"The farming practices section will be very challenging for many
farms that either include both livestock and crops for human
consumption, or bring manure or manure-based compost onto the farm.
Some requirements, such as documenting that wild or domestic animals
can’t get into the production area, are nearly impossible to comply
with.
	The critical questions revolve around livestock. By the USDA
standard, the presence of livestock near (within 2 miles) or adjacent
to (within a half mile) the farm is a major problem, and may result
in a 15-point deduction. Manure management on the farm with livestock
is also subject to review. Notice—all of these issues are neutral
about which farm has the livestock. If your neighbor, 2 miles away,
had animals and a minimally managed manure pile, your farm score
would be affected. Or, if you had animals in fields that were
completely segregated from your crop production rotation, you would
get a deduction.
   	GAP requires 120 day waiting periods between manure application
and crop harvest. It regulates compost much more tightly, and
assesses water quality as well.
	 A rational assessment process would consider each of these issues
and evaluate which practices are potentially risky. Under the current
yes-no scoring system, it will be very difficult for farms that
include both crops and livestock to pass a review."

	Now to the Leafy Greens connection. Farmers who cut and sell heads
of looseleaf lettuce probably won't be considered "processors". But
if they pick and pack spinach, mesclun greens and maybe even items
like kale and collards they might be considered processors by some
businesses even if they are traditional salad growers and not are not
part of the huge national-scale bagged salad mix market. Small
farmers may now be subject to a "Marketing Agreement" put together by
the Leafy Greens Big Boys in California, the epicenter of the E.coli-
on-spinach outbreak in 2006 which killed three people and sickened
hundreds more all across the country. In an agribusiness-based
regulatory fait accompli a hundred or so handlers, shippers and
buyers put together a Leafy Greens Marketing Agreement (LGMA)
requiring their growers meet uniform food safety standards,
effectively fashioning self-serving mandatory standards across the
board for large and small family farmers alike.

	Utilizing GAP parameters, the LGMA rules rely on a "sterilization"
approach to farming -- including removal of grassed waterways,
cancellation of conservation projects, fencing against wildlife,
compost prohibitions, sterilizing soil with ag chemicals, etc. which
completely flies in the face of the biological-ecological-organic
paradigm based on building a healthy biodiversity and recycling
nutrients. There are a number of groups gearing up to fight this. The
Center for Food Safety, Union of Concerned Scientists and Food and
Water Watch are actively involved. Please go to the Wild Farm
Alliance for the conservation concerns and effects on biodiversity
and habitat destruction:
www.wildfarmalliance.org/

....and go to CAFF -- the Community Alliance with Family Farms --
whose food safety campaign addresses the real needs of consumers and
small-scale farmers:
www.caff.org/foodsafety/

	The FDA first published their GAP rules in 1998. The Agency is
currently reviewing the Gap Guidelines: "Guide to Minimize Microbial
Food Safety Hazards for Fresh Fruits and Vegetables,"  with the aim
of tightening it further and possibly going mandatory. They are now
asking for comments on specific aspects of the program, with a quick
deadline of Dec 31st -- it's posted on the Federal register at:
http://edocket.access.gpo.gov/2008/E8-20187.htm

	Because of the complexity and lack of sound scientific data on this
issue, clearly the flagrant gaps in the GAP program need to be
carefully addressed by the entire sustainable ag community. There's a
movement, even from some larger producers, requesting FDA for a 90
day extension to March 31st, 2009. This additional time is
desperately needed! Meanwhile, a "Leafy Greens Working Group" has
been formed by the Northeast Organic Farming Association (NOFA)
together with organic and sustainable ag groups in the East from
Maine to Florida to address this matter, produce comments and get the
word out to farmers and consumers. Please log on to the FDA site
today and request an extension -- for starters...

Thanks!

Steve Gilman
NOFA Policy Coordinator

-------- Original Message --------
Subject: 	Re: [growingsmallfarms] HACCP, GAP and Leafy Greens --
SANET-MG Archives -- December 2008 (#9) -- small farmer alert
Date: 	Wed, 3 Dec 2008 07:45:32 -0500
From: 	Chris Sawyer <jakesfarm at msn.com>


The other issue GAP  does not address is to prevent overhead irrigation
of surface waters. It is just common sense that that is a dangerous
practice. I hosted a GAP training at my farm. I passed in all areas
except having my dogs in the fields. That practice is automatic failure.
So would having a deer in your field cause you to be failed. Not a point
deduction, but failure.

Needless to say I am not GAP certified. I am needing to deer and
wildlife fence eight acres and have no money for that. My neighbor has
sold his cows so that is no longer a problem for us. However we do have
neighbors (downstream) from us who allow their cows still to wade the
creek for water. Buffers are coming soon and no one is gonna like it. I
see wars looming on the horizon between ranchers and farmers rights
concerning clean water for irrigation. It will be mandatory to only
irrigate from wells or treat surface water before spraying on crops, or
else treat the water is my thinking. The only way to grow lettuce in
August here is with some overhead cooling water, and it is common
practice for frost control in strawberry production.

All in all the small family farmer is going to have to invest so much
money to comply that he/we will simply have to quit and let coporate
farmers have the world, unless we get some common sense in the regs.
A HACCP plan has to be written by a pro...cannot write your own.

Chris Sawyer
www.jakesfarm.com <http://www.jakesfarm.com>

-------- Original Message --------
Subject: 	Re: [growingsmallfarms] HACCP, GAP and Leafy Greens --
SANET-MG Archives -- December 2008 (#9) -- small farmer alert
Date: 	Wed, 3 Dec 2008 10:12:05 -0500
From: 	rancher <rancher at carolina.rr.com>


I've forwarded this thread to our discussion group in
Charlotte.   http://ronpaul.meetup.com/1891/  and our Liberty group
  http://www.meetup.com/greater-charlotte-liberty/   I hope you don't
mind.  Very few of us are farmers of any sort, but I do intensive
gardening (non-gmo, heritage, organic) in my yard and many of our
members do as well.  All of our members, in both groups, are very aware
of what big government/corporations are doing to this country.  I'm not
sure they knew about this, but now they do.

I'm glad that the link to change.org has been included, BUT, lately
we've found that any reference to ending the Federal Reserve has been
removed from the list and is no longer available for anyone to view or
vote on.  IMHO, they don't care, period.

More people need to know about what the small farmer is going through,
you guys are the cornerstone of what we all like to think of as our
country.

Pat Armstrong


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