[Market Farming] [Fwd: Re: [SANET-MG] HACCP, GAP and Leafy Greens] MORE

Lawrence F. London, Jr. lflj at intrex.net
Wed Dec 3 21:25:20 EST 2008



-------- Original Message --------
Subject: Re: [SANET-MG] HACCP, GAP and Leafy Greens
Date: Wed, 3 Dec 2008 20:10:53 -0600
From: Douglas Hinds <cedecor at GMX.NET>
Reply-To: Douglas Hinds <cedecor at gmx.net>
Organization: CeDeCoR, A.C.
To: SANET-MG at LISTS.IFAS.UFL.EDU

Steve Gilman answered the question I posed to Juli Brussell as
follows:

>  Hi Douglas,

>         I'm glad you asked -- this is becoming a major government regulatory
> compliance issue for family farmers.

in what way?

> 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.

That's the whole point, I believe. As I understand it (and I have
had contact with it since 1989), HACCP is a set of procedures
consciously designed to:

1).- Identify the pathogens and chemical substances that could
      conceivably contaminate a particular fresh or processed food;

2).- Identify the points (places and moments) when contamination
      could occur, during cultivation, packing and shipping; and

3).- Develop a procedure capable of determining whether the food in
      question has or hasn't become contaminated, at each and every
      point.

> 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.

I would think that a distinct set of procedures would have to be
developed for each food and set of circumstances. For that reason,
the construction of an international data base based on HACCP must
be created. If this hasn't be done, that would certainly make
implementing HACCP a more daunting task in many cases.

>         Instead, the FDA has moved to the GAP -- "Good Agricultural
> Practices" program -- a certification program for farmers to supply
> business --

There's also GMP - Good Manufacturing Practices - a complementary set
of procedures.

> which is being severely co-opted by the big industrial
> food players.

How so?

> 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.

So who does the certifying?

> And as this approach gains steam at the state level many feel that
> MANDATORY is just around the corner.

Schools must meet federal standards and shipping food across a state
line (inter rather than intra-state commerce) involves Federal Laws
also (i.e. the PACA - the Perishable Agricultural Commodity Act).

> 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

If that's the case, the USDA's implementation of GAP is exactly the
opposite of the principle I stated above.

> 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.

This sounds like an issue that should be brought to the attention of
the Obama Transition Team.

> 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.

So what would you suggest?

> 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.

If the USDA doesn't care, consumers do.

> 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?

Sure! EVERYONE wants their food products free of pathogens. (When
you say E. Coli, you are talking about the pathogenic strain, of
course).  In fact, even the largest and wealthiest growers can be
bankrupt by the ill fame a few caused deaths would bring.  This is
every growers worst nightmare.

> But wouldn't we also want to have any governing standards based on
> sound scientific data and truly good ag practices??

For sure.

> 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.

More than manure, it's the state of the gut of the animals producing
it, the food they are eating, and (of course) composting or aging
that manure.

> Some requirements, such as documenting that wild or domestic animals
> can’t get into the production area, are nearly impossible to comply
> with.

Is electric fencing that costly?

> 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.

They're substituting distance for health - and dealing with the
wrong issue!

> Manure management on the farm with livestock is also subject to
> review.

Stupid, ignorant and incompetent bureaucrats can make a mess out of
anything.  The wrong people have been in power - which is not to say
that legitimate standards aren't needed.

> 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.

Another illogical conclusion.

> 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.

That's four months - regardless of whether the manure was adequately
aged or not (fresh manure should never be used).

> It regulates compost much more tightly,

More tightly than manure?  That doesn't make sense!

> and assesses water quality as well. A rational assessment process
> would consider each of these issues and evaluate which practices
> are potentially risky.

Correct - using comprehensive, systems based criteria.

> Under the current yes-no scoring system, it will be very difficult
> for farms that include both crops and livestock to pass a review."

That's unfortunate.  Perhaps creating two separate corporate
entities would help.

> 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.

I spent October and half of November in Ohio (my mother turned 90
Oct. 11 and I stayed over for the elections - which were held on MY
birthday).

Each and every Saturday we both got up before dawn to get to the
Farmers Market at Cleveland's Shaker Square around daybreak. There
were lots of greens (none bagged - they were bagged then and there,
if loose leaf), roots, fruit, mushrooms and bread; with all of it
grown or made less than an hour's drive away.

The same was true with the local supermarket chains.  People don't
eat the way they used to.  Fresh food has taken over, but the chains
must include out of state food.

> 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.

Standards are needed. The question is, who sets them and what
principles are they based on. Some players assume that the world is
a hostile place, full of threats. These people would be happy to see
irradiation mandated, for instance.

>         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.

I wrote the paragraph above before reading yours.  We are evidently
understanding the issues from a simular perspective and need to know
more about who Obama will place in decision making positions related
to agriculture, public health and the environment.

> 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

I'll take a look at six websites you mentioned. This is an extremely
important issue.

> 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!

If the extension is approved, two of those three months will occur
during the next administration, but the actual administration will
decide whether to grant the extension or not.

> 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...

I'll do it tomorrow.

> Thanks!

Thanks for the orientation.  I intend to get involved with this.
We need to know more about Obama's choices for the USDA, FDA, EPA,
DHHS etc. and what their allegiances are.

In a related vein: As I recall, an organic farmer (possibly in
Montana - the name Jon Testor rings a bell) was elected Senator (or
was it Governor?). I wonder whether he been pro-active in relation
to these issues?

Douglas Hinds
CeDeCoR, A.C. (Center for Community and Rural Development)
National Coordinator for Organic Production, CNPR
Director of special Projects, National Supreme Indigenous Council
(All in Mexico)
Chair, Organic Pineapple Working Group, ISHS
(World)

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