[Market-farming] Proposed USDA Restrictions on Salad Crops

John Ferree john at seldomseenfarm.com
Tue Nov 27 11:12:12 EST 2007


Protect Fresh Leafy Greens and Family Farms

*Federal Regulations Would Harm Sustainable Farmers and Biodiversity*
We need your help in another battle to stop the *slippery slope toward a
sterilized and industrialized food system* that threatens biodiversity
and the very existence of family-scale farms that grow food in a safe,
healthy, and environmentally sustainable way.
In response to the E. coli 0157 outbreaks last year in bagged spinach,
the USDA is considering a change in the federal regulations that could
potentially require growers of *_all_ fresh leafy green vegetables* to
follow specified guidelines in the fields and during post-harvest
handling. The federal rules would be similar to the California
guidelines that were set by large-scale operations after the outbreaks.
The _guidelines include growing practices that discourage biodiversity
and sustainable/organic farming practices_, deplete soil fertility, and
create “sterile” fields—methods that have not been scientifically proven
to actually reduce E. coli 0157 bacteria but are certain to *reduce
biodiversity, harm wildlife, and burden family-scale farms*.
*Small- and medium-scale farmers would bear the greatest financial and
logistical burden of such specified guidelines*. For example, if the
rules require testing for pathogens at every harvest—as they currently
do in California—then large-scale farms that grow one type of crop and
harvest only one to three times per season would pay much less than
smaller and more diverse farms that continually harvest many types of
vegetables. If regulations dictate a single set of growing practices and
food safety measures, which are appropriate for large-scale “factory
farms” but not for diverse family farms, *_we risk losing the very farms
that grow leafy greens in a healthy and sustainable way_*. A
one-size-fits-all regulation will not work!
The rules threaten biodiversity and environmental sustainability in
several ways. Farmers would be encouraged to eliminate wildlife and any
vegetation that may provide habitat for wildlife. The rules also
discourage the development of microbial life in the soil. These *methods
have not been shown to reduce the risk of harmful bacterial
contamination*. In fact, sustainable farming methods that promote
microbial life in soil have shown to reduce E. coli 0157 because it has
to compete with other microbes and is therefore less likely to thrive.
However, the aim of these rules seems to be for sterile fields that
support no forms of life, except for the leafy greens.
*We must make our voices heard*, telling the USDA that we do not support
federal rules that would put a great financial and logistical burden on
family-scale farmers, discourage environmentally healthy ways of
farming, and harm wildlife.
Taking action is easy, but with a *December 3 deadline* for submitting
comments to the USDA, we need your help *_today_*. Please tell the USDA
that food safety is an important concern, but that mandating measures
with no scientific basis that will put small farmers out of business,
and harm wildlife, is not the way to go.
*Please submit your comments today by downloading the sample letter
below* or writing your own message and posting it online (see
instructions below), or faxing it in. The USDA is specifically asking
citizens to comment on its plan to implement these rules, and it’s
important that you tell the USDA that you want to ensure access to
fresh, leafy greens and that you oppose a Marketing Order or Marketing
Agreement that would impose federal standards for all growers of leafy
greens. Remember that every comment counts, but individualized
messages/letters carry more weight than form letters.
<http://www.cornucopia.org/LeafyGreens/Leafy_Greens_SampleLetter.doc> TO
*1) To submit online: *

      Go to www.regulations.gov <http://www.regulations.gov>. In the
      middle of the screen, you will see “Search Documents.” 

      In Step 1, choose “Documents with an open comments period”
      In Step 2, choose “Department of Agriculture”
      In Step 3, choose “PROPOSED RULES”
      In Step 4, choose “Docket ID” and then type in “AMS-FV-07-0090” 

      Hit “Submit.”
      Next, you will see a column titled “Comments, add/due by.” Click
      on the tiny tan dialogue icon, and you are now ready to submit
      your information and your comment. 

*2) To fax: (202) 720-8938. *
** Please make sure that your letter references Docket Number
In addition to the Cornucopia website more information on this matter is
available by visiting the California-based Community Alliance for Family
Farmers’ website at http://www.caff.org/foodsafety/. We thank CAFF for
their diligence on this issue.

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