[Market-farming] Proposed USDA Restrictions on Salad Crops

E C GRANATA elainegranata at msn.com
Wed Nov 28 23:38:54 EST 2007

Thanks for alerting us to this -- sent my comments off tonight.

  ----- Original Message ----- 
  From: John Ferree<mailto:john at seldomseenfarm.com> 
  To: Market Farming<mailto:market-farming at lists.ibiblio.org> 
  Sent: Tuesday, November 27, 2007 9:12 AM
  Subject: [Market-farming] Proposed USDA Restrictions on Salad Crops


  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<http://www.cornucopia.org/LeafyGreens/Leafy_Greens_SampleLetter.doc>> TO
  *1) To submit online: *

        Go to www.regulations.gov<http://www.regulations.gov/> <http://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/<http://www.caff.org/foodsafety/>. We thank CAFF for
  their diligence on this issue.
  Market-farming mailing list
  Market-farming at lists.ibiblio.org<mailto:Market-farming at lists.ibiblio.org>

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