[Market-farming] FDA regs was losing insurance coverage

idyllwild farm idyllwildfarm at gmail.com
Wed Feb 20 08:58:49 EST 2013

Quick version- link below is to the summary of the proposed FDA regs on
produce handling. Follow the links from that page if you want to get into
the weeds of the proposal. Its gap on steroids, the focus is on practices
(separation between animal & produce is a big one) and record- keeping with
a little common sense (e.g. You don't have to exclude wild animals from
your fields but you do have to have policies in place on how you don't pick
produce with deer poop). And you will have to participate if you make more
than $25k selling to consumers. Handlers will have to be able to track
back- does that include organized farm market associations?don't know, but
they shouldn't ignore it either (enforcing clear labeling, etc). Exemptions
exist but all bets are off if you are associated with a public health
My hope is that extension and the larger farm markets, etc will help the
small farmer put together the policy manuals by providing generic policy
pages on things like handwashing, etc. Proper implementation is up to the
farm, but there is no reason for each farm to build the recordkeeping and
policy manuals from the ground up (although I'm sure some will see the $$
making opportunity). MN extension has already posted plans for portable
handwash station, for example.
If you do sprouts or microgreens pay very close attention;FDA isn't really
grooving on them at all.
This is the comment period, so you do have a voice right now. At the
meeting i was at, a large grower did slam the smaller growers on sanitation
and the longer period of time to comply, so I don't expect much slack based
on the size of the farm-the big guys won't stand for it. I think the rule
is scheduled to go into effect in may? And there are several years buffer
to give time to comply.
Regards, Mike

On Feb 20, 2013 8:18 AM, "Richard Stewart" <rstewart at zoomtown.com> wrote:

> I'd love to post something about and I am thinking Mike Haas who is also
> on the list and has attended more than I have look at doing the same.
> I am trying to get a bunch of stuff ready for two weeks worth of market so
> I can leave the farm and go on vacation starting on Thursday.  I'm hoping I
> can do this will relatively little issues (created by me or others).
> So, with that said, and detail thoughts will come in March.  I am just
> hammered for time.
> I will say that here in Ohio we have two issues to contend with.  1) The
> Ohio Produce Marketing Agreement, which was given teeth back last fall when
> our Governor signed into a law legislation that allowed for "marketing
> agreements" by non-grain commodity industries.  I sat through an OPMA
> session at the OEFFA Conference where Bob Jones (COO of Chef's Garden in
> Huron Ohio) said (and I am paraphrasing) if you don't play ball get out of
> the business" and told us that he is going to push to have Farmers' Markets
> in Ohio come under the same guidelines as the rest of the buyers (requiring
> OPMA or GAPS certification of some sort).   Not to sure if it will happen
> or not.  I have heard rumors that they cannot get enough people to sign on
> yet to make the effort sustainable and folks like me who are more concerned
> about the Federal requirements than the OPMA (I live in a border region and
> work,sell, farm in three States, not just one).  Insurance WILL be effected
> eventually if not immediately (say 3 to 8 years or so I would imagine given
> the amount of time required to adopt the requirement in the  Federal
> program).
> I've also been hearing now that the maximum in gross sales is 25K not 500K
> before you start being impacted by the new food safety regulation.  I have
> not seen why this is so, just been told that it is so.  Way to much data to
> pour over to develop my own opinion and way too much nebulous stuff going
> on at the USDA in terms of definitions and hearings.
> All I can say is, unless ALL your business is done on the farm and you are
> selling to JUST the public, chances are you will be impacted somehow.
> Get involved with your local Extension and State Department of AG and be
> involved in your local organic certifiers, Farm Bureau and Farmers' Union.
>  Make comments at the Federal level and do something to inform your local
> representatives that bad things are coming and you need help.  Local food
> SHOULD be on the rise and its about to get kicked in the gut.  If you have
> not done anything you to fight the tide then you, in part, responsible for
> what happens to your business several years from now.  Its that simple.
> You have to separate everything.  Home from business.  Produce and Fruit
> from Livestock.
> And in the future there are far more people better versed than I at what
> is going on and maybe we should have some of them comment here.  I will
> simply be giving you my interpretation of things...
> ...my interpretation right now is that the big guys are having to play by
> a new set of rules and KNOW that they are missing out on the local food
> industry (it is an industry) and want us to play by the same rules as them
> in hopes that we are shut out save but a small few that would have little
> impact overall in the amount of sales.
> I KNOW that at least one food wholesaler is pushing hard, especially when
> our lettuce mix (and other local farmers) is the only one being purchased
> in season by several LARGE local restaurants.
> Its going to be a fight and a big part of me just wants to follow the path
> of least resistance at this point.  I am exhausted worrying about this,
> looking out for my employees, and trying to grow.
> And now I am behind on what I was planning on doing this morning.  :)
> Have fun folks and more on this in March.
> Richard Stewart
> Carriage House Farm
> North Bend, Ohio
> An Ohio Century Farm Est. 1855
> (513) 967-1106
> http://www.carriagehousefarmllc.com
> rstewart at zoomtown.com
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