[permaculture] Once more to the barricades! FDA continues its attack on local food systems

Steve Hart stevenlawrencehart at gmail.com
Fri Nov 7 14:06:48 EST 2014

Thanks Bob...its all slipping in nice and slowly isn't it. We have been in
Europe since March and I have noticed a few dramatic changes since here
last 2 yrs ago, with law enforcement officers in particular but more eerily
the huge increase in private security people in all sorts of places. I had
the pleasure of being stopped by a few traffic police whithin a few months,
never had so much frequency or attention before. One young couple of guys
couldn't comprehend my lines of questioning and degrees of resistance so I
was dragged off to their nice little new office in a small village in
remote France. It was an amazing fortress for a small town with quite a
number of new buildings. All the staff were quite young. I ended up
chatting over Rugby...we have a great alliance do the French and New
Zealand of these great gladiatorial events. This allowed me to open up on a
few lines of questions on different subjects. This institution they have
built is apparently one of dozens across France preparing for massive civil
unrest. So they have it all planned well in advance. And, that partly
answered my questions on the huge growth in private security companies. I
would venture to suggest they will be the new "Brown Shirts". So keep
planting those gardens wherever you can and prepare for the very gradual
change in many elements in our society...Steve Hart

On 7 November 2014 18:25, Bob Waldrop <bob at bobwaldrop.net> wrote:

> In 2011, Congress in an orgy of corporation entitlement, passed the
> "Food Safety Modernization Act", which in reality is the "Impose FDA
> Martial Law in Farm Country" Act.
> Last year the FDA proposed regulations to implement the act which we
> (the Oklahoma Food Coop) and others in the local food community urged
> that we all comment on.
> Now the FDA is back, with new regulations. They are better than the
> previous proposal, but there are still big issues, most notably on how they
> impact small farms and food businesses selling directly to the local
> community. The entire process is a sustained governmental attack on
> local food systems that is driven by the "regulatory capture" by big food
> corporations of the food safety regulation system. The big food
> corporations know they can't really compete with local foods, so their
> best option is to regulate them out of business. The law passed with
> strong Bipartisan support, so both Democrats and Republicans are to
> blame here.
> I invite all to listen to this online Radio Program tomorrow, Nov 8, at
> 11 AM our time (9 AM Pacific) to an interview with Judith McGeary of the
> Farm and Ranch Freedom Alliance organization in Texas, which actively
> represents small direct-marketing farmers in the public policy debates
> with the government.
> Tune in at http://metrofarm.com/food-chain-radio/ .
> Find the FARFA at http://farmandranchfreedom.org/
> Below is an alert sent out by FARFA with detailed actions everyone can
> do to defend our right to grow and eat local foods.
> The permaculture oil relevance?  Local food systems are the essence of a
> vision of a "permacultured future" where we have an agricultural system
> that cares for people, cares for the planet, and has a care for the future
> by accepting voluntary limits and keeping surplus in circulation.  If we
> let the FDA dump what amounts to unrestricted "Round-up" on the nation's
> small farmers, many of whom are endeavoring to incorporate permaculture
> design into their operations, and the nascent invisible structures that
> compose our burgeoning local food systems, then we kill the future.
> Please forward this on to others who need to hear about this.
> Bob Waldrop, Oklahoma Food Cooperative
> http://www.oklahomafood.coop
> From the Farm and Ranch Freedom Alliance
> SUBJECT: Tell FDA to be fair to small farmers!
> We fought hard for the Tester-Hagan amendment to exempt small-scale,
> direct-marketing farms and artisan food producers from the most
> burdensome aspects of the Food Safety Modernization Act (FSMA). This
> exemption is essential to the continued vitality of the local foods
> movement.
> Now the FDA is proposing rules that would make it very easy for the
> agency to force even small-scale farmers to comply with the onerous FSMA
> regulations, and all but impossible for these vulnerable farmers to
> protect themselves.
> Under the proposed rules, if the FDA decides to revoke the Tester-Hagan
> exemption and force a small-scale, direct-marketing farmer or artisan
> food producer to comply with the new federal requirements:
> * The farmer or producer gets only 10 days to submit a written appeal;
> * FDA does not have to grant the farmer or producer a hearing;
> * FDA is not held to any specific standard for what evidence must be
> shown to justify the revocation; and
> * The farmer must comply with all FSMA regulations within 60 days, and
> food producers must comply within 120 days; under either deadline, it
> will be impossible for most small-scale businesses to survive and stay
> in business.
> In practical terms, under the agency's proposed rules, the FDA will be
> able to target small farms and food producers one-by-one and put them
> out of business, with little to no recourse for the farmers.
> This is the second round of proposed rules under the FSMA, and we
> objected to these same problems in the first round. While the agency has
> added a provision that allows the farmer or food producer to petition to
> re-instate the Tester-Hagan exemption, that could only occur after the
> farmer has already complied -- which means that it would be too little,
> too late in most cases.
> The agency has also added a brand new provision that would require
> businesses who purchase ingredients from exempt farms to get various
> “assurances” from the farm. This ambiguous provision could create a
> significant deterrent for small farms who seek to provide fresh
> ingredients to local businesses, hurting both the farms and the
> businesses and ultimately reducing consumers’ food options.
> Please sign on to our letter to tell FDA to implement the Tester-Hagan
> exemption fairly!
> SIGN ON HERE: http://bit.ly/sign-the-tester-hagan-letter
> The FDA is accepting public comments until Monday, December 15; we will
> be collecting sign-on’s to the letter until Friday, December 12, so that
> we can compile all of them and submit them in time.
> After you’ve signed the letter, you can increase your impact by
> contacting your U.S. Representative and Senators and urging them to tell
> FDA to respect both the letter and the intent of the Tester-Hagan
> exemption.
> You can find out who represents you at www.house.gov (for your
> Representative) and www.senate.gov (for your Senators). Or you can call
> the Capitol Switchboard at 202-224-3121.
> When you call, ask to speak to the staffer who handles food and
> agricultural issues.
> Key message: "I am a constituent, and I am worried that the FDA's
> proposed regulations will unfairly harm the farmers and food producers
> who I buy my food from. (Or, if you are a producer, "my farm/food
> business.") I would like Representative _____/ Senator ____ to send a
> letter to the FDA, urging the agency to revise its regulations so as to
> implement the Tester-Hagan exemption fairly and with proper due process
> protections."
> You can add to that message using some of the sample talking points below.
> Share the sign-on letter with your networks and encourage them to join
> the fight! Numbers matter, and the more people we can get to call and
> write, the greater our chance of success.
> We will have memes on our Facebook page (/FarmAndRanchFreedom), posts on
> our Twitter profile (@FARFA_org -- we'll be using the hashtags #FSMA
> #FamilyFarmers #TesterExemption), and a flyer posted on our website
> (www.FarmAndRanchFreedom.org) that you can share. You can also download
> print and social media flyers, as well as view suggested Tweets and
> Facebook posts, on our promotion toolkit web page:
> www.farmandranchfreedom.org/fsma-promo-toolkit
> Here are some talking points you can use when you call your federal
> legislators. You don't need to cover all of these, just pick the three
> or four points that fit your views.
> * Everyone wants safe food. And the track record of small-scale farmers
> and food producers is excellent -- the major foodborne illness outbreaks
> have all come from the large-scale industrialized food system. That's
> why Congress decided to include the Tester-Hagan exemption in the first
> place.
> * The FDA's proposed regulations undermine the Tester-Hagan provision by
> putting these small, high quality farms and food producers at the risk
> that an individual bureaucrat can target them with no evidentiary basis
> for vague, unspecified problems.
> * Revoking the exemption means that the producer would have to comply
> with extensive, expensive new regulatory requirements. For example, the
> regulations for farmers growing fruits and vegetables would require
> building washing and packing facilities, frequent water testing,
> extensive recordkeeping and documentation, and processes that will cost
> thousands of dollars per year.
> * FDA's track record does not inspire confidence. Remember how tomato
> producers were devastated because FDA misidentified the source of an
> outbreak? If FDA makes a similar mistake when revoking a producer's
> exemption, that producer would most likely be driven out of business due
> to a too-hasty decision and too-short deadlines for compliance.
> * If small farms go under, healthy food will become even more expensive
> and, for underserved communities, unattainable, worsening America's
> health crisis and the costs associated with it.
> * Imposing regulatory burdens on small, local businesses effectively
> undermines the economic development opportunity that local food and
> agriculture provide for the whole community. Studies have shown that
> every dollar spent on local food has a multiplier effect of 1.4 to 2.6
> times in the community.
> * The FDA has other methods, besides revoking the Tester-Hagan
> exemption, to deal with situations in which there is an actual threat to
> people's health or a time-sensitive issue. The revocation of the
> exemption is a very serious step, and small-scale, direct-marketing food
> producers should be given all appropriate due process protections.
> * Exempt farms and producers should not be required to provide ambiguous
> “assurances” in order to sell to other food businesses under FDA’s new
> “supplier verification” program. These assurances do nothing to improve
> food safety, but they will discourage small-scale producers from selling
> to these markets by creating unclear, unknown legal liabilities.
> * The test for qualifying for the exemption should be based on the sales
> of foods that are subject to FDA’s jurisdiction, not all foods. A farm
> producing a small amount of produce or value-added products should not
> be penalized for also producing meat and eggs – all that does is
> discourage farmers from diversifying.
> --
> http://www.ipermie.net How to permaculture your urban lifestyle and adapt
> to the realities of peak oil, economic irrationality, political
> criminality, and peak oil.
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Kia ora

[image: Picture]
*Steve Hart*
Ecology Architect
Designer, Teacher, Builder of Ecologically Sustainable Resilient
Skype: stevenlawrencehart
Phone: +420 728 799 115
Permaculture Global Design:
The Permaculture College of Europe.
GAPPS The Global Alliance for Permaculture Partnerships and Solutions.

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