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  • From: Chrys Ostrander <chrys AT thefutureisorganic.net>
  • To: market-farming AT lists.ibiblio.org
  • Subject: [Market-farming] A National Voice to Defend Sustainable Ag from Bad Food Safety Law
  • Date: Tue, 24 Mar 2009 08:52:39 -0700

Folks,

There's a lot of work to do in the upcoming months to make sure that whatever proposed federal food safety laws rise to the top, and for that matter any recommendations coming from the White House food safety task force, do not devastate small-scale farmers, small-scale food producers, local food systems, biodiversity, the ability of organic farmers to maintain their organic status, etc.

In my opinion, the best organization for focusing our concerns, winnowing out misinformation, engaging the grassroots, crafting the required language and effectively lobbying congress in our name is the N ational Sustainable Agriculture Coalition. Take a look at their website and their list of recent activity and I think you'll agree that NSAC is the national organization to defend us as politicians and bureaucrats scramble to "do something" in the face of continuing food safety crises, mostly arising from industrial-scale food production.

NSAC just concluded their winter meeting in Washington D.C. where they set their annual priorities as a coalition (they base the work that they do in D.C. on what the voting members of the coalition - 44 grassroots organizations from the across the country - collectively decide should be the priorities for the coming year).  NSAC has not completely finalized those decisions yet, but I was told they will be involved in doing some level of analysis of food safety issues. However, I got the impression their planned involvement at this point in food safety issues may be more limited than the magnitude of the threat we face really requires.

So, what I believe needs to happen is YOU need to let NSAC know that you have BIG concerns about imminent food safety law changes and ask NSAC to take on the issue in a BIG way.

The way to do this is to look at the list of organizations that make up NSAC's membership. See if you already belong to one or more of them and if not, JOIN one or more of them. Then contact the organization(s) and strongly urge them to request NSAC take a comprehensive approach to addressing the potential threats to small-scale sustainable agriculture posed by imminent changes in food safety laws.  If you already belong to one, contact NSAC and tell them which organization you belong to and ask NSAC directly to fully embrace a comprehensive approach to addressing food safety law. Clicking on a staffer's name on their contact page opens a blank email message to that staffer.

Here are just a few places to look for more background info:
http://www.cornucopia.org/2007/11/protect-fresh-leafy-greens-and-family-farms/
http://www.ccof.org/foodsafety.php
http://www.caff.org/foodsafety/
http://www.nofa.org/policy/leafygreens.php
http://www.lavidalocavore.org/showDiary.do?diaryId=1266


To get a grasp of the magnitude of the task at hand, please read the following summaries of proposed food safety laws:

1) Go here:
http://www.lavidalocavore.org/showDiary.do?diaryId=1222

 2) Read this summary by Martha Goodsell, who owns Fallow Hollow Farms in Tioga County, NY and is a very well respected sustainable ag activist:

Here's my response I've been sending out to those that ask:
 
Yes I've researched HR 845, but no, not all of what you're reading is true. Here's some research I've done on the food bills. I'm most concerned with Senate bill 510 and House bill 1332. Watch them very closely. The bills are very similar though not conferenced at this point.  They are broad sweeping reform bills, just as vague as HR 875 and could be just as, if not more, detrimental to small scale farmers and processors. Unlike HR 875 which exempts some activities which fall under the Federal Meat Inspection Act or the Poultry Products inspection Acts and specifically excludes in section 3.14 any farm, ranch, orchard, vineyard, aquaculture facility, or confined animal-feeding operation, there are no such express exceptions in these other two bills. The record keeping, product testing and HACCP requirements (all electronically of course) would be, in my opinion, overwhelming for most small scale operations. Look what HACCP did to our slaughterhouses-- gone! Any bill that will require one-size rules must be watched intently. These two bills( S510 and HR 1332)  have bi-partisan support so don't let them off your radar by any means. Read them for yourself.

http://www.govtrack.us/congress/billtext.xpd?bill=s111-510
http://www.govtrack.us/congress/billtext.xpd?bill=h111-1332

 
In the meantime, here's my submission to the Broader View Weekly, a small hometown paper, I write for.
 
Food Safety Bills of 2009
By Martha Goodsell
Internet users are up in arms regarding House Bill 875, the Food Safety Modernization Act, but much of what is circulating over the network is hype and inflated fears. However, that’s not to say that HR 875 is not a threat to both small scale and organic farmers and those consumers who support such farms. In its present form, it is a very real- though not a highly probable- threat. HR 875 is not the only food safety bill recently proposed following the peanut butter contamination. There are six other bills that must be monitored. 
There are two federal agencies charged with food safety. The United States Department of Agriculture (USDA) is responsible for wholesome meat and poultry under the guidelines of the Federal Meat Inspection Act (FMIA) and the Poultry Products Inspection Act (PPIA). The Food and Drug Administration (FDA) on the other hand, has the responsibility for oversight of manufactured food products, and all those products not under USDA jurisdiction. Unlike the USDA who inspects products and ensures Hazard Analysis Critical Control Points (HACCP) compliance in slaughterhouses and in meat and poultry product processing facilities, the FDA is charged with the annual inspection of manufacturing facilities. Only a few products monitored by the FDA are required to have and follow HACCP plans. 
Thanks to Upton Sinclair, and his book The Jungle, the USDA oversight on meat and poultry is much stricter than for other food products currently. Many of these bills are looking to change that, by requiring food manufacturers to have and follow HACCP plans, which includes strict record keeping requirements. Unfortunately HACCP implementation poses a greater obstacle to small plants compared to larger facilities. Thus, the single greatest problem with all of these newly proposed food safety bills are that they are not designed with small and large operations in mind. Rather, they are written with a “one-size-fits-all” approach. Knowing that many small operations will chose to close their doors, rather than comply with testing, record keeping, and all sorts of other requirements, these bills indirectly interfere with the rights of individuals to choose their foods. This threat of losing small farms – and thus one’s food choice- is feeding the current hysteria. 
To read more about the bills visit http://www.govtrack.us/congress/legislation.xpd. Please contact your Washington representatives to express your support or opposition to the bills. Let’s take a look at what’s pending:
HR 875 - The Food Safety Modernization Act, sponsored by Rosa Delauro (D- CT) (whose husband works for Monsanto) has 30 co-sponsors at this time. This bill splits the FDA into two units: one which would monitor food and the other to monitor medicinal drugs and medical devices. (The FDA is charged with monitoring both food and drugs so this is only a new approach, not a new duty.) The bill would increase the number - or frequency - of inspections. HR 875 would require HACCP plans. It would also require imports to meet US standards. (Currently as long as a foreign country has an “equivalent” inspection system, product is accepted with little or no further questions or testing.)  HR 875 would establish a national traceability system that would require tracking “the history, use, and location of an item of food”. Section 3.13A specifically exempts those operations currently under USDA inspection under the FMIA or PPIA acts and section 3.14 exempts any farm, ranch, orchard, vineyard, aquaculture facility, or confined animal-feeding operation.
S425 - Food Safety and Tracking Improvement Act, sponsored by Sen. Sherrod Brown (D-OH) has no co-sponsors. This senate bill would amend the Federal Food, Drug, and Cosmetic Act to provide for the establishment of a traceability system so that each article of food shipped in interstate commerce would require a full record keeping system. An audit system would provide for compliance. Premise registration would be mandatory.  S425 amends the FMIA so that any person that has reason to believe that any carcass, part of a carcass, meat, or meat food product is inappropriately transported, stored, distributed, or otherwise mis-handled resulting in adulteration or misbranding shall serve notice to the secretary who shall then call on industry to withdraw the product. The PPIA and the Egg Product Inspection Act (EPIA) would be amended in the same fashion. 
HR 814 - Tracing and Recalling Agricultural Contamination Everywhere Act, sponsored by Diana DeGette (D-CO) has five co-sponsors. HR 814 would direct the Secretary of Agriculture to establish a traceability system for all stages of manufacturing, processing, packaging, and distribution of food. HR 814 would amend the FMIA by requiring identification and traceability for all cattle, sheep, swine, goats, and horses, mules, and other equines presented for slaughter. Without an identification number, farm records, and the ability to trace an animal’s movement, such an animal can not be presented for slaughter. The PPIA and the EPIA would be amended to establish similar provisions for poultry and poultry products and for eggs and egg products. It is interesting to note that nothing contained in HR 814 supports Country of Origin Labeling (COOL) requirements.
 
HR 759- The Food And Drug Administration Globalization Act, sponsored by John Dingell (D- MI) with eight co-sponsors, would require every food facility that manufactures, processes, packs, transports, or holds food for consumption in the United States to develop and implement a HACCP and food safety plan. HR 759 would require that all food facilities use standard lot numbers and that all facilities including food processors, farms and restaurants, keep electronic records. Food facilities must earn an accreditation status. This bill instructs the FDA to establish production standards for fruits and vegetables and to establish Good Agricultural Practices for produce and requiring those that grow and sell fresh fruits and vegetables to have a HACCP plan. COOL would be required. Only certified laboratories could conduct sampling and testing of food to ensure compliance. 

S 429 - Ending Agricultural Threats: Safeguarding America's Food for Everyone (EAT SAFE) Act of 2009, sponsored by Senator Robert Casey (D- PA) with only one co-sponsor, focuses on imported and smuggled foods. This bill directs the Secretary of Agriculture to establish food safety and agroterrorism training programs. Notification of recalled food products would be provided to the public while notice of smuggled food products would be reported to the public and to the Department of Homeland Security (DHS). This bill amends the FMIA and the PPIA to establish civil penalties for failure to present imported meat and poultry products for inspection and requires the use of federally certified food safety labs for product testing. A food-borne illness education and outreach grant program would be established. 
S 510 - A bill to amend the Federal Food, Drug, and Cosmetic Act with respect to the safety of the food supply sponsored by Senator Richard Durbin (D-IL) has 8 co-sponsors currently. This bill addresses the concerns of government to the use of or exposure to certain foods. If the Secretary of Agriculture believes that there is a reasonable probability that the use of or exposure to an article of food will cause serious adverse health consequences or death to humans or animals, each person who manufactures, processes, packs, distributes, receives, holds, or imports such article shall provide access to that food article and to all records relating to such article. HACCP and preventive controls would be required for all manufacturers, processors, packers, distributors, receivers, holders, or importers. Safety standards would be established for production and harvesting of fruits and vegetables. All premises would be required to be registered and pay annual inspection fees. The Secretary of Homeland Security, in consultation with the Secretary of Health and Human Services and the Secretary of Agriculture, would facilitate public-private partnerships to help unify and enhance the protection of the agriculture and food system of the United States; including the sharing of information and intelligence relating to agriculture and the food system. The three agencies would identify best practices and methods for improving the coordination among Federal, State, local, and private sector preparedness and response plans for agriculture and food defense and would recommend methods to protect the economy and the public health of the United States from the effects of animal or plant disease outbreaks, food contamination and natural disasters affecting agriculture and food.
HR 1332 - Safe FEAST Act of 2009,  sponsored by Jim Costa (D-CA) with 19 cosponsors. This is very similar to the senate bill S 510. All food manufacturers, processes, packers, or those who hold food for sale would be required to be registered. If the Secretary determines that food manufactured, processed, packed, or held by a facility has a reasonable probability of causing serious adverse health consequences or death to humans or animals, the Secretary may suspend the registration of the facility. In addition to having access to records and the product, the Secretary may direct the facility to order a recall. In addition to HACCP plans and record keeping requirements facilities would be required to: follow sanitation procedures, establish hygiene training, establish monitoring programs for environmental pathogen controls, implement an allergen control program, develop a recall contingency plan; follow Good Manufacturing Practices (GMPs); and verify source suppliers. HR 1332 would encourage the building of domestic capacity through coordinated councils which would in part identify potential threats to the food supply and would establish surveillance systems through integrated networks. 

This message originated from or was forwarded by:
Chrys Ostrander
Chrysalis Farm @ Tolstoy
Organic Micro-permaculture
33495 Mill Canyon Rd.
Davenport, WA 99122
509-725-0610
chrys AT thefutureisorganic.net
http://www.thefutureisorganic.net

Please consider making a contribution towards my sustainable agriculture organizing work.
https://www.paypal.com/cgi-bin/webscr?cmd=_s-xclick&hosted_button_id=424800

"From each according to their ability, to each according to their needs"
Louis Jean Joseph Charles Blanc - "The organization of work" 1839
Karl Marx - "Critique of the Gotha Program" 1875

"The purpose of agriculture is not the production of food, but the perfection of human beings"
Masanobu Fukuoka (February 2, 1913 - August 16, 2008)  - "One Straw Revolution" 1978

"The community whose every member possesses the art of deriving a comfortable subsistence from the smallest area of soil... will be alike independent of crowned-kings, money-kings, and land-kings...."
Abraham Lincoln: Address to the Wisconsin State Agricultural Society, Milwaukee, Wisconsin, 1859

"We will never have an organic future and a stable climate until we pull all the troops out of Iraq
and redirect our annual $650 billion military budget to greening the economy and guaranteeing
a sustainable environment and economic justice for everyone."
Ronnie Cummins, National Director, Organic Consumers Association
at the "Farms Not Arms" public forum and protest in Manhattan, September, 2007



Thank you.

  • [Market-farming] A National Voice to Defend Sustainable Ag from Bad Food Safety Law, Chrys Ostrander, 03/24/2009

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