permaculture

[Keith Johnson <keithdj@mindspring.com>]

http://www.activistpost.com/2010/12/why-tester-amendment-does-not-help.html

These small producer exemptions are only for "qualified facilities" 
and only pertain to subsections (a) through (i) and subsection (n) of 
S.510 -- as outlined on page 5, line 15 in the Tester Amendment:

        (2) EXEMPTION. --A qualified facility--

        (A) shall not be subject to the requirements under
   subsections (a) through (i) and subsection (n) in an applicable
   calendar year.

Therefore, even a "very small business" making less than "$500K per 
year," doing business "within 275 miles" and directly with "end-user 
customers" is still required to adhere to all of the regulations in 
the remaining subsections of the bill.

Ironically, the Tester Amendment clearly states that in order for a 
*small producer to become a "qualified facility" for these 
exemptions*, they must submit the following to the Secretary upon request:

   * 3 years of comprehensive financial records indicating less than
     $500K in gross sales (Pg. 4, Line 11)
   * I. Documentation that the owner, operator or agent of the
     facility has identified potential hazards associated with the
     food being processed, is implementing preventative controls to
     address those hazards, and is monitoring the preventative
     controls to ensure that such controls are effective (Pg. 5 line
     20).
   * II. Documentation (which may include licenses, inspection
     reports, certificates, permits, credentials, certification by an
     appropriate agency (such as the State Department of Agriculture)
     or other evidence of oversight), as specified by the Secretary
     that the facility is in compliance with state, local, county, or
     other non-Federal food safety law (Pg. 6, Line 5).

Because small producers are being forced to jump through stringent 
local and Federal regulatory hoops just to qualify, the bill appears 
to be designed not to make it "illegal" to sell homegrown goodies, as 
some suggest, but to make the system so cumbersome that small 
producers will say /forget it/ and give up their local food business 
-- which is what many have speculated is the hidden corporate agenda 
of the bill.

*The bottom line is that it's common sense that local organic farmers 
produce a healthier and more nutritious product than their 
factory-farm counterparts, yet it is those promoting health who will 
suffer the most under this food "safety" bill.*
--

Keith Johnson
"Be fruitful and mulch apply."
Permaculture Activist Magazine
PO Box 5516, Bloomington, IN 47407
(812) 335-0383
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