permaculture

[Keith Johnson <keithdj@mindspring.com>]

http://www.grist.org/article/food-2010-12-03-the-real-nitty-gritty-on-small-farms-and-food-safety-bill

   (snip)

   And what if the small producers simply ignore the whole thing, and
   don't produce all the documentation needed to register and conform
   with the "guidance document" and participate in the study and be
   part of the GAP program? Presumably they'd be subject to the very
   strict penalties articulated in S. 510, which is up to 10 years'
   imprisonment.

   I hate to be a cynic, because I like to think that supporters of
   this amendment have had the best interests of smaller food
   producers in mind in pushing for an exemption. But when you review
   the fine print, you can't help but conclude that Tester-Hagan
   represents an unprecedented intrusion by government into the lives
   of small farms and food producers.

   (snip)

   With respect to farms, the exemption is simpler. Under the
   Tester-Hagan amendment, a qualifying farm -- one that grosses
   under $500,000 and sells more than half its products directly to
   qualified end users -- is exempt. Period. There is no need to
   provide special documentation or go through any process, beyond
   putting a label or displaying a sign with the farm's name and
   address.

   Without the Tester-Hagan amendment, under S. 510, these farms
   would be subject to the produce safety standards or, as Gumpert
   discusses, what is often termed "good agricultural practices" or
   GAPs. With Tester-Hagan, these small, direct-marketing farms do
   NOT have to comply with GAPs.

   (snip)

   Nothing in S. 510 changes the underlying reality that FDA has
   broad authority, already, to visit any farm or facility where they
   suspect any kind of food safety issue.

   The ongoing debates about raw milk, raw-milk cheeses, and how FDA
   treats bacteria more strictly than they do chemical residues and
   genetically-engineered foods are not going away, whether this bill
   ultimately passes or not. But those issues are not at the heart of
   the bill, nor are they the reason the Tester amendment was
   proposed and supported by many sustainable agriculture groups.

   (snip)

   the reassurances people are offering now count for nothing.
   Everyone affected by this legislation has to assume the provision
   is there for a reason, and will be carried out.

   Nor has anyone said anything about what the "guidance document"
   that FDA must produce within a year might contain. I presume
   that's because no one knows, and didn't choose to let their
   imaginations go a little like I did.

   Many farmers will essentially be on the defensive, potentially
   vulnerable if the FDA decides for some reason to do a sweep (as it
   did earlier this year on more than 100 cheesemakers).

   Bottom line, the FDA controls the exemption process, and is under
   mandate to collect vast amounts of new data about smaller
   enterprises, many of which will likely be farms. We can hope the
   agency is benevolent, but that is not its history.

   (snip)

   under existing law, the farmer who makes a few jars of jam from
   his produce and sells them at a farmers market may have to
   register with the FDA under the Bioterrorism Act because he
   doesn't qualify as either a "farm" or a "retail food
   establishment." The same is true for the small-scale bread-maker
   or cheese-maker. And under S. 510, that
   farmer/bread-maker/cheese-maker would have to go through the full
   HACCP-type process. Under the Tester-Hagan amendment, that
   farmer/bread-maker/cheese-maker would now be exempt from both the
   registration requirement and the HACCP process as a "retail food
   establishment."

   it is, at its heart, damage control. That isn't the fault of Sens.
   Tester or Hagan or any of the people who advocated for this
   amendment. It's due to agribusiness's capture of FDA and much of
   Congress --  a problem that has developed over decades and that we
   will need to spend the next decade fighting.



--

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