permaculture

["Lawrence F. London, Jr." <lflj@bellsouth.net>]

-------- Original Message --------
Subject: The Food Safety  vs. Market and CSA farmers?
Date: Wed, 22 Dec 2010 22:41:08 -0500
From: Leigh Hauter <bullrunfarm@hughes.net>

As I wrote last e-mail the tester amendment exempts farmers with
less than half a million gross business,  who sold in state or within
275 miles of the farm from the food safety bill.

However, half a dozen people wrote me off list saying "Yes but I
heard it will still effect me by..... " So I went back and did some
more research and found out that   the truth is 'NO', that's not
true.  This bill does not apply to farmers who are covered buy the
Tester amendmenbt.

Here are other ways the food safety bill was amended to make sure
farmers who fall under the Tester Amendment exemptions will not be
affected by this bill.

The list comes from the National Sustainable Agriculture Coalition's
webpage  (http://sustainableagriculture.net/blog/)

    * Senator Sanders (I-VT) providing FDA authority to either exempt
farms engaged in low or no risk processing or co-mingling activities
from new regulatory requirements or to modify particular regulatory
requirements for such farming operations
.
    * Senator Bennet (D-CO) to reduce unnecessary paperwork and
excess regulation required under the preventative control plan and
the produce standards sections of the bill, including instructions to
FDA to minimize the number of different standards that apply to
separate foods, to make requirements scale appropriate, and to
prohibit FDA from requiring farms and other food facilities to hire
outside consultants to write food safety plans.

    * Senator Debbie Stabenow (D-MI) to provide for a USDA-delivered
competitive grants program for food safety training for farmers,
small processors and wholesalers, with a priority on small and
mid-scale farms.
and require FDA to apply sound science to any requirements that might
impact wildlife and wildlife habitat.

    * Senator Sherrod Brown (D-OH) to exempt farmers from extensive
and expensive traceability and recordkeeping  requirements  if they
sell food directly to consumers or to grocery stores, to allow
labeling that preserves the identity of the farm through to the
consumer to satisfy traceability requirements, and to in most cases
limit farm recordkeeping to the first point of sale when the product
leaves the farm.

So my reading of this is that if you come under the tester amendment
then Brown further amended the bill to exempt everyone from record
keeping and labeling requirements.   Bennet amended it to further cut
down any paperwork,  and to make what paperwork  there is farm size
appropriate and also prohibited the bill from forcing anyone to hire
and outside consultant to meet the laws requirement.  Sanders
exempted   farms that do low risk processing and co-mingling of if
the FDA chose to modify the requirements in such a way that they
wouldn't apply to small farmers.  And finally Stabenow amended the
bill to provide grant money to provide small and medium farmers,
processors and wholesalers food safety training.

Of course the devil is always in the details  (which the FDA will be
writing up) but all in all these additional amendments further
exempted small farmers from the food Safety Bill's requirements.

In other words,  the requirements of the food safety bill  has been
written in such a way to make sure that it only applies to farmers
and processors who gross over $500,000 and who are not involved in
direct sales.

Leigh