permaculture

[Lawrence London <lfljvenaura@gmail.com>]

---------- Forwarded message ----------
From: Steve Gilman <stevegilman@verizon.net>
Date: Fri, Sep 6, 2013 at 7:52 AM
Subject: Re: [SANET-MG] Cornucopia - Food Safety Modernization Act
To: SANET-MG@lists.ifas.ufl.edu

Hi All,

FDA has very specific rules for Docket Comments on the proposed food safety
regulations.

Unfortunately, Cornucopia has put out a major media blast that says all you
have to do is fill out their
inclosed proxy and then they will gather them up and "hand deliver" them to
FDA personally.

The Comment rules are clear, however, that even if 100,000 proxies were
delivered to FDA -- they
would ONLY COUNT AS ONE COMMENT. The same goes for those looking to sign
any petitions or
other standardized replies -- the rules are clear -- only individualized
Comments will be counted
here.

EVERY VOICE is important on this important issue. Those farmers who might
think they are somehow
"exempt" may easily not be. The proposed metrics are not science-based --
but they have the
authority to greatly impact how farmers' farm and Eaters' ability to make
localized choices in the
marketplace.

For a robust overview of the problems and issues with the proposed rules as
well as details on how to
Comment, please go to <http://sustainableagriculture.net/fsma/>


[Note: no proxy voting - collections of proxy votes submitted by one
individual count as one vote]
---------- Forwarded message ----------
From: Melody Morrell <morrell@cornucopia.org>
Date: Thu, Sep 5, 2013 at 5:40 PM
Subject: [SANET-MG] CORNUCOPIA: Food Safety Modernization Act
To: SANET-MG@lists.ifas.ufl.edu

Organic and local farmers are concerned that the FDA's new food safety rules
may force them out of business.

Please visit www.cornucopia.org/food-safety for more information.

In response to deadly outbreaks involving spinach, peanut products and eggs,
Congress acted decisively three years ago to pass the Food Safety
Modernization Act (FSMA).  Giant factory farms and uninspected imports are,
literally, poisoning US citizens.  Better oversight is needed but it looks
like regulators and corporate agribusiness are using the FSMA to
simultaneously competitively crush the organic and local farming movements.

Unfortunately, the FDA's draft regulations designed to implement the new law
appear to ignore the will of Congress. Instead, the regulations would
ensnare the country's safest family farmers in burdensome regulations in a
misdirected attempt to rein in abuses that are mostly emanating from
industrial-scale factory farms and giant agribusiness food processing
facilities.

SHORTAGES of FARM-DIRECT PRODUCE?

Small farms forced out of business?

We thought we had won a victory with the Tester Amendment adopted by
Congress exempting farmers doing less than $500,000 in business from these
new rules, but the FDA seems more interested in a "one-size-fits-all" food
safety law.

In reality, these small farms are not really exempt.  The FDA is proposing
that the agency can, without any due process, almost immediately force small
farms to comply with the same expensive testing and record-keeping

requirements for factory farms.   The added expense and record-keeping time

will potentially force many small farms - those selling to local farmers
markets, co-ops and restaurants - out of business instantly.

Just as important, for farms over $500,000 in volume (and there are plenty
of excellent medium-sized organic farms in the $1-$3 million range or
larger), some of the provisions will not only be economically damaging (some
farmers might not survive this) but actually prohibit some basic practices
in the Organic Food Production Act.  Yet if all farms, conventional as well
as organic, had to follow the organic regulations for manures/composts, we'd
have safer produce.

These new rules are just as much about protecting industrial agriculture,
and their giant factory farms, as they are about protecting human health.

Consider:

1.            The FDA has conflated the number of foodborne illnesses that

originate from farm production (seed to harvest) with contamination that
takes place later, in processing/distribution - in justifying supposed
economic benefits from the new rules.

2.            The FDA fails to recognize that some processed crops, grown

in certainm regions, are the genesis of 90% of dangerous outbreaks!

Thousands of individual illnesses come from food processing practices - not
farming practices - for fresh-cut/bagged salads, greens, and sprouts.  And
there are no outbreaks linked to many kinds of U.S.-grown fruits and
vegetables.  Yet these very onerous rules will apply to all farmers.  We
need to target our tax money where it will do the most good: addressing
high-risk areas and practices.

3.            Almost all pathogenic pollution that contaminates ground and

surface water, fertilizers and even the air comes from giant concentrated
animal feeding operations, or CAFOs (factory farms), not from fruit and
vegetable growers.  In fact, the riskiest pathogens are found on CAFOs.

But the FDA proposes nothing to address sick livestock in animal factories
and their pathogen-filled manure that's contaminating surrounding rural
communities, farms and our food supply.

The giant spinach E. coli contamination a few years ago was from an organism
commonly found in feedlot cattle.  And, according to FDA news releases, the
recent Cyclospora outbreak, sickening customers eating bagged salad at Red
Lobster and Olive Garden in multiple states, was initially traced back to
the giant Taylor Farms' Mexican operation - not U.S. family farms.

To guarantee the supply of local, fresh, safe and nutritionally superior
food, we must focus food safety rules on the truly risky operations and
practices - this is not what the FDA's proposed rules do.

NO MORE ORGANIC EGGS?

Just like imported/factory farm produce might be dangerous and require
regulatory oversight, the 2010 salmonella outbreak in eggs, centered in
Iowa, shone a spotlight on industrial-scale egg houses confining tens of
thousands of hens in filthy and dangerous conditions.

The salmonella outbreak led to this new egg guidance.  Even though there is
scientific evidence tying higher rates of pathogenic contamination to older,
massive factory farms with cages and forced molting (practices banned in
organics), the FDA is zeroing in on flocks with outdoor access (certified
organic).

Their new guidance, on the one hand, will make it difficult, expensive and
maybe even impossible to have medium-sized flocks of birds outside.  At the
same time, the FDA has colluded with the USDA's National Organic Program to
say that tiny "porches," which hold only a minute fraction of the flock,
will now legally constitute "outdoor access."

Cornucopia might very well be headed to court over the governmental abuses
in violating the spirit and letter of the organic law in regards to
confining organic livestock (poultry).

We are on a tight timeline. Additional talking points and background are
available at: www.cornucopia.org/food-safety

Mark A. Kastel

Codirector and Senior Farm Policy Analyst

PS:  Please forward this webpage to anyone who cares about the quality of
their food: www.cornucopia.org/food-safety