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  • From: "Pete Gasper, Gasper Family Farm" <farmer1@gasperfarm.com>
  • To: permaculture <permaculture@lists.ibiblio.org>
  • Subject: Re: [permaculture] Food Safety Modernization Act | North Carolina Health News | Competing Public Health Needs Complicate Proposed Food-safety Rules | Exemptions Info
  • Date: Mon, 16 Sep 2013 17:33:11 -0500

The article mentions the 1 million gross sales exemption. That is deceptive, there are multiple exemption levels depending on which exact set of regulations and section of that you're dealing with. There are various requirements for smaller operations as well with exemption levels at 500k and 250k. And there is also talk that the FDA can unilaterally reject a farms exemption.

It has been estimated that the cost of compliance for a farm grossing 250k (about enough to support 1 full time farmer) at $12k. Way more than enough to sink most farms.

Pete

On 09/16/2013 02:21 PM, Lawrence London wrote:
Food Safety Modernization Act | North Carolina Health News | Competing
Public Health Needs Complicate Proposed Food-safety Rules | Exemptions Info

http://www.northcarolinahealthnews.org/2013/08/30/competing-public-health-needs-complicate-proposed-food-safety-rules/

North Carolina Health News

Competing Public Health Needs Complicate Proposed Food-safety Rules
August 30, 2013 by
Editor<http://www.northcarolinahealthnews.org/author/editor/>in
Environmental
Health<http://www.northcarolinahealthnews.org/category/environmental-health/>,
Featured<http://www.northcarolinahealthnews.org/category/featured/>,
Infectious
Disease<http://www.northcarolinahealthnews.org/category/infectious-disease/>,
Public Health<http://www.northcarolinahealthnews.org/category/public-health/>

In 2011, President Obama signed the Food Safety Modernization Act into law.
But in an attempt to address one public health problem – food safety – the
law may create complications in dealing with other public health issues.

*By Rose Hoban*

As new federal food-safety rules loom beyond the horizon, hundreds of
farmers and food processors gathered this week at the state fairgrounds in
Raleigh for N.C. Agriculture Commissioner Steve Troxler’s annual Food
Safety Forum.

“We all realize food safety is a public health issue,” Troxler said. “But
it’s also an agriculture issue.”

Since passage of the Food Safety Modernization Act (FSMA) in January 2011,
Troxler has been using the forum to help farmers and processors understand
what will be expected of them by the new law.

But he’s also encouraged people from the state agricultural community to
weigh in as the U. S. Department of Agriculture and the Food and Drug
Administration create rules and regulations mandated by the law.

North Carolina Agricultural Commissioner Steve Troxler convened farmers
from around the state this week for an annual food-safety conference. Photo
credit: Rose Hoban.

“This really became a focus,” Troxler said. “The state’s partnership with
the FDA will be instrumental, and it’s actually in the law that the
partnership has to exist. We’re building relationships and sorting out what
the partnership will look like.

“It’s kind of a shotgun marriage, but we’ve got to deal with it.”

*From the dirt*

The 2012 recall of cantaloupes grown in eastern North Carolina found
contaminated with the bacteria Listeria monocytogenes and a similar recall
of melons from a Colorado farm the year before were still fresh in many
people’s minds at the forum.

According to the FDA, the North Carolina cantaloupes were sold in states
from Florida to Maine. And even though the recall affected only one farm’s
produce, the rest of the industry felt ripples. No one was sickened by that
2012 recall, but the 2011 Colorado farm recall led to dozens of infections
and at least one death.

It’s recalls such as these – going back to the highly publicized recalls of
bagged California lettuce in the 1990s – that spurred Congress to create
the FSMA.

All cantaloupe growers felt the effects of the most recent recalls, said
Matt Solana, vice president of operations for the Jackson Farming Company,
which grows cantaloupes, watermelons and honey dews, as well as
strawberries and a host of other fruits and vegetables.

The porous skin and rough texture of some melons makes them more capable of
harboring pathogenic bacteria. Photo courtesy S.Zelov, flickr creative
commons

Jackson Farming has farms in North Carolina and several other states.

“When the [Colorado] issue in 2011 came up, we were already done for the
seasons, which was a good thing, because the market crashed,” Solana said.

“Then last year, there was a recall of North Carolina product. There wasn’t
any of ours in there, but the phone started ringing off the hook: ‘Is this
your cantaloupe? Can I serve it to my church group on Sunday?’ ‘Yes, ma’am,
you can.’ ‘Would you come over and eat it with me?’”

Solana said a decade ago, his company’s food-safety regimen consisted of
cleaning up, sweeping and hosing down the packing facility with bleach
every day and washing the fruit. But that time, and the small expense, was
driven by market demands, not legislation.

Click on these links to read and comment on the Proposed Produce Standards
Rule<http://www.regulations.gov/#%21documentDetail;D=FDA-2011-N-0921-0199>or
the Proposed
Rule for Preventive Controls for Human
Food<http://www.regulations.gov/#%21documentDetail;D=FDA-2011-N-0920-0188>
“Eastern
cantaloupe gets wet,” he said. “You have mud and dirt and that. So the
chain stores wanted brushed, washed and chlorinated cantaloupe to come into
the store.”

But this past year, Solana’s company spent more than a half-million dollars
to enclose its packing house and put stainless steel on every packing
surface, and FSMA rules aren’t even in place yet.

The changes drove Jackson Farming’s food-safety costs up about a thousand
fold.

“Take away the $330,000 that we just spent to redo the cantaloupe line and
shed, and it’s $240,000 in expenses this year in people and training and
equipment and chemicals,” Solana said, noting that those are expenses that
will eventually drive up the cost of a piece of fruit as farmers look for
return on their investment.

But the reality is that measures taken by farmers might not eliminate the
possibility of a recall.

“You’re dealing with products that are grown in the dirt, so ‘from farm to
fork’ means from dirt to your kitchen counter,” Solana said.

“But how many hands touched it in the grocery store? You’re not the only
person who’s touched that cantaloupe. It goes in the shopping cart that’s
had multiple use, it goes down a belt in a grocery store that’s had
multiple use, before it gets home to your place.”

Fresh produce at the State Farmers Market in Raleigh. Proposed food-safety
rules might adversely affect farmers selling more than $500,000 worth of
produce each year. Photo courtesy Kel and Val, flickr creative commons.

*Small processors affected*

It’s expenses such as this that worry Scott Marlow, an agricultural
economist who heads the Rural Advancement Foundation International, a
not-for-profit organization that advocates for small family farms.

Marlow’s not a fan of FSMA, in particular because he believes that, in the
end, large farm organizations will have an easier time finding the money to
adhere to the regulations than the small farmers he represents.

“There is no way for us to eliminate the existence of pathogens; it’s not
going to happen,” he said. “What we need to do is design a way of getting
product safely from farms to people.

“But the way that FSMA is being implemented is by increasing the regulatory
burden. It becomes a fixed cost that’s high, and it becomes harder to do
for small producers.”

Marlow said the law is also the problem, for reasons related to cost.

“Let’s look at where the food-safety outbreaks have come from,” he said.
“Are they coming from small-scale producers? No. They’re coming form the
large-scale plants, the large-scale peanut processor in Georgia, the
large-scale salad producers in California.”

“Smaller-scale producers are not viable because they can’t absorb that
added fixed cost. So you have one plant that everyone has to go to,” Marlow
said, explaining that having everyone processing through a large plant
increases the chances of cross-contamination.

Proposed rules under the Food Safety and Modernization Act could make it
more difficult for small- and medium-scale processing plants to survive.
Photo courtesy saidunsaids, flickr creative commons

“If I buy beef direct from a farmer and his beef has E. coli, I get sick
and my family gets sick and that’s it,” he said. “But if that farmer sends
that cow to a processing plant that handles thousands of cows a day, then
thousands of cows and, subsequently, thousands of people get exposed to it.”

Marlow said the goal should be to create a process that minimizes the
possibility of cross-contamination, and that, in many cases, smaller is
better.

*Exemptions may not help*

According to the FDA speakers at the food-safety forum this week, the
proposed rules have exemptions for farms that have less than a half-million
dollars in annual sales.

But Roland McReynolds, executive director of the Carolina Farm Stewardship
Association, said while a half-million dollars sounds like a lot, it’s
pretty easy for a small farm to top that and thus be ineligible for an
exemption.

“If you have 100 acres of corn and beans and a one-acre you-pick strawberry
operation, your total sales of food will be well over a half million,” he
said, noting that it takes that much volume for a farmer to make a modest
profit.

And McReynolds said it’s especially easy for small cooperatives to reach a
half-million dollars in sales.

“Several farms together – like a multi-farm community-supported agriculture
group or Eastern Carolina Organics in Durham – if you’re one of those kinds
of businesses, the USDA economic analysis says you need at least a million
in sales to be economically viable, and that’s what they’re doing,” he said.

“They’ll all be subject to these rules,” McReynolds said. “So the exemption
won’t mean much.”

He called the new rules a “serious threat,” and said many in the state’s
Department of Agriculture and Consumer Services are privately quite
concerned, as are the many small farmers in the state who have driven the
local-food movement that’s revitalized large swaths of North Carolina
agriculture.

Local farmers deliver their harvested produce to a central market in North
Carolina in July 1981. Photo courtesy National Archives and Records
Administration.

McReynolds said there needs to be balance with food safety, but that the
FDA may be “throwing the baby out with the bath water.”

“We need to be eating more fresh fruits and vegetables,” he said, and rules
that might limit accessibility to fresh produce would, in the end, be
counterproductive.

“The public health crisis around our food today is about obesity and heart
disease and diabetes and cancer. That’s what’s killing 800,000 people a
year.”

FDA officials who spoke at the food-safety forum in Raleigh were explaining
how the rules would affect farmers, but they also encouraged input from the
community.

“We feel very strongly that food safety is a priority, and is [farmers']
priority as well,” said Jenny Scott, an official with the FDA Office of
Food Safety.

“Farmers should take a look at what we’re requiring in the proposed rules
with regard to food safety,” she said.

Tagged FDA<http://www.northcarolinahealthnews.org/tag/fda/>, Food and Drug
Administration<http://www.northcarolinahealthnews.org/tag/food-and-drug-administration/>,
food poisoning<http://www.northcarolinahealthnews.org/tag/food-poisoning/>,
food safety<http://www.northcarolinahealthnews.org/tag/food-safety/>, Food
Safety and Modernization
Act<http://www.northcarolinahealthnews.org/tag/food-safety-and-modernization-act/>,
NC Department of Agriculture and Consumer
Services<http://www.northcarolinahealthnews.org/tag/nc-department-of-agriculture-and-consumer-services/>,
USDA<http://www.northcarolinahealthnews.org/tag/usda/>
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