|The Food Safety Modernization Act: Submit Comments by November 22 (deadline extended)|
Paul Muller of Full Belly Farm shared some of his thoughts about the Food Safety Modernization Act in the August 5 issue in the farm’s Save CSA newsletter (reprinted here). Many of our local growers will be similarly affected by these new regulations, and this issue deserves the attention of anyone who supports biodiversity in agriculture. Please consider making a comment to the FDA. More information and helpful guidelines are available here. A sample letter is available here for download
I am sitting in the kitchen late Sunday evening putting some thoughts together regarding proposed rules to implement the Food Safety Modernization Act (FSMA), a massive new set of regulatory proposals that are open for public comment until the middle of November. FSMA will affect many aspects of our integrated farm: the compost we apply; the management of our sheep and chickens; the record keeping, and the ultimate authority over the definition of ‘Good Agricultural Practices’.
Many of the farm practices used by entry level farmers use the same integrated design as at Full Belly, for example, pastured poultry as a cornerstone of soil restoration and fertility needed to produce healthy fruits and vegetables. FSMA will be a huge new barrier to entry for these beginning farmers. At their heart, these ‘sustainable strategies’ employ the microbial world as workers in a system to create a healthy plant/soil/human ecology. FSMA sweeps all of these strategies into a category of suspect practices and overlooks many issues that should be at the heart of today’s food safety discussion.
Even the title, ‘food safety’ and ‘agricultural modernization,’ delivers a shot over agriculture’s bow, implying that the present system of food production is both unsafe and backwards, ignoring the incredible volume of safe food delivered by American farms to the marketplace each day.
The dimensions of food safety need to consider the causes of diseases resulting from highly processed foods. Melanie Warner, in the Daily Beast writes: “The 3,000 annual deaths and 130,000 hospitalizations due to food borne illness, though tragic, are miniscule compared with other deaths related to our diet. Every year at least 310,000 Americans go to an early grave and many more are sickened because of largely preventable diet-related conditions such as heart disease, diabetes, obesity, hypertension, strokes, and some cancers. The big problem with our food supply isn’t pathogens, it is processed food. We’re being killed not by E. coli, salmonella, or campylobacter, but by the nutritionally hollow contents of the bags, boxes, and fast-food clamshells that have managed to pass as nourishment in our society.” Likewise, the issues related to GMO crops, their juggled plant proteins and the related massive use of herbicides are also ignored in FSMA.
Full Belly continues to take seriously our responsibility to produce wholesome, healthy food. We have a focus on healthy soil as the cornerstone of healthy plants and nutritious food. We focus on bringing fruits and vegetables to you in as short a time as possible. There is however much that we don’t know and in these cases, we act with the best knowledge and best practices that minimize risk to our customers. Certainly, FSMA emphasis on traceability and sanitation is very important. We have an internal food safety plan here at the farm and continue to educate our crew about both safe food handling and personal hygiene. We operate in a pretty limited geographic arena – primarily the SF and Sacramento regions, so that our impact is pretty local and doesn’t span multiple states. We also seek to deliver our products largely within one day of picking.
We adhere to the conviction that diversity creates ecological stability. That is, a healthy balanced soil is both microbiologically rich and quite alive. A mere teaspoon of healthy soil can contain billions of soil organisms. Balance among those organisms may in fact ward off the invasion of pathogens. One problem with the FSMA approach is that it fails to take into account the importance of the overall health of a particular farming system. For example, Full Belly Farm’s sheep are browsing on cover crops and leftover crop residue. We assert that a grazing animal, on healthy pasture eating plants grown in well balanced soil, will produce a different stomach ecology than a confinement-fed animal where a grain diet fattens it quicker but requires doses of antibiotics and hormones.
The FSMA has a bias against biological farming systems. We remain humbled by the complexity of growing healthful food and insist that the “food safety” regulators remain open to biologically integrated organic systems.
Note: Several organizations (Community Alliance with Family Farmers, National Sustainable Agriculture Association and Wild Farm Alliance) will soon be publishing guidance for anyone who would like to submit comments to the FDA regarding their Proposed Rules. Meanwhile, submit your comments to the FDA online