The Future is Organic Blog

From Western Organization of Resource Councils (WORC):


http://www.worc.org/userfiles/file/Food%20Safety%20Act2.pdf

(Thanks to Jill Richardson: http://lavidalocavore.org )

        Tell
Congress: One Size Does Not Fit All When Considering Food Safety
Bills

Local foods businesses are not the same as animal factories or
mega-farms that sell products into industrial scale national and
international markets.

H.R. 2749 - Food Safety Enhancement Act of 2009

Lead Sponsor: Rep. John Dingell

The House of Representatives is working on H.R. 2749, the Food Safety
Enhancement Act of 2009. It’s an attempt to address the worst problems in

U.S. agriculture, but as it stands the bill threatens to undermine
the best things in U.S. agriculture - small farmers producing for local
markets. H.R. 2749 is a well-meaning attempt to address the genuine
problems of contamination from foodborne pathogens and complications in
prevention and intervention caused by large, industrialized food
distribution systems. All of the well-publicized incidents of
contamination in recent years - spinach, peppers, peanuts, hamburger -
occurred in industrialized food supply chains that span national and even
international boundaries. Food safety is a priority shared by all. It is
not compromised by the growing trend toward healthy, fresh, locally
sourced vegetables, meats, fruits, and small processing firms
reinvigorating local food systems. The following priorities need to be
incorporated to make food safety and healthy local food systems
complementary. Local food systems are inherently safer and traceable.

Record keeping should not strangle small producers selling into local
markets

Record keeping and traceability are essential in long industrialized
supply chains. For direct market produce growers, elaborate reporting and
record keeping requirements, including mandatory electronic filing, do
not make sense, as the buyer knows where the food comes from. For sales
to local retailers and restaurants, records should be kept to a minimum,
and should be flexible - on file on paper or electronically.

Under the legislation, FDA will develop rules for record-keeping. The
bill should add language to ensure that direct market produce growers be
consulted and included as a unique category of business in the rulemaking
process.

Registration and fee structures should recognize small home-based and
farm-based local processing

Farms that sell directly to the consumer or to a retail outlet or
restaurant are exempt from registering with the FDA. However, if a farm
makes jams and sells them it would need to register with the FDA and pay
a $500 annual fee, same as food giants like Del Monte.

FDA oversight of small, local food processors is overreaching and
unnecessary

The size and extent of industrial processing (including multiple
sourcing, etc.) should play a significant role in determining the level
of inspection, record keeping, and traceability requirements mandated and
overseen by the federal government. Small local processors selling into
local markets do not need federal oversight appropriate for large,
industrial, multi-sourced supply chains. The legislation permits
delegating some oversight responsibilities to the states. There should be
a clear threshold where state and local public health and sanitation laws
and authorities are sufficient.

All facilities subject to registration under theAct, including those
only engaged in intrastate commerce, are subject to federal inspection.
The large recalls during the last several years have all involved
facilities that shipped interstate. The Act should set a jurisdictional
threshold based on scale and extent of distribution. Since foodsheds
often span a state-line, these may be most appropriately defined as a
mileage radius.

HACCP undermined local and regional meat packers while failing to
increase inspections and

safety of large industrial meat processors

For meat processors, the Hazard Analysis and Critical Control Point
(HACCP) system adopted by the U.S. Department of Agriculture in the
1990’s effectively reduced the number of small regional packers by
creating a maze of paperwork and red tape that many were unable to
manage, while failing to reduce the increasing incidence of food borne
pathogens in the large industrialized meat packers. The HACCP system all
but eliminated the number of independent inspections of the large
industrial slaughterhouses. It is critical that Congress not replicate
the ineffective systems that failed in the meat industry.

H.R. 2749 extends HACCP type models to produce, with potentially
disastrous consequences for small producers.

Imports need sufficient scrutiny to ensure public health is not at
risk

Increased scrutiny, inspection and enforcement of safety of food
imports is a good idea to protect public health. There needs to be a
level playing field between U.S. farmers and global competitors. H.R.
2749 adds some labeling and inspections of imports, but it needs to be
stronger to protect public health. Free trade agreements, such as the
North American Free Trade Agreement (NAFTA), give carte blanche to
agricultural products coming in from trade partners whose standards and
systems of inspection may be grossly inferior. H.R. 2749 needs to go
further to study imported foods and ensure they are held to the same
standards as U.S. products.

FDA will establish standards for safe growing, harvesting, packing,
sorting, transporting and holding of raw agricultural commodities

It is over-reaching to establish federal farming standards for
produce that is not going into interstate commerce.

Care should be taken not to duplicate systems. Products that are
already certified under other rigorous certification standards (e.g.
organically certified, etc.) should be exempted.

This message originated from or was forwarded by:
Chrys Ostrander
Chrysalis Farm @ Tolstoy
Organic Micro-permaculture
33495 Mill Canyon Rd.
Davenport, WA 99122
509-725-0610
chrys@thefutureisorganic.net

http://www.thefutureisorganic.net

"From each according to their ability, to each according to
their needs"
Louis Jean Joseph Charles Blanc - "The organization of work"
1839
Karl Marx - "Critique of the Gotha Program" 1875

"The purpose of agriculture is not the production of food, but the
perfection of human beings"
Masanobu Fukuoka (February 2, 1913 - August 16, 2008)  - "One
Straw Revolution" 1978

"The community whose every member possesses the art of deriving a
comfortable subsistence from the smallest area of soil… will be alike
independent of crowned-kings, money-kings, and land-kings…."
Abraham Lincoln: Address to the Wisconsin State Agricultural Society,
Milwaukee, Wisconsin, 1859

"We will never have an organic future and a stable climate until we
pull all the troops out of Iraq
and redirect our annual $650 billion military budget to greening the
economy and guaranteeing
a sustainable environment and economic justice for everyone."
Ronnie Cummins, National Director, Organic Consumers Association
at the "Farms Not Arms" public forum and protest in Manhattan,
September, 2007