Volume 7, Week 13, November 18-20, 2013
So where do I start? Last week we got into the FSMA (food safety modernization act) and I was going to send you a link to the FDA’s public comment section and ask you to speak-up for small farms and organic farming practices. So I wrote a full page explanation and summary of what’s going on, included some links to good articles on the subject, the FDA comment link and then I try that link myself so I can describe how to go about it….Their comment site is “down for repairs.” Really? You’re kidding right? How hard can it be to have a place to leave a comment? Hello Government, us citizens out here want you to do more smart stuff and less dumb stuff. Our web guys could build such a site in an hour. AAAAAAAAAAHHHH!!!
Did I mention I was really frustrated? The public comment period is over by the time you read this and asking you to do snail mail would have been quite presumptuous. Let me at least take some space to better describe what’s up. It got going with that Odwalla apple juice incident in 96. The next biggie was the spinach problem in 06. That triggered a lot of internal industry wide protocols and 4 years later this FSMA which is now about to be implemented.
To speak out against these rules sounds like you’re against baseball and motherhood, but while they’re going to cost a medium farm about $14,000 (FDA’s own number) in compliance costs, it’s not going to fix the problem. You see, it’s extremely rare to find one of these problems; from cantaloupes, to tomatoes, to peanuts, to Turkish pomegranate arils that can be traced back to an American farm. The problem always comes from either processing, dirty CAFOs (confined animal feeding operations), or imported produce, yet this low hanging fruit isn’t addressed very well in the new rules; more regulation for the good guys, status quo for the bad guys; isn’t that such a surprise? But that isn’t what caused me to get off the bench on this issue and write about it.
After 38 crops worth of dealing with the geometric increase of paperwork, I’m 20 years past being angry about more rules; I think numb would be a better description.The problem here is the impact these specific rules are going to have on organic, biological farming; and subsequently on all our health. If your only tool is a hammer, every problem looks like a nail. To the FDA (who has never been involved with agriculture at all and certainly not with organic agriculture) all these problems are caused by a pathogen. “Kill the pathogens” is the central message of this. Sounds good to a chemist, but to a biologist, not so much.
We are all about life, the interconnectedness of all life; which can’t exist in a vacuum. If we have a clean biological production system—and the existing organic rules are very strict in this regard—we have very safe food as illustrated by the non-existence of problems with whole produce from a local system. The absurdity of these new rules leads to things like: “Mister Farmer, do you have any wild birds in your orchard? Birds do poop you know.” “Yes Mister Regulator, we’ve trained all the robins and blue jays to only poop over in the riparian area, but we’re still working on those darned mockingbirds. Help me Mister Wizard!”