Wednesday, March 25, 2009

Food Safety Regulation - Why I am concerned with H.R. 875

I've been asked a number of times why I am spending so much effort on this bill. I get a lot of people saying it wont pass and even if it does it wont be the doom of small farms, so why worry.

Here's a true story that illustrates why I am concerned.

A few years ago I worked on a small farm in Texas. The mission of this farm was to train people who were preparing to go overseas on agricultural missions or peace core deployments. Much of the farm was set up to give people real experience with the conditions they would meet in the field. They learned to build, live with, and maintain composting toilets, rain catchment systems, water pumps, water filtration, wood fire cooking, etc. It was a great learning environment.

To raise some of the money needed to maintain these programs the farm operated a small grade A Raw Milk dairy and a vegetable CSA. There were also farm days held a couple of times a year when community members came for food and fun and donated money. After one of these farm days someone complained to the health department about conditions at the farm. There was no sickness, no problem that I was aware of, just a complaint. An inspector from the Health Department came to check things out. She happened to show up on CSA day. We were just finishing bagging the lettuce for the afternoon pickup. We, the farm staff, interns, and CSA members, were working at tables in the shade on the porch of the learning center. The inspector walked around with the director, asked a few questions, and left. A few days later we were notified that we must cease processing (washing and bagging) lettuce or any other produce until we had a certified, inspected, separate processing facility in which to work. The facility had to be completely enclosed, washable, have a bathroom, a separate hand washing sink, refrigeration, etc. It needed to basically be a commercial kitchen without the cooking equipment. The cost of such a facility, even with donated labor and some donated materials would run to several thousand dollars (much more than that with out the donations and the existence of a concrete pad we could build on.) Everything was put on hold while the farm scrounged the donations, money, and help to build the facility. It came close to permanently shutting down the CSA.

The CSA at this farm had been running for years. The state dairy inspector visited the farm every few weeks to check the dairy and the milk we sold. There was never a problem brought up that was outside the normal operating of a dairy. Yet, one unrelated complaint to the Health Department almost shut down the whole operation and cost the farm thousands of dollars and a huge amount of time. If this had happened to a farm that was not a well known and fairly well funded non-profit teaching center, it could have easily spelled ruin. Very few small farmers have the resource base to create such a facility mid-season. The banks rarely loan money for such projects (the return is too small and takes too long from a business pov.) It would be a disaster.

The proposed Food Safety Modernization Act would link the state and federal systems much more closely with the state doing the ground work of registration, inspection, and data collection. It would also completely open farms to the regulation of the Health Department. Because most small farms process (wash and bag) produce on farm they become subject to the same inspections and regulatory requirements as large processing facilities. Most small farms can't afford to create the required facilities and would be forced out of business.

That is why I'm concerned with this bill and am working to see it doesn't pass. I support safe food and inspections that help insure its safety. I think there is a need for it at all levels of the food production process. But the large scale commercial system is vastly different from the small scale local system. This bill does not address these differences, it lumps everything together. It falls short of the needs at the large scale and doesn't even consider the needs at the small scale.

Here is a link to another look at the bill and some ways to get involved Check it out.
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