Showing posts with label Small Farm Issues. Show all posts
Showing posts with label Small Farm Issues. Show all posts

Tuesday, October 12, 2010

Learning To Fly

In the comments to my last post I found some interesting thoughts from Leon. He said, “I more and more think that our weird desire "to feed the world" is actually part of the problem.” And I have to agree. “Feeding the world” is and always has been a nice front for economic/political expansion and control. I feel no need to “feed the world”, but I know I must find a way to feed myself, my family, and help feed my community that doesn’t destroy the place I depend on for life. If I find a way that works here, I also feel obligated to share that with others around the world so that they might adapt it to their own place. That way the world feeds itself.
In her book The Vegetarian Myth: Food, Justice, and Sustainability, Lierre Keith says, “Agriculture (as we have been practicing it for the past 10000 years) is the most destructive thing humans have done to the planet, and more of the same won’t save us. The truth is that agriculture requires the wholesale destruction of entire ecosystems.”

Allan Savory once said that Organic Agriculture was responsible for the downfall of more civilizations than all the wars combined.

Agriculture, as we have been doing it for the past 10000 years is built on the idea that we MUST produce more. Having more keeps us safe. It gives us power. It has become our one measure of success and worth. (Imagine a CEO saying, “Let’s just produce as much this year as we did last year…” That business would be thought of as stagnant, and if the trend continued… failing. Even though that level of production might provide a comfortable living for all the people involved and keep the business functioning indefinitely, WITHOUT CONSTANT GROWTH WE ARE FAILURES!) Continual growth requires continual increases in resources. Initially we found those resources by eliminating other things that were using them. (Take a good look at a farm field. The only thing that lives there is what the farmer wants there, the crop. Everything else has been displaced or killed.) We quickly used up those resources. So we started taking resources from elsewhere. First we expanded so we had more area to use. Then we conquered, so we could make others produce for us. Then we pushed back in time to take resources that were removed from the system millions of years ago (coal, oil, natural gas…), Now we are out of places to find more resources to continue our growth so we alter what we grow so it will produce more from less. We modify the very structure of life to get more production.
Along the way we have hit limits. When that happens civilization crashes. Those who survive, regroup and try again. They try harder and smarter, develop new methods and new technologies, and get bigger. They crash again and again. The Anasazi, the Maya, the Mesopotamians, the Romans, etc… Every time we rise from the dust of the crash and learn to reach farther, dig deeper, make more from what we take.
We BELIEVE a story where this works. It defines our style of civilization. Kind of like those folks who didn’t believe in gravity. Or, more like the folks who believed they were exempt from or above the limits of gravity. They spent their lives in the sure knowledge that if they walked off a cliff they would not fall. Right up to the day they walked off the edge. CRASH! We are not walking, we are running full tilt, and we will crash yet again. We’ve been doing this for the last 10000 years, running at the edge of the cliff as fast as we can with as much as we can and believing we can fly. We crash and die. Somewhere else someone picks up the bits and does it again, bigger and better. Civilization! CRASH! AGAIN! CRASH! AGAIN! THIS TIME WE’VE GATHERED THE WHOLE GLOBE, EVERY LIVING PERSON, AND EVERY LIVING CREATURE (BY DEFAULT…) WE ARE RUNNING FULL TILT TOWARD THE EDGE….

Time to learn to fly…

Flight only happens when you understand gravity and the rest of the laws that, by limiting, make flight possible.

Let’s learn to fly… or better yet, lets learn to farm in a way that doesn’t lead yet again to a massive crash.

Tuesday, October 27, 2009

Vote NO on Ohio Issue 2

Here are some links to others who feel the same way.


The Humane Society of the United States

Ohio ACT

Ohio Ecological Farm and Food Association

Here's a bunch more

I find it very interesting that the Cattlemans Association, The Corn Growers Association, The Pork Producers, The Poultry Association, etc. all support this issue and the Humane Society does not. Animal Welfare isn't really the issue on the table.

The Power of Community - A Post in two parts - Part 2

This past weekend we had our Harvest Celebration at Roberts Roost. It is a time when we gather our friends from the community to share food, fire, and talents, and to enjoy each others company. Most of all it is a time to talk about everything and nothing, to share stories, to laugh, to give and receive support without any agenda. Out of these conversations around the fire two ideas arose that I need to explore.

The first is the power and importance of community as we take the road less traveled. I’ll be posting those thoughts on NDiN.

The second is the power of community to act. I’ll be posting about that on Roberts Roost.


Part 2 The power of community to ACT.

There were a couple of stories told around the fire about how community came together to help someone or do something. The details are not important, but the mechanism is. The informal network of communication and the willingness of individual people to do a little something just because it needs doing is one of the things that makes communities so powerful. Someone sees a need, makes a few calls and those folks each make a few calls and before you know it a large group is mobilized to solve a problem or meet a need. It is one of the things that makes a community work, a kind of glue that makes a community more than a group of people living in close proximity and shopping at the same stores. The stories reminded me of the power and speed of such a system.

While the party was going on I was cornered by various people and asked my opinion on Ohio Issue 2, 2009. I haven’t talked much about this issue because voting NO was pretty much a no brainer. (I’m discovering that people are not as cynical or paranoid as I am, so they didn’t automatically jump to the same conclusion on this issue.)

Issue 2 is an attempt by the big agribusiness groups (mostly chicken, egg, and pork producers, with some additional support from the dairy and veal producers) to use peoples fear of PETA and their belief in the wholesome, local, family farm myth to scare the voters into amending the state constitution and creating board (appointed by the Governor and heavily weighted to favor the status quo) to “establish standards governing the care and well-being of livestock and poultry in this state.” The backers paint a picture of a board made up of family farmers ensuring the continued quality and availability of locally produced food. Of the 13 board members only 3 slots are designated for “family farmers”, one appointed by the Governor, and one each for the House and Senate. The remaining members are either directly or indirectly agribusiness representatives. The proposal has very little to do with improving animal care or ensuring the continued future of local food. It is a power grab by big business intended to give them the ability to continue with their current model. It gives local farmers and local residence no say in the future of food in this state.

I know that election day is only one week away but I’m putting out a community call to rally people to vote NO on Ohio Issue 2.

If you are an Ohio voter call all your friends and get them to vote NO. If you know any Ohio voters call them and talk to them about voting No on Issue 2. Lets use the power of community to keep the power to make good food choices in the hands of the people, not in the hands of politically appointed representatives of big Agribusiness.

Thursday, October 15, 2009

Blogger Action Day - Climate Change, A childs view

This is the first of several posts I will be doing today. We have been discussing this issue as a family for the past couple of weeks as I try to formulate what I wanted to say. This morning my daughter JJ said she wanted to share her thoughts about Climate Change, and I thought that would be a good place to start. It is her world we are messing up, so she ought to have a chance to say what's on her mind.

GLOBAL WARMING
A child’s view.

Global warming happens when a lot of different people let toxic gases go into the air. Then the gases get caught in the Earths atmosphere and make the earth a little hotter than usual. The extra heat melts the glaciers in Antarctica and that environment diminishes. With the extra water from the glaciers the water level will keep rising and may cause a flood.

So factories, businesses, and people who drive cars think about that. Whenever you drive or have a factory with smoke or other toxic gas coming out of it, you are adding a little more to the process of Global warming.
But if you think of new ways or try old ways of not putting toxic gas into the air, then instead of adding a little bit to global warming you are adding a little bit to stopping global warming.

Its important to me that we do this because it will help every living thing on earth. The polar bears up in the arctic are losing their environment because of global warming. Around the world habitats are being lost. As everything gets warmer more things will die, maybe even us. We can make it so that doesn’t happen. If we try, if we really, really try, we can stop global warming.

Friday, September 4, 2009

Alan's Soapbox - Gotcha!

Once again I find my self trying to wade through deep streams of government speak. I've been spending my leisure hours reading the Ohio Uniform Code, trying to make sense of the regulations and how they can be used to shut down a small farmer for washing his lettuce. Besides the vague doublespeak, and labyrinthine way of defining things by referring to other Code written somewhere else, I keep running into these little gotchas. It's kind of like the clause at the end of a contract that says "other duties as required." That covers everything. What I keep seeing, where ever the Code doesn't specifically define some method, is the "best practice" line. Sounds pretty innocuous. Who wouldn't be for best practices. Except...

Best practice is almost always what ever has the most research support. It isn't necessarily best, just most researched. So, what's wrong with that? Often nothing, but sometimes there are methods and practices that are good, maybe even best, that don't end up on the list because they don't have the "research support". Research is expensive. Some things get funded and some don't. Much of the funding goes to support and enhance the interests of the funders. Things that don't do that, because they run contrary to industry or because they are not patentable, don't get funding and don't get researched.

Best practice in agriculture (and probably in medicine) almost always come out favorably for the big industrial producer/supplier. They rarely support alternative/sustainable methods.

As the rules start getting inflicted on small, local scale producers, they are going to be pushed to adopt conventional "best practice" methods or go out of business.

Thursday, September 3, 2009

Following up on Ohio's Food Safety

Some follow-up on the "food safety" rules in Ohio in response to Jack-of-all-thumbs request for a link.



Here is another source for the article I got from Acres USA



http://wholefoodusa.wordpress.com/2009/07/12/alert-ohio-farm-food-and-health-alert/

The Ohio Code is here

http://codes.ohio.gov/oac/901%3A3

And here

http://codes.ohio.gov/oac/3717

The only thing I can find is the lettuce was "adulterated" by being "processed" with water in an unlicensed facility. It's pretty hard to follow, but I'll keep looking.

P.S.

Found a bit more. It seems that on farm "processing" falls under the "cottage food operation" heading and, since most homes lack facilities for properly washing food, products that could be hazardous, like adulterated (cut and washed) lettuce, are prohibited.

Here's a link that gives a bit more of the code. Good luck.

http://www.agri.ohio.gov/divs/FoodSafety/docs/Cottage_Food_Rules_Final6-09.pdf

While We Were Sleeping - Food Safety Regulations Creep Forward

Acres U.S.A. - September 2009 p.8 "Farmers Market Crackdown - The Ohio Department of Health/Department of Agriculture has issued a Notice of Violation to farmer Kris Oluich at a farmers market in Lake County. The notice states that it is a violation to offer cleaned and rinsed "lettuce and mixed greens" in a backage. It must be sold dirty, the notice adds. This is due to new rules for "food processing." Since the rules are developed in cooperation with the USDA, it is likely that similar actions will be taking in other states as well."



The push to get food safety legislation passed seems to have died down a bit, but the buerocracy never sleeps. They don't need legislation to develope new rules. So now our locally produced fresh food will be safer because the farmer can't wash it and package it? This isn't food safety, it is an attempt to squeeze the little guys a bit harder to encourage them to go away.



Also in the news. AgDay reported the development of a laser tattoo for use on produce to replace the stickers currently used on supermarket produce. (It was also reported in Smithsonian.com) The process was developed by the Agricultural Research Service, a branch of the USDA. It is still awaiting USDA approval, but is seen as a boon to producers and to food safety. It is supposed to be cleaner than the stickers and would be a permanent identifier, enhancing the traceability of produce and there by making our food "safer."

As I plan my new USDA inspected Class 3 food production facility (so I can wash and bag my lettuce before I take it to my local farmers market) I had better include space for a laser produce tattoo machine. I'm sure it will soon become a rule even if it never becomes law.

Sunday, August 30, 2009

Buddha in a box

I was in the book store a while back, cruising the stacks waiting for something to jump out at me, when I saw it nestled on the shelf in a stylish black box with gold lettering. I had to stop. I had to pick it up, read the back, and came darn close to buying it. Buddha In A Box, a lovely little statue of the Buddha, complete with a handy guide to everything you need to know about Buddhism. Perfect, and much nicer looking than the black and yellow Dummy’s Guide to Buddha. Certainly much easier and faster than slogging through the six shelves of Buddhist philosophy/theology books, working with a priest, meditating, etc. The vast, complicated, somewhat incomprehensible world of the Buddha all wrapped up in a ten page booklet and a cute little box.

We put everything in boxes. That’s how our brains are able to process so much information so quickly. Every label, every name, every concept comes with it’s own box. We fill the box with our experiences, things we have read, things we’ve been taught, and a whole truck load of cultural baggage having to do with the particular label on the box. What is in the box is different for every person, sometimes very different. For example, I consider myself a farmer, and the work I do farming. But for most people in my part of the world a farmer has big tractors, big trucks, vast fields of corn and soy beans, and spends his day using his equipment to make sure the beans and corn have everything they need to thrive. I, with my five acres of grass, no tractor, and a small market garden, don’t fit the information in their farmer box. I’m not a farmer from their perspective even though I spend may day working the land to make a living.
 
Sometimes these labels, these boxes are tied closely to our definition of self. I am a farmer. When I talk about, write about, think about farming, farmers, agriculture, I am talking about myself. When someone questions, belittles, or attacks the way I farm it is personal. It is very difficult to separate one’s self from such a conversation. This happened to me a few months ago. I was having a conversation with Sheria from The Examined Life, and the subject of race came up. For me, race and racism is an intellectual exercise. It is important, I’ve thought quite a bit about it, and I think of my self as a non-racist. But it is a lot like the Buddha in the box. While I’ve read the guide to racism and feel informed, I haven’t lived it. The stuff in my box may be accurate, but is could all fit in a teaspoon. And, most importantly, it isn’t a defining part of who I am. For Sheria it is. She has lived with racism her whole life. It impacts how she thinks, how she approaches problems, and how everything is interpreted. When I, viewing the perception of racism in the topic we were discussing, said people should just “get over it!”, I hit a nerve. What I said, valid or not, was an attack on, or at least an affront to, Sheria as a person. For a time it changed the nature of the conversation. We got past it and understand each other a bit better. Many people don’t get there.

So, this past week when my way of living, my vision of a way forward, and most importantly, my self defining idea about what a farmer is came under attack, I got mad. It has taken me more than a week to remember the Buddha in the Box and realize that the attackers were working with a different vision of farmers, farming, and agriculture than I was. Their definitions and understanding, their box doesn’t invalidate my way of living or who I am. It does make it difficult for us to have a conversation. If I remember that they are coming from a different place, with a totally different concept of what a farmer is, we may be able to make some progress.
Here are the links to the things that got me fired up. Take a look and let me know what you think.

Sizing Up Sustainable Food: NPR Science Friday
Farmer vs. Michael Pollan

Thursday, August 13, 2009

Sustainable Success

Our fudge has been doing brilliantly. Every time I turn around there is a new order or someone at the door or on the phone wanting more. It’s great. It is nice to know that we guessed right this time, that we jumped the right direction when the wheels started coming of the wagon. People seem to really like it. They also seem really interested in the farm story and in offering advise and opportunities. Hardly a day goes by anymore without someone asking about bulk sales, wholesale prices for this store or that, or letting me know about small business development ideas, loans, grants, schemes, etc that will help me grow the business and be successful. It’s exciting, it’s interesting, it’s tempting, but…
…the weird little man who sits on my shoulder screams “is it sustainable?” Fortunately (or un-), I have to listen to him. And listening, I have to ask my self the question. “Is it sustainable?” The answer seems to be dependant on two words and how we define them. The first is ‘sustainable’. I’ve already beaten this one to death. My definition is limited by the local resource clause. Local resources used locally and every bit, including waste, returned to the local resource pool in a way that it can be used again. If that isn’t happening then what you are doing isn’t sustainable. My fudge making already fails on that count. Half of the ingredients used come from somewhere well out side my local range. There is no way they will ever be produced here. However, everything else is produced locally and sustainably. It isn’t perfect, but I can live with it for now.
The second word in need of defining is ‘success‘. I thought ‘sustainable” was difficult to define. This one is impossible. I know what I mean, but I’m sure my idea wouldn’t meet most people’s expectations. So I asked a few friends how they would define a successful business enterprise. The first thing that comes back is profitable. Ya got to make money if ya want to be a success. The second thing (and it is linked to the first) is growing. The venture needs to be growing, vibrant, expanding, increasing market share and profits from year to year. They all went on to talk about ethics, community, environmental stance, yadda yadda yadda. The bottom line of our measure of success is ever increasing growth and accumulation of resources. This is where I start butting heads with civilization. (This definition of success is one of the driving forces of civilization. It is what nations, and empires are built on. It is the key to power. It is also the root of our destruction, but that’s a different discussion.)
So is there such a thing as sustainable success? I think it would require a different definition of success. One not built on ever increasing growth and resource accumulation. I don’t have an answer yet. We are doing this on the fly, defining and inventing as we go along.
Do you think there is a workable new definition of success that doesn‘t clash with sustainability? If so, what?

Tuesday, August 4, 2009

Growing New Farmers

Today's post is over at NDiN. I've shared some of my thoughts on the future of small farms and the need to grow some new farmers. Head on over and share your thoughts.

Tuesday, July 21, 2009

Alan's Soapbox - Health Care

Like the President, I've been thinking about health care reform lately. I haven't been crunching numbers or lobbying congress. Rather I've been thinking about the one of the major problems with the health care system and trying to find an answer. Everyone (according to the spin doctors and the talking heads on the news) thinks universal coverage is the issue. It is part of the issue, as is escalating cost, but it is not the whole issue. It isn't even the most important part. The issue is that the system doesn't keep people healthy. It doesn't matter if you have insurance or not. The system isn't about keeping you well. It is about fixing you when you get sick. Doctors, hospitals, pharmaceutical companies, etc., don't make money if you are well. They don't really make any effort to insure you don't get sick. Keeping you well is not in their best interest and it is not rewarded.

When I was managing a ranch in Wyoming we had a similar problem. We had about a dozen cowboys on staff and they worked cows and fences all over about 80,000 really rough mountainous acres. Most of the work was done using 4wheel drive trucks and ATVs. Originally the ranch provided these vehicles. The cowboys were required to do all the regular maintenance on the vehicles they used, and the ranch provided everything they needed. Not one vehicle lasted the summer. Every single one of them had a major mechanical problem and ended up in the shop for expensive repairs. The maintenance wasn't being done and that caused major problems and expense.
We solved it by fixing or replacing everything, requiring the cowboys to use their own trucks and ATVs (some of the ATVs were given to staff after they were fixed). The ranch paid each staff person a vehicle allowance that covered gas, maintenance, and depreciated the vehicle so they would have enough to buy a new one at the end of its useful life. The staff paid out of pocket for all maintenance and repairs. All the work got done and only one vehicle ended up out of service and that was an accident, not a maintenance problem.

Maybe if the doctors and hospitals were paid a monthly fee to keep people healthy and had to eat the cost (or most of the cost) of any preventable illness we would have a better system. Insurance would still be needed to cover catastrophic things, but it would be much less expensive. People could by coverage for non health things like plastic surgery. Maybe focusing on caring for health rather than fixing sick people would be a step in the right direction.

Friday, July 10, 2009

Sustainability?

We had guests at the farm this past week. Two kids ages 7 and 9 to play with our two. It was full on, but great! This morning I had to take them south to meet their parents. On the drive I was listening to NPR's morning show. They were blathering about the economy and politics and I wasn't really listening. Then the sponsor came on and my brain kicked in. The hour was sponsored by our friends Monsanto. They came on and said "Morning Edition is sponsored by Monsanto, committed to sustainable agriculture..." They went on to talk about the wonderful genetically superior products they offered to sustain farming into the next century. My brain shut down after the first line. Monsanto, the champion of sustainable ag. The mind reels. So, I started thinking about the word sustainable. For Monsanto and for many people it implies that this business will continue into the "foreseeable future". It has nothing to do with long term, ecological, or geological sustainability. There is no thought about the future of the species or the planet, just the short term viability of the business. That is not my definition of sustainability, but it is the definition that is used by much of the public sector. Some effort needs to go into creating these definitions. Otherwise the words mean nothing.

Wednesday, April 1, 2009

Hysteria

Today I grumbled about the hysteria surrounding Food Safety Legislation. The chatter on the net is filled with such theories of Grand Conspiracies. I think it gets in the way of rational discussion of the problems with the proposed legislation. When I arrived here (Bioneers) I found another tirade against the Monsanto consortium and their bid to take over the world. I was about to comment when this link popped up on my desktop (a link from a conversation at Wildlife Gardeners-On the heels of HR875). Another 12 bills to add to the 5 I was already following and trying to be rational about. Maybe a bit of hysteria is called for. It does seem that someone is trying to ram "food safety" legislation down our throats. Maybe we should be wondering why!

I find it passing strange that I'm writing about politics. In the political season I didn't and two bloggers I really respect (Jack and Sheria)did. I sniped at their posts, playing the cynic. Now they blog about their lives and I scramble to keep up with the politics. Justice, I suppose.

Food Safety Legislation and The Grand Conspiracy

There has been a lot of chatter on the net about H.R 875, H.R. 759, H.R. 814, and Senate Bills 425 and 510. Doom and gloom. Apocalyptic ranting and raving. The END OF EVERYTHING. I understand the feelings being expressed, but most of these tirades tend to get labeled as the ranting of the lunatic fringe and discounted. That doesn't mean there is no truth in these posts, or that the accusations they make have no validity. It just means they wont be taken seriously by the politicians or the main stream public.

The truth is these bills, H.R 875, H.R. 759, H.R. 814, and Senate Bills 425 and 510, consolidate power in a single bureaucracy, increase safety requirements and regulation of small, diversified producers (with many requirements that would put small producers out of business), and do very little to improve food safety. Large producers are already regulated and the tracking systems are already there for most of the things they produce. The failure has been in the bureaucratic administration of the existing regulations, not in the lack of regulations. Creating a larger bureaucracy with more regulations will not increase food safety. Having a more localized, diverse food system will. These bills deliberately or inadvertently eliminate such diversity from the system. That is why they should be opposed. If the government is truly looking for ways to ensure safer food it would be developing ways to support smaller, more localized, more diverse food production. The "redundancy" and "inefficiencies" in this kind of system make it less susceptible to threat from disease or terrorists.

We need to stop ranting about Monsanto and start calmly expressing our concerns as voters to our representatives in the government. Money may be powerful, but so are voters.

Thursday, March 26, 2009

The Food Safety Modernization Act - Trojan Horse?

I'm being told that H.R. 875, The Food Safety Modernization Act, is not going to pass. I shouldn't worry about it. Apparently the bill that has the best chance of passing is H.R. 759, The Food and Drug Administration Globalization Act. It is in committee now. It is much harder to get a handle on. Much of it is written as amendments to Title 21 of Federal Code. That makes it pretty tough for a non-lawyer like me to wade through it and figure out what it means. There is a section dealing with Safety Standards for Fresh Produce that makes me think small farmers who "process" produce on farm should be concerned with this bill as well.

Here is the text of that section.

SEC. 104. SAFETY STANDARDS FOR FRESH PRODUCE.

(a) PROHIBITED ACT.—Section 301 (21 U.S.C. 331), as amended by sections 102 and 103, is amended by adding at the end the following: ‘‘(pp) The production or harvesting of produce not in accordance with minimum standards as provided by regulation under section 419A(a) or a variance issued under section 419A(e).’’.

(b) STANDARDS.—Chapter IV (21 U.S.C. 341 et seq.), as amended by sections 102 and 103, is amended by adding at the end the following:

‘‘SEC. 419A. STANDARDS FOR PRODUCE SAFETY.

‘‘(a) STANDARDS.—The Secretary shall establish by regulation science-based minimum standards for the safe production and harvesting of those types of fruits and vegetables that are raw agricultural commodities for which the Secretary has determined that such standards minimize the risk of serious adverse health consequences or death.

‘‘(b) CONTENTS.—The regulations under subsection

(a)—‘‘(1) shall set forth such procedures, processes, and practices as the Secretary determines to be reasonably necessary—‘‘(A) to prevent the introduction of known or reasonably foreseeable biological, chemical,

12 and physical hazards, including hazards that

13 occur naturally, may be unintentionally intro14

duced, or may be intentionally introduced, in15

cluding by acts of terrorism, into fruits and

16 vegetables that are raw agricultural commod17

ities; and ‘‘(B) to provide reasonable assurances that the produce is not adulterated under section 402;

‘‘(2) shall include, with respect to growing, harvesting, packing, sorting, and storage operations, minimum standards for safety;

‘‘(3) shall include standards addressing manure use, water quality, employee hygiene, sanitation and animal control, temperature controls, and nutrients; ‘‘(4) may include standards for such other elements as the Secretary determines necessary to carry out subsection (a);

‘‘(5) shall provide a reasonable period of time for compliance, taking into account the needs of small businesses for additional time to comply; and ‘‘(6) shall provide for coordination of education and enforcement activities by State and local officials, as designated by the Governors of the respective States.

‘‘(c) PRIORITIZATION.—The Secretary shall prioritize the implementation the regulations under subsection (a) for specific fruits and vegetables that are raw agricultural commodities and have been associated with food-borne illness outbreaks. ‘‘(d) ENFORCEMENT.—The Secretary may coordinate with the Secretary of Agriculture and shall contract and coordinate with the agency or department designated by the Governor of each State to perform activities to ensure compliance with this section.’’.



I'll keep working my way through this as best I can and as time allows. I'd appreciate feedback from others who have looked at it from a small farm perspective.

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 http://www.opednews.com/articles/A-solemn-walk-through-HR-8-by-Linn-Cohen-Cole-090314-67.html Check it out.

Tuesday, March 24, 2009

Food Safety Bills - more information

There is a summary of H.R 875, H.R. 759, H.R. 814, and Senate Bills 425 and 510 on the Farm and Ranch Freedom Alliance site. They also have links to more information and to ways to take action.

Judith McGeary, from the Farm and Ranch Freedom Alliance ended her letter to the editor of Acres Magazine, April 2009 issue, with the following;

"None of the bills recognize the fundamental differences in food safety between the industrial, centralized food system and the sustainable, local food system. To one degree or another, they all attempt to impose expensive, burdensome requirements on all farmers, regardless of the scale of operation or the management methods. True food safety reform needs to recognize that foods such as grass-fed meats, processed in local, small-scale operations, are not the same as - and should not be regulated as - feedlot meats processed at massive facilities and shipped all over the country. Nor should vegetables and fruits from a local farm be treated the same as spinach from mega-farms in California, processed at a multimillion-dollar facility, and shipped all over the country."

If you care about the future of local, sustainable food you should get involved. Follow the link to Farm and Ranch Alliance and take action.

Monday, March 23, 2009

Food Safety Modernization Act - Another Look

Since I posted my take on the Food Safety Modernization Act - H.R. 875, I have been drawn into a number of conversations about the bill and what it means or does not mean for small farmers. In these conversation a fact sheet put out by Food and Water Watch has been referred to often, either by people who support the bill or people who work for Food and Water Watch. Their reading of this bill and mine differ on a few points. Here is what Hayley, an employee of Food and Water Watch, posted in the comments on the Garden Rant discussion of this bill.

Hayley said...

Hello everyone,

My name is Hayley and I work for Food and Water Watch. In the posts, Jill, mentioned our fact sheet, well I think it's important to clear up the bill, so I'm going to post it here. Our policy experts have read and interpreted the entire bill and basically there are 6 food safety bills being circulated in Congress, but only this one seems to be receiving a lot of attention. H.R. 875 – would overhauling the totally dysfunctional Food and Drug Administration. But the rumor mill has this legislation pegged as something entirely different. Now it’s time to set the record straight. Here are a few things that H.R. 875 DOES do:

- It addresses the most critical flaw in the structure of FDA by splitting it into two new agencies –one devoted to food safety and the other devoted to drugs and medical devices.
- It increases inspection of food processing plants, basing the frequency of inspection on the risk of the product being produced – but it does NOT make plants pay any registration fees or user fees.
- It does extend food safety agency authority to food production on farms, requiring farms to write a food safety plan and consider the critical points on that farm where food safety problems are likely to occur.
- It requires imported food to meet the same standards as food produced in the U.S.

And just as importantly, here are a few things that H.R. 875 does NOT do:
- It does not cover foods regulated by the USDA (beef, pork, poultry, lamb, catfish.)
- It does not establish a mandatory animal identification system.
- It does not regulate backyard gardens.
- It does not regulate seed.
- It does not call for new regulations for farmers markets or direct marketing arrangements.
- It does not apply to food that does not enter interstate commerce (food that is sold across state lines).
- It does not mandate any specific type of traceability for FDA-regulated foods (the bill does instruct a new food safety agency to improve traceability of foods, but specifically says that recordkeeping can be done electronically or on paper.)


HOWEVER Several of the other bills include provisions that should worry small farmers – like H.R. 814, which calls for a mandatory animal identification system, or H.R. 759, which is more likely to move through Congress than H.R. 875 and calls for electronic recordkeeping on farms and registration fees for processing plants.

I hope everyone found this helpful!

Hayley says the bill "- It increases inspection of food processing plants, basing the frequency of inspection on the risk of the product being produced". What she doesn't mention is that if you "process" (as in cut and bag, or otherwise package food or produce) you are reclassified as a food establishment and subject to these inspections. Many small farms do this. Most large farms do not. She also points out that this bill "extends food safety agency authority to food production on farms." Food and Water Watch think this is a good thing, and it may be for large commercial farms. The requirement to "write a food safety plan and consider the critical points on that farm where food safety problems are likely to occur" (and submit it for review, approval, and inspection, I'm sure) is a good thing for giant producers of some kinds of produce, but would be burdensome and unnecessary for small farms.

Hayley goes on to point out things the bill "does not" do. Some of these are true as far as the wording of the bill is concerned (except that if you process anything on farm you instantly become a food establishment and subject to all the requirements of this law.) Other things, like "- It does not call for new regulations for farmers markets or direct marketing arrangements." are true. The bill isn't aimed at the marketing methods, and contains nothing about farmers markets or direct marketing. But, (9) CATEGORY 5 FOOD ESTABLISHMENT.—The term ‘‘category 5 food establishment’’ means a food establishment that stores, holds, or transports food products prior to delivery for retail sale. the small farmer taking his bags of lettuce to market and holding them there for sale could also fall subject to the inspection and requirements for a Category 5 Food Establishment. That could mean refrigerated trucking, refrigeration at the market, etc. This would have a huge impact on small farms and small Farmers Markets.

She says "
- It does not apply to food that does not enter interstate commerce (food that is sold across state lines)." I didn't find this anywhere in the bill.

On the topic of traceability Hayley says the bill will not "establish a mandatory animal identification system." and that "- It does not mandate any specific type of traceability for FDA-regulated foods (the bill does instruct a new food safety agency to improve traceability of foods, but specifically says that recordkeeping can be done electronically or on paper.)" But the bill states "SEC. 210. TRACEBACK REQUIREMENTS.

(a) IN GENERAL.—The Administrator, in order to protect the public health, shall establish a national traceability system that enables the Administrator to retrieve the history, use, and location of an article of food through all stages of its production, processing, and distribution.

(b) APPLICABILITY.—Traceability requirements under this section shall apply to food from food production facilities, food establishments, and foreign food establishments." Seems like a traceability requirement for all food to me.


I still think this bill addresses some efficiency issues that need to be looked at. But it is written with an eye for large producers. The regulatory part takes into account their needs and the problems associated with them. It does NOT consider small farms at all. That is a different system and needs to be addressed in different ways. This bill as it is written has the potential to severely damage the small farm and local food movements. Not from maliciousness, but from ignorance of the issues at this level.

Thursday, March 19, 2009

Food Safety Modernization Act of 2009 - A Small Farm Perspective

Food Safety Modernization Act of 2009

I’ve been trying to work my way through this bill for a few days now. Things keep getting in the way (the weather has been great, and there is a lot to do), but this is important, and people keep asking, so here are some of my thoughts.


On the whole, consolidating the various inspection and monitoring agencies is probably a good idea. That is a big piece of this bill, and it means nothing to me. There are some bits written into the directives and implementation parts of the bill that have the potential to impact small farms, farmers markets, CSA’s and other small scale local food efforts in a very negative way. I’ll detail a couple things below. I don’t think this is a Monsanto (or any other big corporation) conspiracy. However, their interests tend to get better representation in legislation and bureaucratic implementation because they have more “clout”. It is important that the voice of the small producer and their customers get heard.

PROGRAM ELEMENTS.—In carrying out the program, the Administrator shall—(1) adopt and implement a national system for the registration of food establishments and foreign food establishments, as provided in section 202 of this Act; (2) adopt and implement a national system for regular unannounced inspection of food establishments; (3) require and enforce the adoption of preventive process controls in food establishments, based on the best available scientific and public health considerations and best available technologies;

There is a clause in the bill that exempts food production establishments from this registration. A “Food Production Facility” is defined as follows:

(14) FOOD PRODUCTION FACILITY.—The term ‘‘food production facility’’ means any farm, ranch, orchard, vineyard, aquaculture facility, or confined animal-feeding operation.

“Food Establishment” is defined as a Processing Facility. And “Process” is defined as follows:

(19) PROCESS.—The term ‘‘process’’ or ‘‘processing’’ means the commercial slaughter, packing, preparation, or manufacture of food.

All food establishments are required to register and to be subject to random inspection based on their classification ( a category 1 being inspected the most often and so on through category 5. Here is one of the places that the small farmer could get into all kinds of trouble. Most small farms are also food processors. On my farm, for example we harvest and package various kinds of salad greens. That would put us in the Category 3 Food Establishment. That would require that I build a separate “processing” facility to package my salad greens. That facility would have to meet certification requirements from the state and now federal inspectors as well as OSHA etc. I would also be subject to at least monthly inspections, and a mountain of record keeping. I sell to about 150 people a week, all of whom know me, my farm, my methods. My produce doesn’t really enter the conventional food system. Yet I would have to meet all these requirements (I’m sure there are more.) A giant salad greens farm in California who cuts and sells their lettuce to a processing facility would be exempt from these requirements. Everything I do on my farm meets the requirement of at least a Category 5 Food Establishment and subjects me to these requirements. Most large producers would be exempted.

SEC. 210. TRACEBACK REQUIREMENTS.

(a) IN GENERAL.—The Administrator, in order to protect the public health, shall establish a national traceability system that enables the Administrator to retrieve the history, use, and location of an article of food through all stages of its production, processing, and distribution. (b) APPLICABILITY.—Traceability requirements under this section shall apply to food from food production facilities, food establishments, and foreign food establishments.

This is another requirement of the bill that impacts small producers more than large producers. It gives the force of Federal Law to NAIS and goes on to require a similar system for all types of food. I suppose there will be a NTIS (National Tomato Identification System) and a NLIS (for lettuce) and… I don’t know how it will work, but, as we have seen with the NAIS, small, diversified producers are disproportionately impacted by the cost and paperwork burden of this kind of a system. There are also numerous reports and studies showing that traceability is about as effective at preventing food related outbreaks as closing the barn door after the horses have run off is at keeping the horses in the barn. All this kind of system does is let the blame and the penalties run downhill to the smallest producer.




I’m sure we are all in favor of safe food and government efficiency. Both of those things are things I support. I’m not opposed to some level of government inspection or oversight, but I want it to be appropriate to the processes I use and the level of threat my production methods pose to the general health of the nation. Contact your congress people and voice your opinion. We can have a safe, as well as a diverse, food system if they act rationally rather than legislate out of fear.

Wednesday, March 11, 2009

Change is coming

There are some regulations coming down the pike that will make our food "safer" and be a "positive" change for all of us. It's called H.R 875. It has the potential to eliminate small growers, Farmer's Markets, and food choices of all kinds. Check it out and tell me what you think. I feel a rant coming on and will have to dig out the old apple crate.

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