S. 510 Opinion: Protect Small Farms
The nation's biggest fresh produce handlers, distributors and retailers received a gift last week when Food Safety News published an apparently long-planned Q&A with Bob Whitaker, Chief Science Officer for the Produce Marketing Association. Dr. Whitaker used this opportunity to decry the supposedly grave threat to public safety from small farms that will escape the dragnet of FDA supervision under S.510, the Food Safety Modernization Act, if it includes the Tester-Hagen amendment.
As Food Safety News and the ag media have reported, after Senate negotiators and representatives of the Make Our Food Safe coalition last week agreed to include the Tester-Hagan amendment in S.510, the lobbyist associations for the big produce handlers, distributors and retailers launched a counterattack on this reasonable approach to supporting public health and local food system development.
It has been interesting to see how effective their campaign has been. Dr. Marion Nestle recently quoted with approval Dr. Whitaker's comments to the effect that it's ridiculous for small farms to complain about a little paperwork and that adopting the industry's food safety regimens are easy and necessary. What is also interesting about the anti-Tester-Hagan campaign is its proponents' remarkable lack of awareness of the day-to-day cultural and economic realities of the small farms that are on the verge of revolutionizing America's food system.
Three-acre organic market gardeners in Chatham County, NC irrigating their plants with from a pond are as committed to protecting the health of their customers as 1,000-acre lettuce growers in Monterey County, CA using triple-treated municipal waste water, if not more so. The direct relationships that the small producer has with the customers, and the inherently limited nature of her customer base, create a market incentive for protecting those customers as strong as any in the produce business.
Seeking protections for those growers from the proscriptions of FDA regulators regarding the proper means of assuring safety on the farm is not a reflection of a lower desire for safe food, as the big handlers, distributors and retailers would have the public believe. In fact, the Tester-Hagan amendment, in conjunction with the totality of S.510, is a well-designed means for supporting the ability of small farmers to provide the healthiest food possible.
But the corporate giants that dominate the fresh produce industry to cannot conceive of the means for managing contamination issues in the local food sector. Those agribusiness behemoths' only frames of reference are their own capital-intensive, compliance department-managed, standardized, large-scale operations. From this perspective, the realities of low-input, owner-manned and -operated, diversified, small-scale operations are unfathomable.
I have experienced this in meeting with food safety regulators and auditors. I have seen firsthand the attitude of state Good Agricultural Practices (GAP) inspectors change from incredulity that any small farm would have a problem with GAP to breakthrough realization that GAP auditing every one of the 20 or more different crop plantings that a small diversified producer may harvest each year would in fact be cost prohibitive. I've heard the biggest produce commodity growers in North Carolina, be they apples or sweet potatoes, acknowledge that the paperwork and testing protocols they have to develop, implement, monitor and review for FDA or GAP certifiers would be impossible for their small farm brethren.
The FDA's own guidance just published for processing cut leafy greens, which any local garden that prepares a salad mix for sale to local restaurants is potentially subject to, estimates that it would take a trained corporate team 100 hours to develop an appropriate safety plan, not to mention the cost of tests that such a plan would have to require. The husband-and-wife team likely operating a produce farm for a local food market, in addition to their off-farm jobs, don't have a spare two-and-a-half weeks to create a plan, let alone the expertise of a team of food technologists, lawyers and engineers necessary to come up with a plan in 100 hours.
There is room to believe that the big handlers, distributors and retailers driving the food safety train--whose bagged, ready-to-eat salad mixes are responsible for 99 percent of the outbreaks of pathogen contamination in leafy greens, despite their supposedly state-of-the-art GAP and Good Handling Practices plans--are willfully ignorant in their lack of awareness of the impact of their style of food safety on the small farm. Dr. Whitaker's PMA, along with United Fresh and Western Growers, have spent the last several years trying to get authority from the USDA to establish a "voluntary" national food safety regime for leafy greens based on the model of California's Leafy Greens Marketing Agreement. The California experience has shown that the big boys' model is devastating to low-input growers, as well as organic farming and soil conservation programs.
Among the thousands of comments received by USDA on the federal leafy greens marketing proposal, the vast majority opposed it, including more than thirty agricultural organizations, ranging from sustainable farming alliances, to state departments of agriculture, to state Farm Bureaus, that were frozen out of the process of developing the rule. Those comments offered suggestions for how to accommodate the purported goals of the agreement and the actual conditions on small farms, suggestions that have been completely ignored by the big handlers, distributors and retailers and their lobbyists.
The effect of changes won to S. 510 by sustainable agriculture advocates, including and in addition to the Tester-Hagan Amendment, is not to exempt small and local food producers from the need to manage pathogens, but to foster the development of multiple climate-, scale- and market-appropriate models for promoting safe and healthy food in a sector of the farm economy largely ignored heretofore by research institutions. Before we won the inclusion of Tester-Hagan, we fought for the Stabenow amendment, which would create incentives for universities and trade groups to tailor research and training to the unique conditions of small and diversified farming operations, so that those growers can have access to the best, most up-to-date, most relevant information. Tester-Hagan increases the leverage for these farms and food producers to demand increased training and research resources for the local food sector.
The small farm protections in S. 510 may in fact create a space for local food to catch up with the safety management investments that the big produce companies have made in their systems of national harvest and distribution. With the best available safety resources targeted in the most appropriate ways for every sector of the produce business, the emerging small, farmer-driven system will be on equal footing with the entrenched giant, distributor-driven one. Then maybe we will have a chance to see head-to-head whether diffused, distributed localized food systems work to better protect public health, encompassing nutrition, pollution, as well as pathogen control, than our dominant, highly-concentrated national system does today.
The local food community welcomes such a competition. The big handlers, distributors and retailers appear less enthusiastic.
Editor's note: With Senate action on the Food Safety Bill approaching, we received more opinion pieces than we had space in our format, so these contributions from Roland McReynolds and Chuck Jolley are being posted in the news section.
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