Editor’s Note: Perhaps you heard last week about lettuce recalled from stores in several states, and upon seeing romaine in this week’s FarmShares, can’t help but pause to ask “is this safe to eat?” In fact, as discussed below, the lettuce in a CSA is fundamentally different product than the sealed bags found in supermarkets. Congress is desperately searching for a legislative fix for an increasingly risky modern industrial food system. It’s critical that they hear from people who eat local food that the “fixes” should not make family farms and the environment collateral damage.

Last week an outbreak of food poisoning linked to bagged romaine lettuce caused 29 illnesses, including several hospitalizations for life threatening symptoms. We’ve written previously in our newsletter about dangerous strains of E. coli that have spread into the general environment from cattle feedlots. We’ve also reviewed the statistics showing that the majority of outbreaks and illnesses can be traced to bagged produce and the processing plants that they come from.

We are convinced that fresh produce, picked and then delivered to your kitchen within a day or two, like the produce in your CSA boxes, carries much less risk of contamination from on-farm sources. Eating fresh produce (not in the sealed bags) means that it has come direct from the field, with limited processing and fewer steps between you and the farm. However, the increased presence of toxic bacteria in the environment, regardless of the source, requires us to step up our activities to prevent food contamination from ‘high-risk’ animals. With that in mind, we’ve been following developments in Washington D.C. that will result in “food safety” guidelines that must be followed by all farmers. Because some produce buyers have taken extreme and counterproductive measures in efforts to eliminate all forms of wildlife from farms, we have encouraged our friends and CSA members to stay informed and even to voice an opinion when appropriate.

The House of Representatives passed their food safety bill (HR 2749) almost a year ago. The bill gives the U.S. Food and Drug Administration (FDA) more authority over the produce industry. Since that time, a parallel bill (S 510) is being developed in the Senate. Called the Food Safety Modernization Act, it is expected to be considered by the Senate right after the Memorial Day recess. The legislation is going to have a significant impact on farmers. The National Sustainable Agriculture Coalition (sustainableagriculture.net) and the Community Alliance with Family Farmers (caff.org) are working on several amendments to the Senate Bill and posting regularly to their web sites.

Meanwhile, in preparation for its new powers, the FDA is taking comments until May 24 on the “best way to develop safety standards for the growing, harvesting, and packing of fresh fruits and vegetables.”  FDA has stated that they are most interested in comments regarding a number of points, including the following:

• Identification and prioritization of food contamination risk factors;
• Coordination of produce food safety practices and sustainable and/or organic production methods;
• Coordination of produce food safety practices and environmental and/or conservation goals or practices.

Here are some of our thoughts on those subjects. In terms of the first bullet, prioritization of risk factors, we think that this is the crux. Not all animals on the farm are risk factors, thus management should be directed at eliminating high-risk wildlife and animals. Likewise, processed, bagged produce has proven to be a higher risk than fresh produce direct from the farm. That recognition should be incorporated into the rule making. This doesn’t negate the need for all farms to adopt common-sense practices. It simply argues for a priority to manage the highest risks.

With regards to the second and third bullets, the FDA should clearly coordinate the “food safety” rules with sustainable and conservation practices. Wildlife and wildlife habitat are a low food safety risk. Moreover, the conservation and restoration of grasses and wetlands that filter E. coli pathogens, and the promotion of diverse soil microorganisms that are antagonistic to these pathogens, increase the safety of food. By recognizing the importance of managing for both food safety and for wildlife, the FDA should try to avoid conflicts with the Endangered Species Act, Federal and State water quality mandates like the Clean Water Act, the National Organic Program, and programs of the Natural Resources Conservation Service (NRCS).

In 2008, over a mile of riparian trees and shrubs, one hundred feet wide, was bulldozed along the Salinas River because of misguided food safety requirements. Because more than 2/3 of the federally-listed rare species are found on private land, private property is very important in the management and conservation of habitat for fish, wildlife and plants. Salinas Valley farmers, under great pressure from food safety auditors and their buyers, reported in a survey that they had adopted measures to actively deter or eliminate wildlife on huge acreages. FDA should be very careful not to force farmers to choose between complying with food safety rules versus providing environmental stewardship services.

We run the risk of reaching for an unattainable and indeed risky “sterile” growing environment for the nation’s food crops, at great cost to farmers, consumers, and wildlife. We could instead build upon conservation practices already underway on many farms to enhance the effective ecosystem services provided by a healthy growing environment while ensuring the safe growing of food. Grass and wetlands are known to filter out 70-99% of E. coli so that it does not spread throughout the landscape. Vegetation like the hedgerows and windbreaks on Full Belly can filter dust and since E. coli O157 can be carried on dust, they too serve to reduce pathogen transfer. The billions of dollars spent by government programs on farm conservation should augment FDA standards, not be at odds with them.

Instructions on how to submit comments to the FDA can be found here. While it is important to stay involved it is also true that the legislative and policy responses to an increasingly complex and interlocking world seem increasingly bereft. Until meat animals and cattle are raised in healthier conditions the catastrophe of E. coli 0157 will continue to spiral out of control.

By Judith Redmond, Partner, Full Belly Farm

Related posts:

• Getting to the Root of Food Safety
• The Kitchen Project @ Sequoia High Teaches Youth to Cook Good, Clean, and Fair Food
• Smart Food Systems