By Judith Redmond, Full Belly Farm

We’ve been following with some concern, the conversations taking place in Washington D.C. on “food safety.” The policymakers and lobbyists are trying to respond to the outbreaks of food contamination in spinach, peppers, peanuts, pistachios and even cookie dough. The concerns are understandable, given the scary nature of some of the microbes that can get into food. Jean Halloran, Director of Food Policy Initiatives at Consumers Union said, with some hyperbole that, “Our current food safety system is broken and has been in need of reform for more than a decade… every day without action means more lives needlessly lost to food contamination.”

Research by the Community Alliance with Family Farmers after the 2006 spinach contamination outbreak showed that in terms of leafy greens, 98.5 percent of the reported illnesses were traced to fresh-cut, processed leafy greens. ‘Fresh cut’ is an industry term that does not include fresh produce sold without processing and bagging. The data compiled by CAFF indicates that centralized washing and packaging of produce from different farms may increase risks of cross-contamination. In fact, pre-cut salads stored in sealed plastic bags may be in an ideal environment for bacterial growth.

There is also strong evidence that the virulent E. coli O157 that causes serious disease and sometimes death when it gets on food, is strongly linked to feedlot beef eating high-grain diets and treated with prophylactic doses of antibiotics.

H.R. 2749 is the federal legislation expected to “overhaul the system and address the causes of contamination of food.” However, it will not have any impact on the way that meat, eggs or milk are produced. It says nothing about Confined Animal Feeding Operations where huge populations of cattle are crowded together. And in a tidy fait accompli the large vegetable producers and handlers in California have made sure that although they will be subject to most of the provisions of the new law, they themselves will maintain considerable control over its implementation on their particular farms (likely to all become members of the new National Leafy Greens Marketing Agreement).

So who is left? One of the most significant changes contemplated by this new legislation is the inclusion of vegetable growers under the jurisdiction of the Food and Drug Administration (FDA). The FDA will publish standards for the growing, harvesting, packing, sorting, transporting and holding of raw agricultural commodities. The standards will, at a minimum, address manure use, water quality, employee hygiene, sanitation, animal control and temperature control. It will be mandatory for farms to adopt the new standards. H.R. 2749 gives the FDA other increased authorities on farms, such as access to business records, ability to make unannounced inspections, and authority to quarantine facilities.

But farms, as many Full Belly members may understand, are considerably more complex than the processing facilities and laboratories that FDA staff are familiar with. While an FDA professional might be troubled by wildlife habitat or the presence of livestock on a vegetable farm, the farmer might believe that the integration of diversity and wildlife are critical to the farm and food’s overall health. While farms must be clean and safe environments for food production, we believe that the following principles should guide new regulations:

1) New regulations should address the causes of food contamination and should target processed vegetables, where the majority of the problems have been.

2) New measures must be evaluated as to their impact on small and mid sized producers. They must not discourage good producers from continuing production or others from entering production.

3) Compliance with food safety measures is best accomplished through education. Significant resources should be devoted to this effort. Government agencies should partner with producer groups to carry out this educational effort.

4) The FDA and the USDA should follow the model of the National Organic Program by allowing other approved agencies and organizations to pursue compliance with food safety measures.

5) Food safety measures must be evaluated as to their impact on the natural environment. The environment and its health must be enhanced by such measures.

If you too are concerned about the impact that FDA oversight of food safety may have, please contact your Representative and express your views. Let them know that to your thinking, the provisions in H.R. 2749 that affect produce growers do not get at the “causes of contamination in food” at all. Find your Representative.

Related posts:

• The Kitchen Project @ Sequoia High Teaches Youth to Cook Good, Clean, and Fair Food