By Ed Yowell
Fresh carrots, perfectly ripe strawberries, crisp salad greens from local, sustainable, family farmers at farmers markets, from CSAs, and in grocery stores. Are these the foods you like to buy, prepare, and enjoy with your family and friends? If you are reading this, I think I know the answer, "YES!"
Sustainable, small and mid-scale family farmers across the country have been innovating with new, creative approaches to get these kinds of fresh, healthy foods to people affordably, wherever they shop and eat, and – even better – do it using sustainable and organic growing practices. Innovations like direct marketing, aggregation, food hubs, multi-farm CSAs, and on-farm, value added processing are getting more good, clean, and fair food to more eaters than ever before!
But wait, there's a catch. Remember last year when we sounded the alarm about new food safety regulations being developed by the United States Food and Drug Administration (FDA), under the federal Food Safety Modernization Act (FSMA)? And how the proposed new rules could make sustainable and organic agriculture, local food, and farm conservation collateral damage in the name of a safer food system?
The most significant incidences of foodborne illnesses, that are responsible for FSMA and the proposed new Produce Standards and Preventive Controls Rules, have been the result of industrial-scale food production and distribution, not the result of food produced and sold by small and mid-scale family farms. Responsible small and mid-scale, sustainable, family farmers support a safe food system and should have the protection of rules that are clear, consistent, and reflective of the scale and risk of their operations.
There is some good FSMA news and some bad FSMA news.
The good news is that the FDA received tens of thousands of comments from responsible farmers and concerned eaters (like you), and, to their credit, they took those comments seriously, re-drafting several key sections of the proposed FSMA rules.
The bad news is that, while the FDA did make some critical improvements, the improvements don't go far enough. They mean well, no doubt, but the FDA still doesn't quite get what it means to be a sustainable family farmer participating in a local farm and food economy.
As someone who cares about sustainable food and farms, we need your help to tell the FDA, Let a farm be a farm!
- Farms innovate. Don't let the rules squash farmers' innovative efforts in growing and selling local food. The rules need to ensure that local food and farms can grow and thrive.
- Farms work with nature. Don't let the rules undermine farmers' sustainability. The rules need to allow farmers to use sustainable farming practices.
- Farms deserve fair treatment. Don't let the rules raise costs for farmers, food businesses, and consumers by imposing unclear, inconsistent, and unfair rules. The rules need to provide options that treat family farms fairly without creating unnecessary, excessive costs.
There is no doubt, everyone has a role in ensuring that our food is safe – from the farmers who grow the food to the eaters who take the food home and prepare it. But, unless we act now, the proposed new rules will have a devastating effect on the small and medium-scale family farmers and businesses responsible for putting local, sustainably produced fruits, vegetables, and other healthy foods on our plates – which, in turn, undermines local farm and food economies and affects our health and well-being.
STAND WITH FARMERS, COMMENT BY DECEMBER 14!
It's EASY; customize, cut, paste, and submit your personal message (below) to the FDA
Suggestions for customization are highlighted in bold italics. Submit your customized comment in TWO places – to the Produce Standards Rule (www.regulations.gov/#!submitComment;D=FDA-2011-N-0921-0973) and to the Preventive Controls Rule (www.regulations.gov/#!submitComment;D=FDA-2011-N-0920-1553). This is important because the food you love is affected by both rules.
Re: Preventive Controls Rule: FDA-2011-N-0920, Produce Standards Rule: FDA-2011-N-0921
To whom it may concern;
I am a [consumer, parent, etc] who is very concerned about the impact that the FDA's proposed FSMA rules will have on the [farms that I buy food from, my family's ability to find local food, the environment, etc.]. I ask you to let a family farm be a farm – and to treat it like one, not like an industrial factory or corporate mega-farm!
I value safe food and family farms and want to be able to [choose food for my family based on its sustainable production / support my local farm and food economy / purchase local, sustainable, and organic food].
I get much of my food at [my farmer's farm stand, my farmers' market, from my CSA, at a grocery store offering local food] and I want to continue to be able to find the food I love there. These proposed new rules can't subject family farmers to rules intended for massive, industrial agriculture and be so expensive to follow that they put small and mid-scale sustainable family farmers out of business.
Please modify the proposed new FSMA rules to reflect the realities of sustainable farming:
- Farms innovate. Don't let the rules squash local food. The rules need to ensure that local food and farms can grow and thrive. The final rules must provide a clear definition of what FDA considers a farm, and must take a risk-based approach to regulating farms. FDA must clarify the difference between a farm and a facility using common sense and risk-based distinctions that have clear connections to promoting food safety.
- Farms work with nature. Don't let the rules undermine sustainability. The rules need to allow farmers to use sustainable farming practices. FDA should incorporate stronger incentives into the rule for on-farm conservation that supports food safety and protects our soil, water, and wildlife habitat.
- Farms deserve fair treatment. Don't let the rules raise costs for farmers, food businesses, and consumers by imposing unclear, inconsistent, and unfair rules. The rules need to provide options that treat family farms fairly without unnecessary, excessive costs. FDA should find ways to decrease the costs of compliance with the new rules, especially for small and very small farms.
Thank you for your consideration,
[Your full name, city and state, e-mail address]