The Honorable Thomas Vilsack, Secretary
United States Department of Agriculture (USDA)
1400 Independence Avenue SW
Washington, DC 20250
March 4, 2014
Re: Docket No. APHIS-2013-0047
Dear Secretary Vilsack:
The Pennsylvania Association for Sustainable Agriculture (PASA) is one of our nation’s largest member-based, sustainable farming organizations, with about 6,000 mostly farmer members located primarily throughout Pennsylvania and across the Mid-Atlantic region. Our mission is to promote profitable farms that produce healthy food for all people while respecting the natural environment. In keeping with this mission, we wish to express our grave concerns regarding the issue of “Enhancing Coexistence” as framed by the Report of the AC21 Committee in 2012. Continue reading
The past year has been an extraordinary one in the world of sustainable agriculture for many reasons, some of which may not be fully understood for many years to come. That year (November ’12 thru November ’13) included much attention across the country to labeling of genetically engineered foods, including two high-profile public referendums that went down to defeat in California and the state of Washington. For many, this effort, occurring state-by-state, has become the holy grail of the effort to promote local, sustainable and organic food and farming systems for the future.
But for me and many of my closest colleagues across the country, the past year has been about something much less glamorous, i.e. the drive to understand, explain and then fix the problems in proposed regulations associated with the federal Food Safety Modernization Act (FSMA). This was certainly a long slog by any measure, with dozens of folks working together to generate hundreds of pages of public commentary in response to thousands of pages of material we were given to digest last January. It was an extraordinary experience that I wouldn’t want to repeat, but the sort of work that had to be done at a critical moment in our sustainable food system movement. Continue reading
Back when the Food Safety Modernization Act (FSMA) first started to move through Congress in 2009, none of us really anticipated that we’d be fighting over four years later to preserve the very idea of a “farm” as defined in the new law. Well, almost none of us expected this, except perhaps my very dear friend Russell Libby, then executive director of the Maine Organic Farmers and Gardeners Association (MOFGA). In an email directly to leaders at the Food and Drug Administration (FDA) with whom we were negotiating, Russell decried what he called the “broad and inclusive definition of ‘facility,’ and relatively narrow sense of what constitutes a ‘farm,’” contained in the language of the Bioterrorism Act of 2002 (BTA), upon which FSMA would rely for such definitions.
Russell is now gone, a victim of the cancer that took his life a year ago this December. There will always be a hole left in the lives of those who knew him, and also now this lingering feeling that he could see ahead, to the potential disappearance of farms as we know them, both literally and in the figurative sense as part of the laws of our country. And as the newly-extended comment period closes this week (Friday, November 22) for comments to FDA on FSMA, there is almost certainly no higher priority to any of us than that the definition of a farm ends up in the regulations as richly diverse and comprehensive as we have always known it to be. Please take one more look, and help us get this right. Continue reading
There’s something happening here
What it is ain’t exactly clear
There’s a man with a gun over there
Telling me I got to beware
I think it’s time we stop, children, what’s that sound?
Everybody look what’s going down
–Stephen Stills, For What It’s Worth, 1966
If you’re like me, you are starting to grow weary of all the hoopla generated by the Food Safety Modernization Act (FSMA) and the effort to generate public comments to the Food and Drug Administration (FDA) by the November 15 deadline. This has been a long slog, seeming perhaps like much ado about nothing to many who are not directly involved. Along with Stephen Stills, you might be tempted to agree that what’s happening ain’t exactly clear, and no one could blame you for that.
The tendency in situations like this is to exaggerate what’s happening, in order to get people to pay attention to what is otherwise a rather mundane subject. There has been plenty of that type of hyperbole in the food safety debate, and this writer is not totally innocent in that regard. But when the public discussion about food safety regulation began in earnest in early 2009 – following problems discovered with our beloved peanut butter – there were various public messages promising that backyard gardening was about to be outlawed by Congress. Well, such blatant falsehoods did more damage than good, directing attention away from some extremely important implications for our food system in the ongoing saga of passing and implementing FSMA. Continue reading
You really have to hand it to the Food and Drug Administration (FDA). They have accomplished a feat in the last 10 months that Secretary Tom Vilsack and his United States Department of Agriculture have not been able to do after five long years of trying . . . uniting America’s farmers of all stripes to stand up for each other and speak with one voice.
Beginning in January of this year, when the FDA issued its first proposed rules under the Food Safety Modernization Act (FSMA), which passed Congress in 2010, produce farmers in particular, both big and small, have been reacting with skepticism that the federal government really understands the nuts and bolts of food production well enough to tell them how to do it in a way that minimizes risk to consumers.
Maybe it’s because these farmers know the actual science involved – that diets rich in fruits and vegetables can save far more lives than the risk of pathogens would ever cost our society. I suspect, however, it’s a far more concrete image that has galvanized the farming community – that of two young farmers led into a Colorado courtroom in shackles, despite their lack of knowledge or intent to hurt anyone with the Listeria-laden cantaloupe they sold through Wal-Mart and other big retailers to consumers across the country. Continue reading