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
Every year I try to use my chance to speak at our annual conference to raise some of the most important issues facing us in the sustainable farming community. And with each succeeding year the urgency of these issues seems to increase. This is partly because some of the negative situations we face are actually getting worse, and partly because the positive solutions our movement offers are increasingly met with resistance and denial by those who represent the status quo.
Let’s back up just a bit and review some of the challenges we have encountered over the past year. First and foremost, 2013 will always in my mind be the year of proposed rules coming from the Food and Drug Administration (FDA) aimed at implementing the Food Safety Modernization Act (FSMA). What a long slog it was! At conference time last year we were still reviewing about 1,200 pages of material – with hundreds more to come – and were just starting to think about some of the implications involved should the proposed rules go into effect.
At the beginning, we were very much outnumbered and outspent in terms of being able to influence the final outcome, but what we had going for us was beyond the ability of any other group to purchase with mere dollars. We had a devoted coalition of dozens of groups from across the country working feverishly together, with meetings every week throughout most of the year, and many of us in smaller groups attending FDA listening sessions held across the country. We also found some new partnerships that we hadn’t really expected, including with faculty and students at the Law Schools of Harvard, Georgetown and Emory Universities, the leadership of the United Fresh Produce Association – a powerful group that had fought us hard in the legislative phase of FSMA, and even the National Association of State Departments of Agriculture (NASDA). At one point NASDA even shared a post I had written on my Write to Farm blog with the Departments of Agriculture in all fifty states. 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
Blogger’s note: This is a guest post coming from two very experienced PASA farmers regarding the potential impact of the rules being proposed by the Food and Drug Administration (FDA) in implementing the Food Safety Modernization Act (FSMA). I have learned that it is often best to just step aside and let the farmers we work with do the talking, and this piece helps to prove that point! Readers should keep in mind that the FSMA rules are open to public comment through November 15 of this year. To learn more, please look elsewhere on this blog, or check the National Sustainable Ag Coalition website on this matter. BWS
By Michael Tabor, Needmore, PA and Nick Maravell, Buckeystown, MD
Each week at my farm stands in the Maryland area, we try to explain a peculiar situation to our customers. On the one hand, they want to buy our fresh fruit and vegetables. However, I tell then, that in a few years, these will all be illegal to sell!
Because they have some degree of dirt and bacteria on them. The strawberries for instance, have some trace amount of straw and soil on them. As do the tomatoes, beans, and cucumbers. We do rinse them before leaving the farm – but we won’t put them through a disinfectant bath nor pack them in antiseptic plastic containers and put “PLU” labels on them. That’s not what consumers want at a farm market—nor is it something we’ll ever be able to do. Continue reading
Subtitle: Antibiotics and Pesticides and GMOs, Oh My! …or, It’s the System, Stupid!
In working on issues related to food safety over the past four years, I have often been struck by how the language of regulators and consumer advocates sounds frighteningly similar to that used by defense and homeland security officials to talk about the threat of terrorism. At first just a source of amusement, I later could not shake the impression that the two seemingly unrelated predicaments were heralded by prophets of doom singing from the same hymnal. Whether the “enemy” happened to be a terrorist or an unwelcome pathogen in our food, it seemed the only solution would be to “smoke ‘em out” and do them in wherever they lurked.
The link between the two sets of issues is in fact indelible, starting with passage of the so-called Bioterrorism Act of 2002 (BTA) before the dust of the fallen World Trade Center in New York had fully settled. Among other things, the BTA for the first time required federal registration of all “facilities” that handle, process or distribute food. That category was supposed to exclude all farms, except that when the Food and Drug Administration (FDA) got to looking, they realized that in fact many farms these days are doing things that look like what they thought only food facilities would do. For historical perspective, farms have always been rather complex places of business, except perhaps in the minds of federal regulators.
What many people don’t realize today is that the new Food Safety Modernization Act (FSMA), which was signed into law in January of 2011, was intended primarily as an elaboration and ultimate completion of the BTA. So for all the noise about foodborne illness outbreaks since 2002, the new FSMA actually has its roots in the desire to thwart terroristic intentions, or at least the theoretical threat that some external evil force would attempt to destroy our nation by poisoning the food supply. Continue reading