Let a Farm Be a Farm

{blogger’s note: Please make sure to read the action alert at the end of this post!}

With the dust still settling from the horrific terrorist attacks on September 11, 2001, the U.S. Congress passed and President George W. Bush signed into law a piece of legislation widely known as the Bioterrorism Act (BTA) in early 2002.  From one perspective this action was a necessary response to one of our greatest vulnerabilities as a nation, a potential attack on our people through the food supply chain. From another, it was an overreach of federal power intended and abetted by corporate America to extend their control over our food system. The actual reality of the situation probably falls between these two perspectives, and in many ways is still very much in play today.

No matter the effects of the BTA, one of the most significant things it did was to draw a distinction between two major categories of activity within any food system by defining a “farm” as a producer of raw agricultural commodities as distinct from a “facility” that transforms those commodities into the variety of processed foods that can readily be observed in any modern supermarket.  The distinction was critical, especially since the stated intent was to exempt all farms from the new regulations facilities would face, beginning with the requirement to register under the federal Food and Drug Administration (FDA), establishing the agency’s authority to regulate the activity of all such facilities.

Enter the Food Safety Modernization Act of 2010 (FSMA), which was intended as an elaboration and extension of the BTA, now with added intent to authorize direct FDA regulation of farms producing raw agricultural commodities consumed by humans or animals with very little or no processing by a regulated facility along the way. The immediate effect of FSMA was to blur the lines between farms and facilities, such that even FDA personnel visiting farms – some of them for the very first time – were apt to see facilities wherever they looked. It was a dramatic representation of the old adage “Give a boy a hammer and everything looks like a nail.”  Even those of us working to improve draft regulations written to implement FSMA were wondering if anything such as a farm, pure and simple, could ever exist, at least according the definition being used in the new regulations. Continue reading

A Message to Public Officials on Food Safety

{Blogger’s note: I know I said there would be no more posts before the end of the FSMA comment period on November 15, but I came across this statement approved by PASA’s board of directors at the very beginning of this process nearly five years ago, and thought it was worth sharing again at this time. Our views have matured considerably since that time, but the basic points are the same. Please keep in mind that help is available for commenting on the proposed rules at the PASA website, including templates to follow and links directly to FDA}

Pennsylvania Association for Sustainable Agriculture (PASA) — May 22, 2009

It seems everyone in elected office these days wants to do something about food safety.  Who can blame them, given that the headlines on any particular day might carry news of the latest food poisoning scare?  It is a supreme paradox that, while all of us must eat in order to survive, food can also become an instrument of death.  As a community of farmers, we must also come to terms with the fact that harmful pathogens occasionally present in food can originate on farms in various ways that at times defy easy explanation. Continue reading

Consider the Bees of the Field

{Blogger’s note: This post was completed with the very welcome assistance of my colleague Jo Ann Baumgartner, director of the Wild Farm Alliance located in Watsonville, California. Jo Ann can be reached at wildfarms@earthlink.net}

I was honored to be asked this year to address the annual conference of the Eastern Apicultural Society (EAS) held in early August in West Chester, Pennsylvania.  With well over 500 professional beekeepers and bee scientists present, it was also a tremendous opportunity for me to learn something about a topic with which I had very little previous experience. I was both amazed and a bit alarmed with what I learned.

While the occurrence of Colony Collapse Disorder has captured the concern of the general public, very few people know just how complex the situation with honeybees really is.  I’ll add that even fewer have any idea how the viability of the bee population might be affected by the Food Safety Modernization Act (FSMA). Congress passed FSMA in 2010, and the Food and Drug Administration (FDA) has now issued proposed rules for its implementation, with a deadline of November 15, 2013 for public comment.

In brief, the situation for honeybees and other pollinators, already dire in some places, is likely to get worse as new regulations associated with FSMA take effect. It really comes down to loss of biodiversity in the diet of honeybees and potential destruction of the habitat necessary for their survival. To the extent that food safety regulations make these situations any worse, by promoting the separation – far away from food crops – of what also functions as wildlife habitat, so will the pollinators, and ultimately the crops themselves, suffer. Continue reading