When I sat down to write today’s blog I fully intended to share something more charming than government rules and regulations. Something more cuddly and appealing, like a writhing ball of red wriggler worms in the compost. To be honest, I’d rather shovel the foot-deep layers of bedding and manure out of the winter chicken barn than dig into the new rules and regulations proposed in the Food Safety Modernization Act.
But the truth is, as we have visited with farmers around the region this fall, this act has come up over and over again as a frightening danger to small farm operations, especially those following organic practices and innovative integrated systems of both growing and marketing. Lately it’s been coming up on local papers and social media, with pleas to make comments before the November 15th deadline. It’s become both impossible and irresponsible for me to continue to ignore it, so I spent some time today sifting through links, trying to understand, and finally making my official public comments.
And it’s a good thing I did, because if we don’t pay attention and take some action these regulations have the potential to limit even my ability to shovel out the layers in that winter chicken coop and turn them into a productive soil amendment--or at least the ability to sell or market anything that we grew with that rich, organic fertilizer that required no manufacturing or transport beyond a shovel and the garden cart (talk about low carbon footprint!).
I am grateful for people who take naturally to government, policy, and committees--people like my father who, after two decades of serving on his local school board, can parse through pages of mandates and regulations as easily as he runs a harrow through his fields. For the rest of us, it’s easy to get lost and even to give up before taking any action. I’m writing today to urge you to take at least some action on this, even if you can’t dig through every detail. Though I am no expert, I’ve tried my best to distill down just a few of the core issues that could affect us and the successful diversified small farmers we admire and hope to emulate.
- Regulations on the use of manure and compost. Building healthy soil is the most important thing a grower does, and our main tools for that are the billions of microbes and soil fauna that work in our compost piles and fields. The proposed regulations make it very difficult to use this critically important soil amendment (already regulated under the regulations for organic practices) without either sterilization by chemical or physical means, or a lengthy waiting period between applying it and harvesting from the field it was applied to.
- Prohibitive costs to regulations, regardless of scale. Many of the requirements of the Produce Rule (including overly strict requirements for weekly testing of any surface water used for irrigation) are estimated by the FDA as averaging $4,697 per year for “very small farm” ($25,000-$250,000 in annual sales). Much of this has to do with small farms, which present a much lower risk, being required to go through the same proceedures and regulations as much larger operations.
- Limitations to innovative and diverse marketing strategies. especially direct-to-consumer marketing. The current rules do not clearly distinguish when a farm becomes a “facility” subject to a suite of additional regulations and costs that really are not necessary or appropriate for a farm stand, farmer’s market booth, or a multi-farm CSA.
I encourage you to follow the links to do more detailed research yourself, if you can. If you’re inclined to policy, you can dig in to your heart’s content by following the rich set of links, on the National Sustainable Agriculture Coalition’s website, or the #FixFSMA campaign.
It's not that our national food system doesn't need some drastic improvements to ensure food safety (recent outbreaks of various food-borne pathogens make that clear). It's just that the current set of rules places an undue burden onto the smaller farms, drastically out of proportion to the risk that they pose, compared to larger operations. That problem can be fixed, with your input, so small farms can continue to operate and be accountable directly to their customers, while larger operations comply with improved regulations.
These regulations apply most directly to the farms and farmers, of course, but remember that even if you are on the buying or eating end, this affects you, too. If you value access to fresh, carefully grown produce or farm products, if you find yourself inspired by farm-to-school programs bringing fresh veggies into elementary schools, or if you like picking up a box of produce directly from the people who grew it, you need to chime in with comments. It might not be as fun as picking out your favorite vegetables at the market, but this kind of action is critical to your ability to do that next summer. Please join us in taking some action by learning about the issues, making your comments, and spreading the word.
Note: The links above include some tips and suggestions on effective comments, but require several clicks and a little patience to get to the actual comments page. If you're already informed and savvy, and ready to make comments directly, you can jump straight to the government pages in the links here and here.