Fear the Turtle: FDA's One Sided Food Safety Regulations

The FDA is accepting public comments through November 15th on a draft set of regulations based on the Food Safety Modernization Act (FSMA). Shining a spotlight on food safety is a great idea and something that consumer advocates have been working toward for a long time. Clearly there are safety problems with our nation's food system, and we have seen what happens when unsafe food gets into the marketplace. Unfortunately, the draft rules have some real problems and could undermine small vegetable farms like my own. Please take action by hopping over to the National Sustainable Agriculture Coalition's website where they do a great job of explaining what is at stake and make it easy for growers or consumers to make a difference by sending comments to the FDA.

Fear the Turtle - Really?

The FSMA issue first grabbed my attention when I attended my Maryland state organic farmers meeting last winter and listened to a presentation about the draft rules. To my surprise, the presenter showed a slide of a box turtle under a tomato plant and described the turtle as a "dangerous intruder" because it could carry pathogens. Other red flags in an operation included farming near waterways and wooded areas where wildlife abound and including animals in your farm operation.

My husband and I run a small CSA based farm raising vegetables and flowers in Maryland just 20 miles from Washington, D.C. We have been growing vegetables for more than 10 years for people who live around our farm and in the Capitol Hill neighborhood of Washington D.C. We always considered the natural landscape around our farm an asset. The wooded areas and small streams that surround our farm help ensure that our farm remains relatively free of chemical pollution and runoff.

We even have a few natural predators like foxes, owls, snakes and bats that reduce pressure from insects and groundhogs.

When you look at food safety entirely through the lens of biological threats, wildlife like birds and turtles are perceived as dangerous invaders. On the other extreme a farm near polluting industry might appear "safe" because it is already free of wildlife. We cannot grow healthy food in a landscape scrubbed of natural elements or sterilized by chemicals. Consumers are clamoring for natural, organic food that is free of chemical pollution. We need rules that encourage farming with nature.

We need to take a broad and comprehensive approach to food safety. Addressing food safety by focusing on biological pathogens without consideration of the impacts of chemical agriculture on workers, consumers and the environment is a lost opportunity. We need to broaden the scope to include the dangers of chemical pesticides, overuse of antibiotics, threats from genetically modified crops and other critical issues. An effort like this would need to involve multiple agencies beyond the FDA and include input from the EPA, the USDA, state agricultural agencies, farmers, environmental groups, consumers and others.

Farming with Neighbors

There is another piece of the proposed FSMA rules which may have negative unintended consequences for rural life. The rule seems to discourage farmers from working together by classifying a farm as a "facility" if the farmer buys fresh produce from another farm. Facilities are regulated by another new set of draft rules which can be expensive and time consuming to understand and follow.

In our experience one of the best ways farmers can support each other is by buying or swapping from one another. It can take the edge off a horrible crop loss, provide support to neighbors and build real rural partnerships. When farmers buy from each other they also stop and talk, sometimes share supplies and basically start knitting together rural community. But since that simple act could magically transform your farm in to a facility, the new rules could discourage farmers from working together.

On our farm we have made a conscious effort over the years to support other farms. I believe the results have been positive for our community. My husband convinced a Mennonite farmer to try organics; another nearby farmer has emerged from retirement to farm alongside us. We trade produce all the time to fill each other's CSA boxes, we share fields, equipment and most importantly friendship. Sometimes it is only another farmer that would understand what it feels like to see your apple orchard nibbled down to stubs because starving deer broke the fence. We need each other and we are so busy that sometimes buying and selling is what brings us together.

Everybody knows how fragile rural communities are today. But thanks to the local food movement we are finally seeing some signs of recovery, especially in the organic sector and local food movements. We should be coming up with ideas to support rural community, not unravel it further.

FDA Need to Rework these Regulations with an Eye on Small Farms

When I first learned about FSMA in a presentation I saw last winter, I left disheartened and feeling like we should give up vegetable farming or fall back on non-food crops like flowers. But there are only so many sunflowers and zinnias the local market can absorb before saturation. And people want okra, tomatoes, kale, arugula and lettuce. In fact they need these vegetables, because these foods are healthy and that is really the whole point of farming anyway.

The FDA should take a much closer look at how these regulations could harm small growers or cast doubt over the safety of local food. The rules need to be rewritten with farmers at the table to ensure justice and continued viability for small farmers. Each component of the rule needs to be based on the best available science and have clear grounding in the realities of farming in diverse environments across the country. The FDA should find ways to encourage farmers to continue raising healthy vegetables for their communities.

The FDA should listen to the comments coming in from farmers, consumers and sustainable farming advocates and go back to the drawing boards. They need to consider the big picture of food safety including threats from GMOs, antibiotic use and conventional pesticides to workers, consumers and the environment. Each aspect of these regulations needs to be discussed with a broad group of farmers from across the country to ensure that responsible growers can continue to grow food in compliance with the rules. Now is our chance to craft rules that make logical sense and address all of the threats to our food supply from chemical pollution to biological pathogens. Together we can make our entire food system safer for everyone and nurture rural communities.