Let A Farm Be A Farm

I’m pretty sure this is what Yogi Berra meant when he said “it’s just like déjà vu all over again”.

Last year, I wrote about the Food Safety Modernization Act and its far-reaching effects. And, while I really try to stay away from issues that are even remotely political in nature, this one really (really) concerns me. Not just for myself and my way of life, but for the future of farming and farm-related products.

But, now it’s back.

Do you have any idea what I’m talking about?  If not, read one or both of these posts from last fall.

http://homesteadhillfarm.blogspot.com/2013/10/at-risk-of-sounding-like-chicken-little.html

http://homesteadhillfarm.blogspot.com/2013/11/lookin-out-for-little-guy.html

Over the past year, all the public comments from farmers and consumers have been 

reviewed and the rules are being updated.  While the new version is somewhat less onerous than the original, it still has some serious faults (to my mind). And, this time, unless there is more public debate, this draft will indeed become final and enforcement will follow in short order and the face of Agriculture will change (and not necessarily for the better).

 A safe food supply is in everyone’s best interest.  Farmers and food producers would be foolish not to take food safety into constant consideration. 

Presently, the US can boast the safest food supply in the world.  Interestingly, we also spend less of our disposable income on food than any other nation. We have food choices that many only dream about.  There are all sorts of safety regulations already in place that make much of this new legislation redundant and heavy-handed.

My biggest frustration with the new wording remains the definitions and the monetary limits.  While there is so much emphasis on promoting the small, local farms, this legislation would in fact make start-up harder and once an operation got any size to it, compliance would become incredibly costly, not to mention time-consuming.  To address any issue with a ONE SIZE FITS ALL solution is simply ludicrous. While the FDA has changed some of the wording, the proposed regulations remain vague and seemingly inconsistent and quite possibly excessive.  The issues faced by a “mom and pop” operation selling directly to the public and a large operation with many employees cannot possibly be the same. To base compliance strictly on annual earnings is flawed to my mind.

While it is assumed that since MOST selling at Farmers’ Markets make far less than the low limit of compliance (and would be exempt), there are those who make enough to require partial, if not complete compliance (from what remains a very small farm).  It is those folks, and the future farmers and market vendors for whom I have great concern. On one hand you have the programs to promote small farms and then this comes along and makes small farming even more difficult. (is it me, or is that truly contradictory?) Now, let me just say right here.  I do NOT think small farms are better than large operations. Nope.  Not at all. Read THIS. But, this particular issue seems to have more effect on the small operations and I take that personally.  "Very small"  farms (those making less than $25,000 annually and would be exempt) will never begin to meet the food demands, even locally. But, "very small" and small farms (over $25,000) and their products are vital to the economy and the vitality of their communities. Many of these operations are already under some sort of inspection (at least for water) and shouldn't be subject to the same rules as large operations, particularly when selling directly to the public. 

So, I would ask you to take a minute (or two) and learn more about this issue.

 Check out this page.

You can let those in authority know what you think here. Simply download the farmer/food biz or consumer template, customize it, and either pop it into the mail or submit it online by the deadline.

Time is of the essence, the comment period ends Monday December 15, 2014.

This is from the National Sustainable Agriculture Coalition, and I find it most important.

“Once finalized next year, these rules will likely stand for generations of farmers.  It’s critical that FDA gets them right.  Join us in submitting comments to FDA today before the December 15 deadline and telling FDA: let a farm be a farm!

Farms innovate.  Don’t let the rules squash farmers’ innovative efforts in growing and selling local food.  The rules need to ensure that local food and farms can grow and thrive. 

Farms work with nature.  Don’t let the rules undermine farmers’ sustainability. The rules need to allow farmers to use sustainable farming practices. 

Farms deserve fair treatment.  Don’t let the rules raise costs for farmers, food businesses, and consumers by imposing unclear, inconsistent, and unfair rules. The rules need to provide options that treat family farms fairly without unnecessary, excessive costs.”

Food choices are important. We need all sorts of farmers and the safe and healthy food products that they provide.  We all need to work together (farms of all sizes as well as consumers) to provide plenty of food choices in a safe and affordable manner. As they are written, these new regulations won't necessarily promote safe food, but in some cases will prevent farms from production.

I will be writing to the FDA again to express my concerns and frustrations with the Food Safety Modernization Act again this year. The future of farming will be affected by this legislation for a long time to come.

It's time to say...Let a farm be a farm!