The Food Safety Enhancement Act is now before Congress! HR2749 This act treats every food producer from the smallest Artisan baker that sells his/her product to the Farmer's Market or CSA, to the food industry giant Kraft foods, as if they are the same! This is as if the food produced by small farm producers present the same risks of adulteration as the Mega food producers, and as if the same preventive measures are necessary for both. Think about the number of people in contact with food, and ways that contamination can occur in the giant food industry. This is so different for small farms and other small product producers. We should be encouraging these producers into the market, not erecting more barriers for them. This new bill will erect barriers, possibly insurmountable ones, to local Artisan food producers and small Farmers.
For example: the bill requires every food producer to pay a $500 fee and undertake a "hazard analysis" to prevent their food from presenting a safety hazard to the public. So Heartland Bakery, New Moon Candies and other local Artisan food producers will pay the same fee as Nestle or Kellogg's and be saddled with the same paperwork burden. I'm thinking Nestle and Kellogg's won't miss the $500 and can probably absorb the costs of developing their "hazard analysis." They probably have on staff a myriad of people to do record keeping for every product line they produce, I know that this is impractical and unaffordable for most small producers.
Here's another example: Food producers engaging in "interstate shipping" must develop a "Food Safety Plan." Again, it doesn't matter how small or new a producer is or how they produce their food product. Small farmstead cheese makers in Alabama who might want to sell at Tennessee farmers' markets, are treated the same as Tyson, which ships tons of factory-farmed chicken to all fifty states. Under HR 2749, both will be . Under HR 2749, both will be required to develop a food safety plan including these elements:
preventive controls being implemented;
procedure for monitoring preventive controls;
procedures for taking corrective action;
verification activities for the preventive controls, including validation, review of monitoring and corrective action records, and procedures for determining whether the preventive controls are effectively preventing, eliminating, or reducing to an acceptable level the occurrence of identified hazards or conditions;
recordkeeping procedures;
procedures for the recall of articles of food, whether voluntarily or when required;
procedures for the trace back of articles of food, whether voluntarily or when required;
procedures to ensure a safe and secure supply chain for the ingredients or components used in making the food manufactured, processed, packed, transported or held by such facility; and
procedures to implement the science-based performance standards issued.
I'm thinking this may put some of our Artisan producers out of business.
It's always difficult to parse out the various reasons people are against any new law to figure out whether it's hysteria from those who simply distrust the government (though I have a lot of sympathy for these folks, too) or whether the provisions in a certain law are really as alarming as some would have us believe. It's easy to dismiss alarmists; let's dial down the hysteria. However, this bill, if passed in its current form, will make it significantly more difficult for small and Artisan food producers to start and maintain a viable business. This will make it harder to find such foods from local sources. This bill, if passed as written, will actually make the food safety problem worse by eliminating sources of good, healthy, locally-produced Artisan food products that are easily traceable, and one that insures a safe food supply chain.
At the very least, we believe that the compliance requirements should be as reasonable for small farmers as it is for Hormel -- which means that small farmers probably ought to pay $25 to register and be required simply to maintain records of purchases so that if a food safety issue arises, those records can be used to figure out what happened. But to require small farmers and Artisans to adhere to the same rules as Pepsico and Heinz is not only silly but doesn't address the fact that food safety problems we've seen over the past ten years have not occured at small farms or Artisanal bakeries.Industrial food giants are at the root of this problem. Artisan food producers and small farmers are the solution, not the problem. Let's ask our lawmakers to recognize that.
I'm not sure the answer is to ask our lawmakers to simply vote against this bill. We do need to address food safety issues in our industrial food supply. But we don't need to behave as if those same problems are inherent in all food production. They aren't. Here on our farm, we are very much in favor of having systems in place to protect the consumer from food borne illnesses, and maintaining records to show compliance. But to ask a small farm to be governed by the same rules as big Agribusiness (where crops are difficult to trace back to a source of contamination)is not only unreasonable, but unafordable as well. If small farmers and producers of local food are to stay in business, let's do the right thing here. Make the regulations such that local producers can continue to bring consumers safe, nutritious and fresh products as they have in the past, by regulating them in a realistic manner.
Ask your congress person to change this bill to provide for a realistic system with which small producers can comply. Those regulations that govern the food giants make this impractical and unaffordable to the small producer. With the regulations that are being put before Congress, the small producer would be looking at having to hire an additional person just to monitor the entire process. Not many small farms or Artisinal producers we know could do this without passing costs along to consumers. No one I know wants to do that.
To email your congress person, visit the Farm-to-Consumer Legal Defense Fund's petition page, which takes you to a handy form where you can enter your address. Enter your message in the blank box, and it will be sent to your congressional representative. The message I'm recommending you send is this:(Just use your Word Processor feature on your computer, cut and paste this message).
I believe small,artisan food producers and farmers should be exempted from this bill as it reads today. They are not the problem. They are the SOLUTION to our food safety problems. We should not be creating new barriers to entry and new compliance burdens for these small producers of healthy food.Traceability is not the same issue with small farms as it is with mega food producers, and the regulations on Small farms and Artisinal producers should reflect this. Thank you.
In closing, we would like to say that we are very much in favor of providing our farm patrons with a safe food supply chain. We operate our farm with this in mind on a daily basis. We already maintain daily records here on our farm as are required by our Certified Organic certification, but adding more record keeping at this point would definitely be burdensome and add to our expenses, with no added food safety advantage to our customers.
Even if you are not an "activist" this is a bill where consumer involvement is a "must" if you want to support your area farmers, and farm producers. Call your Congressional representative and give him your opinion.
Small Farmers and Farm Producers thank you for your effort on our behalf!
