Ed. Note: OFAN subscribers are used to seeing our action alerts and updates for the Farm Bill and other federal legislation. This service is also intended to inform you of opportunities to submit comments on regulatory issues that affect organic growers, such as the one below.
USDA SEEKS COMMENTS ON
REGULATIONS FOR HANDLING LEAFY GREENS
California group alarmed by impact on small growers, organics and the environment
In the wake of recent outbreaks of food-borne illness from bagged produce the USDA is seeking comments on the possibility of a Federal Marketing Agreement for handlers of leafy green vegetables According to the Community Alliance with Family Farmers (CAFF) in Davis, CA, this one-size-fits-all agreement could have negative impacts on small and midsize growers and may prohibit organic farming practices that help preserve wildlife habitat on farms. Scroll down for more background information.
The USDA published the request for information on October 1, and is accepting comments until December 3, 2007. It is vital that organic and small-scale producers speak out on this issue!
Comments can be submitted easiest by fax to (202) 720-8938. Comments can also be submitted online at www.regulations.gov. (Scroll down to get detailed instructions on how to do this.) Comments should include the following:
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Reference Docket number AMS–FV–07–0090; FV07–962–1 AN.
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Reference Pages: 56678 - 56680, Federal Register/Vol. 72, No. 192/Thursday, October 4, 2007/Proposed Rules.
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Your full name and address and the name of your farm or relevant business (if applicable.)
You can view a sample letter at the CAFF campaign website. We encourage you to write original letters as they are given more weight than form letters. If you have any questions or need guidance in submitting comments, please contact Tracy Lerman at tracy@ofrf.org or (831) 426-6606 x 108.
Background
(This information is condensed from material provided by the Community Alliance with Family Farmers.)
In the wake of several devastating food-borne illness outbreaks, the US Department of Agriculture is considering creation of a Federal Marketing Agreement for leafy greens that is similar to one already in play in California. Handlers who sign onto a marketing agreement must require all of their suppliers to adhere to a certain set of growing practices. While joining the Marketing Agreement is not mandatory, it is likely that most handlers will sign on to the agreement (as has happened in California), forcing all farmers, big and small to comply with these onerous measures that do little to protect the public from food-borne illness.
The 2006 E. coli O157:H7 outbreak that was traced back to bagged spinach grown in California was one in a string of several food-borne illness outbreaks from bagged pre-cut leafy greens. These events prompted the pre-cut vegetable industry, under the auspices of the California Department of Food and Agriculture to create the Leafy Greens Handler Marketing Agreement (LGMA). The LGMA has adopted a set of Good Agricultural Practices (GAP), and handlers who sign onto the LGMA impose these practices on the growers supplying them this product. Virtually every handler in CA has signed on to the LGMA, meaning that, outside of direct marketing to consumers, growers have no choice but to comply with the LGMA practices if they want to sell their product. Moreover, the LGMA is controlled by the largest grower-shippers and processors, and small distributors and growers have no representation.
The GAP imposed by the LGMA place the entire burden of food safety on growers and none on the processors. Many of the practices include measures to “sterilize” farms that prohibit important conservation practices. For example, farmers have been required to install chain-link fences around their farms and remove any habitat that supports wildlife. Further, the GAP includes vegetables like chard or kale that are usually cooked and have never been the source of an outbreak. As well, it doesn’t distinguish between pre-cut (processed and bagged) greens and whole greens, even though the overwhelming majority of E. coli illnesses from California produce (98.5% since 1996) have been linked to pre-cut greens. The GAP is designed for large-scale suppliers of the fresh-cut processing industry, not small and midsize intensified farming operations.
For more information, visit CAFF’s Food Safety Campaign webpage or read the Federal Register notice.
How to Submit Comments Electronically
1) Go to www.regulations.gov.
2) Under “Search Documents” Step 1, choose “Documents with an Open Comment Period.”
3) Under Step 2, choose “Department of Agriculture – All”
4) Under Step 3, choose “Proposed Rules.”
5) Under Step 4, choose “Docket ID” and then type in “AMS-FV-07-0090” and then click “Submit.”
6) On the next screen, click on the tiny yellow button on the left side of the page, under the column “Comments Add/Due By.”
7) Follow the instructions on the next page, and remember to scroll down to the bottom of the page to fully submit your comments.
If you have any questions or need assistance in submitting comments electronically, please contact Tracy Lerman at tracy@ofrf.org or (831) 426-6606.
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