From NOFA/MASS, helping us to be ever vigilant about how one-size-fits-all policy and regulation affects local smaller-scale production:
Remember the Food Safety Modernization Act (FSMA) that passed last year? We won a hard fought battle, securing appropriate food safety rules for small-to-midsized farms and processors producing fresh and healthy food for local and regional markets. This law will be implemented by one of the agencies with food safety authoritythe Food and Drug Administration (FDA).
Now, USDA’s Agricultural Marketing Service, an agency with no food safety expertise or authority, is proposing to establish a set of food safety regulations for leafy greens (spinach, lettuce, and cabbage) growers and handlers who sell into the wholesale market, called the National Leafy Greens Marketing Agreement (NLGMA).
The most powerful “Big Ag” players in the leafy green industry are pushing the National Leafy Greens Marketing Agreement (NLGMA). The sellers, processors, or distributors that sign on to the rule will require that the farmers they purchase from comply with its standards. The rule adds a second and conflicting layer of food safety standards and audits on top of FDA food safety rules.
How to comment:
USDA is seeking written comments from the public on the NLGMA proposal by July 28th. Write USDA today to urge them to reject this proposal. CLICK HERE TO SUBMIT A COMMENT TO USDA
Here are some suggested points to make:
I oppose the creation of a National Leafy Green Marketing Agreement, which I believe to be the wrong approach to address food safety concerns.
The Agricultural Marketing Service is not a food safety agency. It is bad public policy to create food safety regulations in order to address the “marketing” goal of increasing consumer confidence in the safety of leafy greens. Food safety policies should be driven by science, not by marketing problems.
The NLGMA, as proposed, would give the large conventional produce industry the ability to use its own world view to dictate farming practices. Small scale and organic farmers would have a very small voice in the standard-setting process.
The NLGMA is modeled on state food safety agreements in California and Arizona. In those examples, the conventional produce industry has pushed through food safety regulations that are biased against organic and small-scale farmers, have led to the destruction of wildlife habitat and discouraged good conservation practices on farms.
Diversified farming operations with complex rotations have been shown to be beneficial to the environment. Yet crop-by-crop food safety regulations, such as the NLGMA, are an economic disaster for diversified farming operations, and are biased toward large mono-cultural operations. For a farmer with 40 crops on 100 acres to comply with 40 different food safety regulations is prohibitively burdensome. Crop specific food safety regulations, such as NLGMA, will drive farmers out of environmentally sensitive diversified crop production, and toward chemical-intensive mono-cultural operations. This is counter to the goals of food safety and more environmentally sound agriculture.
The Food and Drug Administration is currently writing regulations to establish food safety standards for produce. Why is AMS proposing to establish standards that conflict with or duplicate the FDA standards, with the conventional leafy greens handlers in the drivers’ seat?
The NLGMA is a disaster waiting to happen, for farmers, consumers, the environment, and ultimately for food safety. Also see the Action Alert and Comment Form from the National Sustainable Agriculture Coalition(NSAC)
For more information on this action alert, or about NOFA/Mass Policy and Social Action, please contact Jack Kittredge, Policy Director, 978-355-2853, or firstname.lastname@example.org.