If we hadn't
broken my crystal ball, we would be reading in it about the added
record keeping that lies in our future as vegetable and fruit farmers.
That's if we are lucky, stick together and can build solid support from
our customers and all the members of the public who are excited about
family-scale local farms. If not, some of us may decide to close shop.
Agricultural Practices (GAPS) - that sounds innocent enough. The
danger lurks in who defines them and whether the rules and regulations
fit farms of various sizes and processing on differing scales.
Ignorance about microorganisms is so generously spread amongst the
public at large that it is easy for people to panic and out of fear
vote for legislation or regulations that sound safe, though may
actually increase the spread of pathogens and make life a dreary round
of form filling for farmers. Many shoppers, attracted by the
convenience of bagged salad greens, reason that the bag provides a
barrier to contamination. In fact, just the opposite is true. As Wild
Farm Alliance (WFA) director Jo Ann Baumgartner told conferees at the
November 2008 "Food Safety War on Wildlife Teach-In," "the bag itself
is a micro-incubator: many cut leaf surfaces increase areas of
infection, and the washing of thousands of pounds of greens at a time
can spread pathogens to scores of consumers."
In the fall of
2008, the Food and Drug Administration (FDA) posted a notice requesting
public comment on its "Guide to Minimize Microbial Food Safety Hazards
for Fresh Fruits and Vegetables," including "possible measures that FDA
could implement that would enhance the safety of fresh produce." If we
do not pay close attention, public alarm over bagged greens and
contaminated peanut butter could lead to mandatory regulations aimed at
sanitizing our farms.
A little history In the fall of 2006
several deaths and many illnesses were traced to California spinach
contaminated with E. coli 0157:H7. Primarily associated with beef cows
that are raised on grain instead of grass and confined for months to
feedlots before they are slaughtered, E. coli 0157:H7 can also be
transported by feral pigs, water or wind and show up on crops. The
Community Alliance with Family Farmers (CAFF) analyzed FDA data from
1999 - 2006 and found that there were 12 outbreaks of E.coli 0157:H7
traced to California leafy greens resulting in 539 reported illnesses.
Of those 12 outbreaks, 10 were from fresh-cut, processed and bagged
leafy greens and those 10 outbreaks accounted for 531 of the illnesses.
In the 2006 outbreak, the spinach was grown on a farm that was in
transition to organic production, on land leased from a cattle ranch.
Upon investigation, it was found that the irrigation water used on the
spinach had the bacteria, cattle manure from the nearby ranch had the
bacteria, and so did feral pig feces found a mile away from the
fields. Did federal or state regulators take steps to clean up the
beef operation or to clamp down on the fresh-cut system to eliminate
the bacteria? You know the answer. Instead, the packers who buy and
ship the bagged greens devised the "California Leafy Green Marketing
Agreement" (LGMA), a 50-page set of "voluntary" regulations that
growers would have to meet if they wanted to sell to the packers.
Additionally, individual shippers and buyers have established
supermetrics that go beyond the LGMA that encourage farmers to poison
and fence out wildlife, and put in up to 450 feet of sterile ground
buffers between crops and habitat. As Steve Gilman puts it in the
latest issue of The Natural Farmer, "from an ecological perspective,
let alone an organic farming one, the GAPS matrix outlined in the
handlers' 2007 Marketing Agreement was an environmental disaster."
(www.nofa.org) UC Davis researchers have shown that grasses and
wetlands can filter up to 99% of pathogens from water.
PowerPoint put together by WFA (www.wildfarmalliance.org) presents
images that are reminiscent of Stalag 13: high-tech fencing and
ground-level barriers, closely spaced "rodent bait/trap stations" atop
berms at the edges of cultivated fields, and instances of outright
removal of tree lines, hedgerows, and farm ponds. Remarkably, there is
no evidence that frogs or deer vector the E.coli. In a few states, 1 -
2% of deer have tested positive for pathogenic E.coli, but since these
numbers are so small, removing habitat that protects water quality is
unwise. When it comes to soiling the soil, wildlife can't remotely
compete with domesticated herds housed in the ag-equivalent of
concentration camps. Yet even some highly respected consumer
organizations are beating the drums for imposing the LGMA on all
produce farmers whether they sell millions of pounds of bagged salad
mixes or a few hundred heads of lettuce at a farmers market stand.
in the 1990s, after an earlier wave of food borne illnesses, the
Cornell Cooperative Extension began offering training materials for
farmers and farmworkers teaching sensible farm safety practices. The
National GAPS Program is currently based at Cornell and the
www.GAPS.cornell.edu website offers a guide to writing your own farm
safety plan and a DVD for worker training. USDA added grading to the
Cornell guidelines, turning them into a certification system. Some
state departments of agriculture are conducting GAPS audits under USDA
accreditation. Most states also allow private third party verification
programs that can be very expensive. While these programs are all
still "voluntary," some wholesalers and retail chains are requiring
GAPS certification for farms that want to sell to them, as are school
The recent peanut butter fiasco is attracting
public attention to the totally inadequate and uncoordinated hodgepodge
of federal regulations. USDA and FDA both have jurisdiction over
various aspects of food safety, yet neither agency has authority to
require recalls of tainted product. The number of inspectors and
inspections is pitiful, leaving industry to regulate itself. In a
fever to do something, legislators are proposing new laws; some would
set up traceability schemes, others address the structure of FDA and
USDA in more or less prescriptive terms. Tune in later this spring
when a top runner emerges.
To the rescue comes the Leafy Greens
Working Group, a loose coalition headed by NOFA and MOFGA, including
farming organizations down the East Coast, the Virginia Biological
Farmers Association, Carolina Farm Stewardship and Florida Organic
Growers. The National Organic Coalition (NOC) and the National
Sustainable Agriculture Coalition (NSAC) are lending their networks to
this effort. The Leafy Greeners agree that small-scale farms must take
the bull by the horns and address the food safety issue actively and
publicly. MOFGA has contracted with Jim Ostergard, well-known food
safety expert, to design a do-it-yourself guide to creating your own
plan for your farm based on Hazard Analysis Critical Control Point
(HACCP) principles. Prospects look good for combining safety
inspections with the audits that certified organic farms already
undergo. At the same time, the Leafy Greeners are planning a campaign
to ensure that any federal regulations that are passed will be scale
and product appropriate, based on genuine risks and solid science.
They are doing a literature review to see what research has been done
and what is missing. On the West Coast, the Community Alliance with
Family Farmers (CAFF) has created a set of GAPS for small and
medium-sized fruit and vegetable growers that includes a section on the
relative risks of animal presence and conservation concerns. Please
stay tuned for action alerts!
A pro-active response As market
farmers, if we do not want harsh regulations imposed on us, we must
demonstrate to the public that we have the situation well in hand. What can we do on our own farms to ensure the safety of our products? Common sense will give us most of the answers.
Field preparation Do
not use fresh manure to fertilize soils where you plan to grow
vegetables or herbs that touch the soil or that can be reached by
splashing. Organic standards require that 120 days separate
incorporation of manures from the planting of such crops. There is a
lot of research that shows that a living soil with a diversity of
microorganisms reduces the likelihood that pathogens from manures will
survive incorporation in the soil. Thorough composting of manures will
eliminate most pathogens, though careless composting will not. Allow
12 months to go by before using land that has been grazed for growing
Irrigation Test irrigation water for
coliform bacteria. Deep well water is likely to be safer than surface
water, ponds or streams. If farms upstream from you are using
pesticides, herbicides and chemical fertilizers, chances are good that
the water will be polluted by those materials. If there is a feed lot
or Confined Animal Feeding Operation (CAFO) upstream, you should
probably dig a well. City or village water may be chlorinated.
Picking and packing Make
sure that everyone involved in picking and packing is trained in food
safety procedures. Use clean harvesting equipment - knives, mechanical
devices and containers. Harvesters should have clean hands and should
not pick, wash or pack produce if they have contagious illnesses.
After eating, smoking, blowing their noses or going to the bathroom,
harvesters should wash their hands carefully and dry them well and the
bathroom should be kept clean. Keep the wash up area clean and use
potable water for washing produce and for cleaning the surfaces in the
packing shed that come in contact with the produce. NYS regulations
require regular testing of wash water for coliform bacteria. Hydrogen
peroxide, vinegar or peroxyacetic acid (PAA) are alternatives to
chlorine. Organic standards allow the use of chlorine as long as
"residual chlorine levels in the water do not exceed the maximum
residual disinfectant limit under the Safe Drinking Water Act"
(205.605). The standards do not specify how much chlorine to put in the
wash water, only what can remain after washing. Keep in mind that the
pH of chlorine used for sanitation purposes must be carefully
controlled since it is ineffective if the pH is too low or too high.
Exposure to organic materials also reduces the effectiveness of
chlorine, which can combine with organic matter to form toxic compounds
such as trichloromethane. Personally, I do not think we should use
chlorine in our packing sheds.
Communication If your
farm is certified organic, let your customers know that certification
restricts the use of fresh manure, and requires potable water for
washing produce and an audit trail that makes it possible to trace each
head of lettuce back to the bed where it was grown. If fear of
paperwork has kept you from certifying, this may be the moment to
reconsider or to develop a paper trail of your own that documents your
care with the produce you sell. Certified or not, tell your customers
about your safety practices and enlist their support in fending off
excess regulation. While making sure our farms are not incubators
for pathogens, we should take every occasion to suggest a broader, more
integrated understanding of food safety beyond microbial contamination.
A safe food system includes considerations of food quality, nutrition
and freshness, the risk of hunger, the safety of the people who work in
the food system, and the health of the environment. Fresh, local food
provides health insurance, instead of medical insurance. Truly safe
food: ·builds body health and strengthens the immune system
·is produced non-destructively, without poisoning soil, water or air
·provides safe and fairly paid work for producers all along the food chain from the field to the table
·and is accessible to all people at a price they can afford to pay.
Bradigan Spula, a lifelong resident of New York State and the Eastern
Great Lakes bioregion, is a Rochester-based environmental and
agricultural writer, poet, musician and activist. Elizabeth
Henderson farms at Peacework Farm in Wayne County, NY, producing food
for the Genesee Valley Organic CSA, in its 21st year in 2009. She is
the author of Sharing the Harvest: A Citizen's Guide to Community
Supported Agriculture (Chelsea Green, 2007)