For those who care about local foods and small farms, please submit comments to the FDA by November 15th on the new Food Safety Modernization Act (FSMA). Signed into law by President Obama in January of 2011, the FDA has taken more than two years to move FSMA through its rule-making procedure—a process still ongoing. The FDA hails FSMA as the most “sweeping reform of food safety laws in over 70 years.” An undeniably important objective given the attention-grabbing headlines announcing outbreaks of foodborne illness from hamburgers, chicken, fruits and vegetables, FSMA unfortunately undermines some of the safest producers of food in the nation—our local farmers.
The "sweeping" law risks sweeping the little guy right out of business. Designed to cover the disparate extremes of industrial farming and neighborhood farm stands, FSMA's one size fits all is a disaster in the making. The voluminous 548 page law is confusing. On the surface it appears that farms grossing less than $500,000 would be exempt from the law, but on closer examination, many farms would indeed have to comply with the expensive and cumbersome rules. How many? Neither the state agriculture department nor the FDA can answer that definitively, but based on USDA numbers and income criteria likely hundreds of Vermont farms will be affected.
At an FDA "listening session" held last month, farmers from Vermont and New Hampshire gave FDA representatives an almost universally unfavorable earful. Themes repeated throughout the morning were: the proposed law was overly cumbersome to struggling small farms; the majority of food borne illness outbreaks come from imported foods and large scale industrial food companies, not small, diversified farms in New England; criteria for the new law is not supposed to be in conflict with organic standards, but it is; and FSMA seems to duplicate laws that many farms already comply with like the USDA’s Good Agricultural Practices (GAP) program. Across the board, farmers felt the proposed law would put onerous requirements on them, consume their already tiny profit margins, hamper growth, and force many of them out of business.
Over the course of the session, many farmers expressed their frustration at the inconsistencies and double standards in federal food safety policy. The FDA admits it is able to inspect only about 2% of imported food even though imported food has repeatedly been implicated in food borne illness outbreaks. While the government plans to impose increasingly cumbersome regulations on small produce farms, they are simultaneously relaxing and changing laws that will deleteriously affect food safety. Recently the USDA announced that it will allow U.S. grown chicken to be processed in China for resale in the United States, without any USDA inspectors on site. The processed chicken, used in canned soups, chicken nuggets and other products, will be sold
Earlier in 2013, in an effort to save money for the government and the poultry industry, the USDA announced plans to cut back the inspectors at slaughterhouse kill-lines by 75%, leaving only one inspector where there used to be four, while increasing the numbers of chickens killed to 175 per minute. USDA Secretary Vilsack believes that this will reduce thousands of foodborne illnesses, even though the Environmental Working Group’s report, Superbugs Invade American Supermarkets, exposes that antibiotic resistant bacteria is found in 81% of ground turkey; 69% of pork chops; 55% of ground beef; and 39% of chicken breasts, wings and thighs. No worries. Under the new USDA rules, chicken carcasses will be doused in chlorinated water and “other antimicrobial substances” to deal with lingering fecal matter and other contaminants.
The numbers of food borne illnesses used to justify FSMA are high. While quoted in the press as hard numbers they are, in fact, only estimates. These numbers were announced by the CDC a month before Obama signed FSMA into law and are almost 2000 times the rate of illness and 150 times the rate of death that were documented between 1998 and 2008. In Vermont, cases of food borne illnesses are low—about 250 statewide in 2012—although relative to population they hover around what the Vermont Department of Health cites as the national averages for reported cases in 2011 of 14.3 to 16.5 per 100,000. Over the past almost twenty years, the number of cases in Vermont have stayed relatively consistent. The Department’s most recent report on foodborne illness, dated May 2013, explains that Vermont’s cases are mostly “sporadic”—i.e. they are not connected.
While the Vermont Department of Health (DOH) agrees with the CDC that underreporting is a problem, State epidemiologist and foodborne illness expert, Erica Berl is quick to say that the DOH does not want every single person who is experiencing diarrhea or vomiting to report to the state. Berl says there are many reasons for these common symptoms of foodborne illness but, “most cases of GI illnesses are from viruses passed from human to human.”
When asked if she thought foodborne illness in Vermont could be traced to small local farms she replied, “Causation is very difficult to prove and often near impossible with the small numbers in Vermont. It is impossible to state that food borne illness does or does not ever come from small farms. What we know, capital K, is that there are certain high-risk foods linked to certain pathogens.”
In short, there is no way to prove that any small farms in Vermont have caused any foodborne illness in the state. But, there is also no way to prove they haven’t.
While the state may not be able to say unequivocally that small farms are not the cause of foodborne illness, the farmers made it very clear at the FDA session that they do not believe they are to blame for outbreaks in the state. Repeatedly farmers said, “My family and I eat the food we are growing and selling. We would be the first to get sick if there were a problem.” Others commented that since they know their customers, they would be aware if someone got sick.
Some farmers expressed their fear that as small farms are forced out of business that foodborne illness will increase not decrease. The question begs, does trying to reduce the 200 some odd annual cases of foodborne illness which can not be definitively linked to Vermont’s small farms justify the enormous health and economic impact of FSMA throughout the state? If society’s goal is to keep reducing or trying to reduce the percentages of people who are sick then maybe the small farms of Vermont should be viewed as part of the healthy solution and goal, not as the culprits. It raises the need for an examination of health and what is considered relevant to food safety. Acute illness is dramatic and headline grabbing, but debilitating chronic illness is often far more damaging in the long run. Is diabetes a food safety issue? Are allergies a food safety issue? Chronic digestive diseases?
There is a reason Vermont has, per capita, the most farmer’s markets, certified organic farms, certified organic farm land, CSAs, local dollars spent on local foods, artisan cheese-makers, micro-breweries, and maple producers in the entire country. We love our local food producers, we care about our health and we are proud of Vermont’s agricultural heritage.
Champion real food safety and security. Let FSMA fulfill its mandate by regulating those producing contaminated food, not those providing healthy food. Let the FDA know that you support Vermont local farms and local oversight. Tell the FDA that farms grossing less than $1 million should be regulated locally, by the Vermont Department of Agriculture, not the federal government. Keep Vermont’s farmers in business and keep our food healthy. Send your comments to the FDA by November 15th 2013.
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