Food-safety rules a threat to small New England farms

By GARY GEMME

Daily Hampshire Gazette

Monday, August 19, 2013
(Published in print: Tuesday, August 20, 2013)

WHATELY — As a vegetable grower in the Connecticut River valley, I have been involved in a customer-required food safety audit program on my farm for the past three years. The stringent record-keeping requirements of this program, while bringing attention to food safety issues, have become an undue burden, as we are now required to maintain daily documentation on all required aspects of compliance.

This now takes about four hours a day. Presently, the U.S. Food and Drug Administration is proposing the Food Safety Modernization Act, which will affect all full-time farmers in the country with even more complex regulations and record-keeping.

These new regulations would force even small-scale growers such as myself to expend very limited financial and labor resources (in many cases beyond their means) in order to comply with the program. (A program Thursday in Hadley will explore the rules; see story, Page B1.)

The FDA’s proposal does not take into account the lower food safely risks inherent in small farm operations, and they plan to base a farm’s inclusion in the program in part on annual sales figures. By the FDA’s own estimate, a farm my size (100 acres) can expect to pay about $30,000 per year to comply with the regulations. This task will necessitate at least one full-time employee to implement the program. That and the related expenses needed to satisfy the regulations will consume a huge chunk of our average annual profit.

The FDA admits that implementing this act will likely put some small farmers out of business. I believe they are correct in that assessment. It might be an understatement.

I’d like to offer my definition of a small farm. In my view, based on 39 years of growing commercially, a small farm is of a size that allows the farmer the ability to closely inspect all of its crops in a given day. Secondly, the farmer manages all aspects of the production operation and works directly with the labor force in the harvest and post-harvest processes, as well as the sales and shipping of the produce. This describes most farms in New England.

The FDA defines a farm’s need to comply with the act by annual sales, but the government’s sense of which farms are in need of compliance to the regulations are way off the mark. Farms conforming to my definition of a small farm have been involved in virtually no food-borne illness issues. Annual sales are related to the value of what is grown as well as the production per acre (read “skill and ambition of the farmer”).

It’s very common for a small farm to have annual sales well in excess of $1 million — and this does not mean that the farmer is a likely candidate to make people sick.

No one disputes that something needs to be done about the troubling increase in incidents of food poisoning originating from tainted fruits and vegetables. Food should not make us sick. The reaction by groups writing food safety regulations, however, is excessive and all proposals put forth in effect throw the baby (that is, the small farms) out with the bath water.

Almost all proposed regulations have been written with strong input from the largest farms and produce wholesalers, with little regard for or understanding of small farms. Centers For Disease Control statistics show that the majority of food-borne illnesses due to contaminated produce can be traced to large farming operations, to imported products and, most importantly, to improper handling in the food service industry — not to small, carefully managed farms.

Small farms have a small voice, and most small farmers have been shy to speak up for fear of appearing to be mistakenly perceived as against food safety. In reality, it will take very minor tweaking to bring the small farm industry where it needs to be in order to be safe.

There is no food safety issue on our small farms here in New England. Richard Bonano, a vegetable specialist at the University of Massachusetts Extension, recently wondered how we would measure the success of implementing a major food safety program on New England farms, given that there is no problem in the first place.

Small farms are a part of the solution much more than they are a part of the problem. Now, small farmers need the public’s help to dodge this absurd bullet, to be able to continue to provide an income for themselves and to give the community safe and wholesome locally grown food.

People can learn more about this issue, and where to send comments, by going to the Massachusetts Farm Bureau Federation’s website at mfbf.net and reading about the Food Safety Modernization Act.

Gary Gemme runs Harvest Farm in Whately.