Food Safety Concerns Are Leading to Solutions
That Won’t Work for Small and Diversified Farms
by Russell Libby
Maine Organic Farmers & Gardeners Association
May 9, 2007
Our cultural picture of a sustainable farm includes a mix of animals and crops, with hayfields and pasture and, often, intensively managed vegetables. However, if regulators continue down their current path, this won’t be an option for farmers for much longer.
This document is MOFGA’s attempt to summarize the current situation surrounding “Good Agricultural Practices” and related issues, and some principles that need to be considered as we move forward. Because the situation changes rapidly, we will try to update this document regularly.
In their efforts to keep bacteria out of the food supply, the Food and Drug Administration (FDA), the US Department of Agriculture (USDA), and various other agencies, large food processors, and food buyers are on the verge of creating a system that would essentially prevent farmers from raising both livestock and crops for human consumption on the same farm, or in the same neighborhood.
In the fall of 2006 several deaths and many illnesses were traced to California spinach contaminated with E. coli 0157:H7. E. coli 0157:H7 is primarily associated with beef cows that are raised on grain instead of grass and grown in feedlots. It can also be transported, through direct contact or water or other mechanisms, and can show up on crops. In last year’s outbreak, the spinach was grown on a farm that was in transition to organic production, on land leased from a ranch that also had a beef feedlot several miles away. The irrigation water used on the spinach had the bacteria, manure from the feedlot had the bacteria, and so did wild pigs moving among the fields.
And what is the solution, according to FDA and USDA? It’s not to eliminate the bacteria from the system, because that would mean challenging the notion of feedlots and grain-fed beef. Instead, their idea is to isolate vegetable production from livestock production to eliminate cross-contamination.
Good Agricultural Practices
USDA’s effort to deal with these issues is called “Good Agricultural Practices,” or GAP. Under the current approach, in conjunction with FDA, every food processing plant will have an approved Hazard Analysis and Critical Control Points (HACCP, commonly pronounced “hass-up”) plan. For example, the McCain’s french fry plant in Easton will have a HACCP plan that includes handling practices, how the potatoes are handled all the way from the door to the package, and how temperatures are monitored and maintained all the way to the customer. Any point where product quality is at risk becomes a “critical control point.” Most large processing facilities have had versions of HACCP plans in place for the past decade.
What’s changing now is a push down the supply chain to the farmers who supply processing plants. Essentially, processors are requiring their farmer-suppliers to become certified on food safety practices. These are, under the current language, “Good Agricultural Practices.” This year, all the farmers who supply McCain’s have to be GAP-certified.
The first section of GAP certification is just common sense. People who work on farms need to follow basic standards of cleanliness, such as washing their hands before going into a field to harvest produce and after using the bathroom. These are practices that should be used in every place that handles food. The difference is that farmers will have to post signs, provide a training program for their employees, and maintain a paper trail to document that they have done all these things.
The issues become more complex in the next section, the farm assessment. To be GAP-certified, you have to score at least 80% in each area of the program. The farming practices section will be very challenging for many farms that either include both livestock and crops for human consumption, or bring manure or manure-based compost onto the farm. Some requirements, such as documenting that wild or domestic animals can’t get into the production area, are nearly impossible to comply with.
The critical questions revolve around livestock. By the USDA standard, the presence of livestock near (within 2 miles) or adjacent to (within a half mile) the farm is a major problem, and may result in a 15-point deduction. Manure management on the farm with livestock is also subject to review. Notice—all of these issues are neutral about which farm has the livestock. If your neighbor, 2 miles away, had animals and a minimally managed manure pile, your farm score would be affected. Or, if you had animals in fields that were completely segregated from your crop production rotation, you would get a deduction.
GAP requires 120 day waiting periods between manure application and crop harvest. It regulates compost much more tightly, and assesses water quality as well.
A rational assessment process would consider each of these issues and evaluate which practices are potentially risky. Under the current yes-no scoring system, it will be very difficult for farms that include both crops and livestock to pass a review. The farming practices section totals 165 points. To pass, the farmer must have at least 132 points.
Here’s an example of how this system plays out:
- Start with 165 points.
- You or your neighbors have crop production areas near or adjacent to your livestock or poultry production areas. Minus 15 points. Now you have 150.
- You don’t have a monitoring system to prevent wildlife from entering your crop production areas. Minus 5 points. Now you have 145.
- Your compost is not tested for nutrients. Minus 5 points. Now you have 140.
- Your neighbor’s manure pile isn’t contained properly. (Remember, up to 2 miles away!) Minus 10 points. Now you have 130.
- Even if you pass all the other questions, you have failed your inspection.
The guidelines have only one question about pesticide use, asking whether applicators are properly licensed. There are no questions about the amount, type, or frequency of pesticide or synthetic fertilizer applications. The FDA and USDA’s alleged “Good Agricultural Practices” are completely focused on microbial contamination to the exclusion of any other potential food safety issue, or any practice that might be considered improper or excessive.
Currently USDA is proposing that its Food Safety and Inspection Service be responsible for farm inspections. This is the unit that grades potatoes, apples, and vegetables for uniformity and cosmetic standards. USDA charges farmers $75 per hour for the inspections, and expects to visit the farm at several points during the year to see the farms at all stages of the production cycle.
The Complexity of These Changes
Why should farmers be concerned? Isn’t this certification program optional?
Yes, the program is optional, but only if you are not supplying major markets. The USDA has decided that all suppliers of the national school lunch program will have to meet HACCP standards, and that all the farmers who supply inputs for processed foods will have to meet GAP. The Department of Defense, which is the largest institutional buyer of produce in the country and the produce supplier for the school lunch program in many states, is also requiring farms to meet GAP.
Other buyers are requiring similar certification procedures. In addition, produce growers in California are enacting standards through a marketing agreement that may be even stricter than the Good Agricultural Practices strategy being used by USDA.
Some commodities have already moved forward with other parallel certification programs, such as European Good Agricultural Practices (EuroGAP), independently of USDA. The GAP program is still in its early stages. Only 122 farms in 18 states are currently certified for GAP in their farm operations, and one California-based company operates 20 of those. Farmers who have been certified under other protocols, such as the New England Good Agricultural Practices, established between 2000 and 2004, may have to change to reflect new, more restrictive standards.
Farmers as Processors
One side issue that may become more important is the question of when, by FDA standards, a farm becomes a processor, and therefore has to have a HACCP plan that covers all its processing activities. The latest FDA guidelines, issued March 12, 2007, suggest that any activity that involves cutting of leafy greens is included within their “Final Guidance For Safe Production of Fresh-Cut Fruits And Vegetables.” This means any business preparing fresh-cut greens for market would be subject to FDA oversight. The FDA estimates that only 250 businesses nationwide would be subject to the regulations. MOFGA believes that at least that many farms in Maine are harvesting leafy greens and supplying them to consumers, and that most of those farms would be subject to a strict interpretation of the Guidelines.
MOFGA and its farmers support appropriate food safety guidelines and practices. However, the process of establishing these guidelines and turning them into standards that must be met to enter certain markets has been a purely technical one, and has not included organic or diversified farms as part of the discussion.
Neither the FDA nor the USDA uses these guidelines or the certification process to address root causes of this specific E. coli problem. The bacteria E. coli 0157:H7 is most often traced to contamination from manure produced in large feedlots. Additionally, the program asks only whether farmers have a license to spray pesticides, not about what kinds of pesticides farmers are spraying or how often.
If we’re going to have a food safety certification program, we should have one that addresses all aspects of the problem, not just one.
At its April 2007 meeting, the MOFGA Board of Directors voted unanimously to oppose any version of USDA’s Good Agricultural Practices Guidelines that does not integrate crop and livestock agriculture or maintain the viability of small farms within the agricultural system.
The Maine Department of Agriculture plans to use its Quality Assurance staff to inspect farmers for compliance with the current USDA GAP standards. University of Maine Cooperative Extension is working with potato farmers who supply McCain’s to help them prepare for GAP inspections this summer.
MOFGA intends to work actively with its farmer members to be sure they are both aware of the standards and able to meet appropriate food safety practices. MOFGA will send a series of updates on these issues to all of its constituents and will communicate with government agencies at all levels about our concerns with current interpretations of both the guidelines and what constitute “Good Agricultural Practices.”
At the national level, organic farmers need to be aware of this issue and engage in the discussions about what constitute “Good Agriculture Practices.”
For more information, please contact Russell Libby at MOFGA: by email at firstname.lastname@example.org; by phone at 207-568-4142; or by post at PO Box 170, Unity, ME 04988.
1. USDA’s implementation of FDA’s guidelines
This section includes all the ratings sheets USDA inspectors use to assess farmers for compliance with Good Agricultural Practices.
2. FDA Issues Final Guidance For Safe Production of Fresh-Cut Fruits And Vegetables, 03.12.07
3. [Federal Register: March 13, 2007 (Volume 72, Number 48)]
[Notices] [Page 11364-11368]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration
[Docket No. 2006D-0079]
Draft Final Guidance for Industry: Guide to Minimize Food Safety Hazards for Fresh-Cut Fruits and Vegetables; Availability; Agency Information Collection Activities; Submission for Office of Management and Budget Review; Comment Request
AGENCY: Food and Drug Administration, HHS.
4. FDA Food Safety Fact Sheet, 03.12.07
5. The California Market Order Proposal/Western Growers’ Proposal
6. The Organic Center’s Response to the Western Growers’ Proposal, March 2007
7. California Certified Organic Farmers on this issue
8. The Organic Center’s latest summary on E. coli 0157 and its relationship to livestock feeding practices
9. University of Maine Cooperative Extension’s guidance for farmers on how to comply with USDA’s Good Agricultural Practices (ref. 1):
This article is provided by the Maine Organic Farmers and Gardeners Association (MOFGA), PO Box 170, Unity, ME 04988; 207-568-4142; email@example.com; www.mofga.org. Joining MOFGA helps support and promote organic farming and gardening in Maine and helps Maine consumers enjoy more healthful, Maine-grown food. Copyright 2007 by the Maine Organic Farmers and Gardeners Association.