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Testimony of Russell Libby
Executive Director
Maine Organic Farmers & Gardeners Association

Before The Subcommittee on Nutrition and Horticulture
Agriculture Committee
U.S. House of Representatives

May 8, 2012

“Small Changes Make Big Differences on the Ground”

Good morning Chairwoman Schmidt and Honorable Members of the House Agriculture Committee. I am Russell Libby, Executive Director of the Maine Organic Farmers and Gardeners Association, or MOFGA. MOFGA is the largest state level organic organization in the country, with about 6500 member farms, businesses, and households. Formed in 1971, we started the country’s first state organic certification program in 1972 and an apprenticeship program to match new farmers with experienced teachers in 1975, and hired the first organic ‘extension agent’ in 1986. We now have 26 employees who work on services to farmers, education, and outreach to the general public.

MOFGA’s annual harvest celebration, the Common Ground Country Fair, draws 60,000 people each September to Unity, Maine, a town of 2400, making it the country’s largest organic food event. We also run a highly successful new farmer training program. Of the 140 program participants over the past 12 years, 87% are currently farming. Our USDA-accredited organic certification program includes about 5% of the farms in Maine, and about 20% of the dairy farmers.

MOFGA has been in business for 40 years, and in that time, we have witnessed tremendous growth in organic agriculture and in the opportunity for farmers to rebuild local economies through food production. Our farmers have built a robust direct-to-consumer marketing movement in Maine, with close to 150 farmers’ markets and several hundred farmers offering Community-Supported Agriculture programs that supply about 2% of the families in Maine with produce, summer and sometimes winter, and an increasing array of products. With a number of small investments and no-cost policy changes, the 2012 Farm Bill can facilitate this growth and opportunity.

We are a member of the National Organic Coalition, and work closely with the National Sustainable Agriculture Coalition, so our Farm Bill priorities reflect theirs in many ways.

Horticulture Title:

The Horticulture title of the Farm Bill is critically important for organic farmers. The National Organic Program does an increasingly good job of working through issues that confront organic food producers and processors around the country. The Specialty Crop Grants program is a long-overdue recognition of the needs of fruit and vegetable farmers from around the country.

Our suggestions:

  1. Fund national organic certification cost-share at the level included in the Senate farm bill voted out of Committee. Organic agriculture is a strong and growing sector of American agriculture, and organic certification cost-share is an investment in business development for agriculture. Many organic farmers rely on the cost-share program to help them access markets (retailers, specialty food processors). The program also enables farmers to remain in the organic market by offsetting annual certification costs for farmers. Organic producers must meet strict organic standards to be certified, and the costs of certification are going up. As the requirements for the National Organic Program become more strictly defined, the time farmers spend in recordkeeping and compliance increases substantially. Without national organic certification cost-share, farmers here at home will opt not to certify, and organic companies will have to source organic product from overseas instead of from American farmers to meet strong consumer demand.
  2. Encourage more organic farmer participation in critical conservation programs. The 2008 Farm Bill included important provisions in Environmental Quality Incentives Program (EQIP) and the Conservation Stewardship Program (CSP) for organic farmers in recognition of the historical lack of participation and conservation benefits of these systems. However, both programs are in need of reform to address the unique needs of organic farming systems. Issues such as the unfamiliarity of NRCS staff with organic systems, overlapping planning requirements with the National Organic Program, and lack of adequate planning assistance should be addressed in the next Farm Bill. By the way, one of the places that we’ve been very successful in the past few years is getting our new young farmers to participate in NRCS programs, which helps to strengthen the base for that agency long into the future.
  3. Help the National Organic Program (NOP) to be more effective. The National Organic Program enforces the national organic standards, accredits certifiers, develops equivalency agreements, handles complaints – in essence, NOP ensures the integrity of the organic seal. These are essential functions to the survival and growth of the organic sector. Additionally, the program requires a capital investment in innovative technologies that will position the program to be able to grow with the organic sector, providing domestic and international oversight, and transparency and streamlining of systems, data, and information. NOP should receive a one-time infusion of $5 million in mandatory funds for the technology upgrade, and then should be authorized to receive appropriations increasing at a rate of 20 percent annually beginning with $10 million in FY 2013.

Nutrition Title:

When things work right, the full range of USDA programs make a significant difference to farmers and the general public. Linking nutrition programs to access at farmers’ markets, expanding EBT programs, developing more opportunities for farmers to supply the school lunch program—all of these things make farmers more profitable.
The largest programs within the Farm Bill are embedded in the Nutrition Title. If farmers are not able to provide food through programs in the Nutrition Title for the people who need it the most, they are shut out of a major income stream. If the people who are eligible for nutrition assistance do not have access to fresh, local produce, they may not get the full nutritional benefits from the assistance they receive. Connecting farmers with consumers who participate in nutrition assistance can benefit producers and consumers.

How can you help this to happen?

  1. Make it easier for farmers to access EBT programs. The range of marketing options has widened dramatically over the past decade, with farmers’ markets, CSAs, farmstands, buying clubs and other options. Please amend Section 7(h) of the Food and Nutrition Act of 2008 to treat wireless retail food vendors as fixed locations stores are now treated.
  2. Increase the ability of school lunch programs to source directly from farmers who meet their standards by:
    1. Allowing flexibility in schools. Rather than requiring produce purchases through the DOD Fresh program, allow schools the option to use their DOD credit to purchase food directly from local farmers. (Requires amending Department of Defense (DoD) Fresh program in Section 10603(b) of the Farm Security and Rural Investment Act of 2002.
    2. Similarly, allow schools to use 15% of their ‘commodity’ dollars to purchase locally available foods that in turn help to support their communities. This addresses a key tension in many rural communities. Farmers support their schools through property taxes, and in turn would like their schools to be able to support them through purchases.

Other programs important to the whole.

Farmers’ Market and Local Food Promotion Program. As interest in direct markets grows, farmers innovate to supply more. The expanded Farmers’ Market Promotion Program continues to serve direct marketers, but also includes those farm businesses that are trying to develop farm to institution and food hub opportunities across the country. It deserves more funding: the $30 million proposed in the Local Foods, Farms and Jobs Act will only scratch the surface of the current interest. Every new market opened or expanded through the program provides more jobs and keeps money circulating in the many participating communities.

Seeds and breeds. I understand that the prevailing worldview is that the solutions for the future revolve around biotechnology, but I want to say a few words in favor of all-purpose, traditional breeding. In the late 1800’s, farmers in my part of western Kennebec County, Maine, were deeply engaged in the refinement of the Hereford as a cattle breed suitable for the U.S. The dry bean varieties that work in our humid Northeast climate were selected over long stretches of time by farmers, and then further refined by plant breeders at public universities. Even now farmers in New England benefit from plant breeding done at the University of New Hampshire by Brent Loy, who has developed melons and pumpkins that thrive in the Northeast. In our rush to the cellular approach, I hope we don’t lose sight of the value of traditional plant breeding. The Seeds and Breeds provisions of the last Farm Bill were a good starting point, but we need the public plant breeders and the long-term commitment to make those varieties available.

Expanding Economic Opportunities

In conclusion, markets for farmers are changing rapidly. There are thousands of new farmers’ markets around the country and Community Supported Agriculture programs (CSAs) are also rising in number. In Maine, the number of farmers’ markets has grown tenfold in the past 30 years, and CSAs now supply about two percent of Maine families. While this growth in direct producer-to-consumer marketing it exciting, there is a nearly untapped marketing opportunity at the wholesale, retail, and institutional level of sales. Through your actions with the Farm Bill as I have outlined above, you can give this stage of marketing the jumpstart it needs. This larger scale represents the bulk volume of food sales, and it is in this area that the next generation of farmers is working to make inroads. With your help, small changes can truly make big differences on the ground.

Thank you. I would be happy to answer questions.

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An Integrated Approach to Food Safety
Russell Libby, Executive Director, Maine Organic Farmers and Gardeners Association
March 19, 2009

The repeated failures of our food system to provide safe food to all are pushing Legislative and policy changes on food safety. President Obama focused on this issue in his March 14th radio address. Multiple bills are already before Congress. Every week there are news stories detailing past and present problems in situations as diverse as spinach, peanuts, melanin in dairy products, almonds and antibiotic resistance in pork.

Small farmers are already skeptical of USDA’s direction on many of these issues, particularly because the National Animal ID System is being imposed without addressing any of the many equity and ethical considerations that are being raised by farmers across the country. USDA’s Good Agricultural Practices protocol focuses on microbial issues, ignores pesticide use, and discourages diversified farms. Similarly, the Food and Drug Administration has shown a marked inability to find solutions that work for small farmers without expensive and product-changing technology (e.g., juice regulations that drove out most apple cider producers; proposed leafy green protocols that would require high cost testing of each batch of greens.)

Small farmers, fishermen, and food processors are often left out of the policy discussions that try to fix these large-scale national problems. These working principles are intended to provide a framework for the ongoing policy debate from the perspective of an organization that represents organic farmers and gardeners, food processors, food retailers, and thousands of families who are committed to buying local, organic food.

A. Working principles:

1. Focus first on the big problems. From our perspective, many of the food safety incidents of the past decade are closely related to the increased concentration in our food production system. When a problem in one storage facility or processing plant or one field can impact eaters in dozens of states simultaneously, the bulk of the regulatory and enforcement focus should also be directed to these same large facilities. In livestock, concentrated animal feeding operations (CAFO’s) and confinement hog production, widespread antibiotic use in livestock and the increased concentration of livestock processing are all contributing to a series of ecological and health issues. The discussions also tend to ignore anything but biological food safety issues; FDA’s food monitoring data continue to show pesticide residues from DDT and organophosphates at low levels, but it is generally ignored as an enforcement priority. (http://www.cfsan.fda.gov/~dms/pes06rep.html#appa-06)

2. Fairness and Flexibility. Enacting laws or regulations that work for large farms but can’t be met by small farmers is fundamentally wrong. For example, the California Leafy Greens protocol suggests that each batch of greens be subjected to a laboratory test. That may be appropriate for fields of 100 acres harvested over a few days, but doesn’t work for a salad green bed of 2000 square feet.  MOFGA and other small farm groups have been working on a food safety approach that is: a) focused on each farm identifying and monitoring potential problems (similar to Hazard Analysis and Critical Control Points (HACCP) principles), b) appropriate for the market being supplied, and c) tied to existing farm plans. Mandating only one solution (e.g., USDA’s Good Agricultural Practices) limits possibilities for small farmers.

3. Enforce existing food safety laws first before considering reorganization. The Food and Drug Administration and the Department of Agriculture, along with other Federal agencies, already have a wide range of authority and power. Right now neither agency has the capacity (in terms of staffing and coverage) to cover current statutory mandates. If year after year FDA is unable to meet existing inspection protocols, they are unlikely to be able to assume additional responsibilities. Whether food safety continues to be a program within the Food and Drug Administration or it becomes a separate Food Safety Administration is largely a management issue that doesn’t address capacity issues.

B. How organic farms already address some key food safety and food quality issues:
Within the National Organic Program law and regulations are a series of requirements that address some key food safety concerns:

1. There is no use of raw manure on vegetable crops without an extended waiting period between manure application and harvest of the crop.

2. Compost that contains livestock manures has to meet temperature, mixing and time requirements or else the product is treated like unprocessed manure.

3. There is no routine use of antibiotics within either livestock feed or livestock health programs. (Animals may be treated to ensure health, but neither the animals nor their products may then be sold as organic.)

4. There is no use of synthetic pesticides. Their use is not generally considered in food safety protocols like USDA’s Good Agricultural Practices checklist.

5. Organic farmers are required to maintain records that allow “one up, one down” traceability. They have to keep records of the sources of inputs, be able to track activities on their farm to the relevant fields/livestock, and then maintain records of sales that are detailed enough to allow full accountability.

C. Concerns about Current Legislative Proposals in Congress

The various pieces of Federal legislation that have been introduced to change and revise food safety systems are meeting a large amount of skepticism and initial opposition. We think that solutions based on the principles above have more of a chance to build broad political support than proposals that don’t allow various pathways to the same result—a safe and healthy food system.

One major concern for MOFGA is that current bills before Congress seem to ignore the perspective of farmers who are primarily supplying markets where the buyer and the farmer know one another. Among these bills are:

S425, Sen. Sherrod Brown, which focuses on traceability (including livestock identification);

HR 759, Rep. John Dingell, FDA Globalization Act of 2009, which thoroughly updates (and expands) FDA’s authority on a wide range of food and drug issues, and mandates electronic trace-back systems;

HR 814, Rep. Diana DeGette, TRACE Act, which would require systems to trace all foods at all stages, including livestock, meat, poultry, eggs and egg products;

HR 875, Rep. Rosa DeLauro, Food Safety Modernization Act, which would establish a new Food Safety Administration, separate from FDA. Farms would be required to maintain more detailed records and use “good practice standards”.

All of these bills are in the discussion stage and will progress along with the rest of the Congressional agenda. MOFGA believes that the only way to ensure food safety is to work within the principles outlined above.

D. A few related thoughts:

1. MOFGA’s perspective on why we need to be cautious about the GAP approach to food safety:

2. MOFGA Board statement in opposition to the NAIS:

3. A summary of MOFGA’s HACCP-based approach to small farm food safety will be available late in March, 2009.

For more information:

Russell Libby, Executive Director, rlibby@mofga.org, 207-568-4142

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