On October 15th, Co-op Outreach Coordinator, Torey Ligon testified before a USDA panel in opposition to a proposed new set of food safety protocols for leafy greens.
Read about the trial in an article on Southwest Farm Press (an industry trade magazine):
Read The Organic Consumer Association’s position:
Read Ligon’s recap in the Co-op’s monthly newsletter:
By Torey Ligon
In October, I spent a day in Yuma, Arizona. In spite of the endless rows of lettuce and citrus trees, the strip malls, and the heat, my trip was quite interesting. I drove to Yuma to testify before a USDA panel about a proposed new national food safety standard for producers of leafy greens (a category that includes lettuce, spinach, arugula, cabbage, cilantro, kale, chard and more).
The proposal the USDA is considering, known as the National Leafy Greens Marketing Agreement, is based on standards that were voluntarily adopted by large growers of leafy greens in California and Arizona after the e-coli outbreak in spinach in 2006. To counter concerns from retailers and restaurants that leafy greens were unsafe, these growers established a series of metrics designed to provide some guarantee about the safety of their products. The new protocols included things like mandatory testing of soil and water between harvests, and buffer zones surrounding all crops. For large growers, these new standards were fairly easy to adopt and the cost of adoption could be spread over a large volume of product sales. It can also be argued that these standards did make conventionally grown, nationally distributed leafy greens safer.
While nearly everyone can agree that improving food safety for consumers is a worthwhile goal, there is disagreement about how these improvements should be approached. The proposal currently being considered by the USDA left me with some serious concerns. My primary objection to the proposal is that it does not adequately safeguard small farmers from onerous food safety protocols designed for large growing operations. Some of the current metrics being used in California also seem to be at odds with established organic farming techniques. The two metrics sited above, for example, are definitely geared toward large growers of conventional crops. For a farmer growing 1,000 acres of lettuce during the winter who then lets his fields lay fallow during the summer, soil and water testing between harvests is manageable. For a farmer practicing crop rotation on a small 30 acre field, harvests may be ongoing throughout the year, making testing between each harvest both time consumer and expensive. In addition, that small farmer is likely to plant several crops together or in close proximity to each other to take advantage of the beneficial insects and soil nutrients that one plant offers to another. Adding buffer zones between crops undermines a major tenet of many people’s organic growing philosophies. Similarly, many organic farmers have recognized benefit from allowing wildlife zones along the edges of their fields to attract beneficial birds and insects.
During my cross examination at the hearing, a member of the USDA panel asked me if I realized that this agreement was voluntary for growers and distributors. I do. My concern is that this ‘voluntary’ agreement may turn out to be a de facto order for farms once their distributors sign onto it. Under the proposal, any distributor of leafy greens who signs onto the agreement may only work with farms who have also signed onto the agreement and who are in compliance with the established metrics. While the very smallest of farms may get by selling directly to consumers, there is a category of mid-sized farmers that must work with distributors to have access to a large enough market, but who may not be able to meet the demands of these new standards. Food Conspiracy’s main produce distributor works primarily with small to mid-sized organic farms in California. If our distributor gets pressure from a larger retail account to sign onto this agreement, they might be forced to drop some of their smallest farms in favor of larger ones who can comply with the metrics. In this case, not only will small farmers lose, but so will our customers.
While small farms must concern themselves with food contamination, recent national food borne illness outbreaks did not originate on small farms or in small packaging facilities. This brings me to my fundamental objection to this agreement; these standards are most compatible with and may push farmers toward monoculture farming on large pieces of land using conventional growing methods. This style of farming relies on heavy use of pesticides and fertilizers to maximize yields of a particular crop during a specific season so that the same land may be used to grow the same crop the following year. In my opinion, these very growing techniques are not compatible with increased food safety and they are certainly not compatible with a sustainable farming philosophy.
The experience of testifying before the USDA was interesting for me in a number of ways. One of the important things that it highlighted for me, however, had nothing to do with food safety. As I drove home from Yuma, I felt grateful for our Co-op and for co-ops around the country who act not just as purchasers of food from small sustainable farmers, but also as advocates for them in a food system that is designed by and for large multi-national corporations. The reason that co-ops have chosen to be an advocate for small farmers, is that at the most fundamental level, a co-op acts as an agent for its membership and the members of food co-ops around this country have always been pioneers in the push toward a more healthy and sustainable food system. I am grateful to work for the members of Food Conspiracy Co-op because our members, collectively, are supporting an alternative food system that connects the smallest growers and producers with people in their region.
Read Ligon’s testimony to the USDA and other testimony presented at the hearing: