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Column: A Threat to Local Farms

  • Out early to avoid the heat of the day, Fred Lee, 80, of West Springfield, N.H., and about 70 others were in the field at 7 a.m. Saturday, picking strawberries on the first day of pick-your-own at Edgewater Farm in Plainfield, N.H., on June 25, 2005. Lee picked 28 pounds, which will be stored in his freezer and shared with his family for a taste of summer during the cold winter months.<br/><br/>Valley News - Caleb Raynor

    Out early to avoid the heat of the day, Fred Lee, 80, of West Springfield, N.H., and about 70 others were in the field at 7 a.m. Saturday, picking strawberries on the first day of pick-your-own at Edgewater Farm in Plainfield, N.H., on June 25, 2005. Lee picked 28 pounds, which will be stored in his freezer and shared with his family for a taste of summer during the cold winter months.

    Valley News - Caleb Raynor Purchase photo reprints »

  • Piglets root around a bed of hay at Sugar Mountain Farm in  West Topsham, Vt., on April 13, 2012. (Valley News - Sarah Priestap)

    Piglets root around a bed of hay at Sugar Mountain Farm in West Topsham, Vt., on April 13, 2012. (Valley News - Sarah Priestap) Purchase photo reprints »

  • Out early to avoid the heat of the day, Fred Lee, 80, of West Springfield, N.H., and about 70 others were in the field at 7 a.m. Saturday, picking strawberries on the first day of pick-your-own at Edgewater Farm in Plainfield, N.H., on June 25, 2005. Lee picked 28 pounds, which will be stored in his freezer and shared with his family for a taste of summer during the cold winter months.<br/><br/>Valley News - Caleb Raynor
  • Piglets root around a bed of hay at Sugar Mountain Farm in  West Topsham, Vt., on April 13, 2012. (Valley News - Sarah Priestap)
Chuck Wooster

Chuck Wooster

White River Junction

Imagine if the government were to pass a food-safety regulation that required every farmer to eat a little bit of everything they grow, every day. Problem solved: Farmers would have a strong incentive to make sure everything they grew was safe, healthy and nutritious. Or else they’d be the first to get sick.

Having written this, I can already feel a condescending pat on my head from some agribusiness CEO out in California. “Well, my boy, that’s a lovely idea you have there, but, of course, entirely impractical in the real world. How would we figure out who is the farmer? How could we get vegetables to our shareholders every day for them to eat? And how could we possibly comply with such an unreasonable regulation without losing our global competitive edge? You wouldn’t want that to happen, would you?”

Actually, I would. Here are three points to consider.

First, complying with my hypothetical “apple a day” regulation would cost most farmers in America almost nothing. I bet every farmer in the Upper Valley already meets the letter of the law. My own quality control runs to a couple cucumbers, a dozen or more carrots and too many cherry tomatoes to count during a typical harvest day, and the same holds true for other Upper Valley veggie farmers. All we’d have to do to comply with this regulation would be to stick an ear of corn in our mouths, hold up a copy of the latest Valley News to verify the date, snap a picture on a smartphone, and email it to our friendly government regulator. Done. Two minutes, tops, depending on how long it takes to finish the corn.

Second, images of amber waves of grain to the contrary, many farmers in America still run small farms that could comply with this theoretical “apple-a-day” law at minimal cost. Indeed, half of the food grown around the world is grown on small farms just like those in the Upper Valley. An articles in a 2010 Science magazine reported that not only do half of the world’s calories come from small, diversified farms that typically raise both animals and vegetables, but also that such farms hold great promise for meeting future food demand. Small farms aren’t unusual, they’re normal. So what better than a safety regulation that fits their needs?

Third, and here’s the problem: The government is in on the verge of doing exactly the opposite. The Food and Drug Administration is now finalizing the discouragingly titled “Food Safety and Modernization Act,” which will be a cinch for agri-giants to implement but punitive for small farms like those in the Upper Valley.

On its face, the Food Safety and Modernization Act has the laudable goal of trying to end the all-too-frequent bacterial outbreaks that contaminate fresh vegetables and spread illness and sometimes death across multiple states. The rule requires sensible steps such as ensuring that irrigation water is clean, that employees wash their hands, and that produce is stored properly. But then the FDA makes a critical mistake: Instead of applying these regulations to the huge farms that are selling to customers nationwide and causing these problems, it applies them to all farms everywhere.

If you’re a California farm selling many millions of dollars of just a few different crops, say spinach and lettuce, conforming with the Food Safety and Modernization Act will be a piece of cake. But if you’re a diversified New England farm both growing and selling a little bit of a lot of different things — exactly the sort of farm that most of us have around here, given that it’s seldom possible to scrape together enough flat acres to sell a million dollars of anything — you’re going to be coming up against the law in dozens of different ways, each of which will require its own set of solutions and paperwork.

For example, the proposed law requires that animals be separated from vegetables, in time if not in space, which isn’t a big deal on a big farm that raises only lettuce, fertilizes it with fossil-fuel and can install a filter on its irrigation system. But it’s a huge problem on a typical New England farm where animals fertilize the vegetables, and the farm needs the income from both to be viable. Under the proposed law, farmers would be required to wait nine months between applying compost and harvesting vegetables, unless the farm invested in expensive composting equipment and record-keeping. That would prevent the very common practice hereabouts of applying compost in the fall onto fields to be harvested in the spring, knowing that the long winter gives the soil plenty of time to neutralize whatever pathogens remained in the compost.

The FDA is required to calculate how much it will cost farms of various sizes to implement the law. For the nation’s largest vegetable operations grossing many millions of dollars annually, the FDA estimates the cost of compliance to be less than 1 percent of annual gross sales. For smaller farms grossing between a $250,000 and $500,000 a year, the estimate is 4 percent. And for the country’s smallest farms, grossing less than $250,000 a year, the cost of compliance is going to be 6 percent. The smaller you are, the more this will hurt.

The FDA recognizes that the law needs to be tailored to farms of different sizes and has set several exemptions and thresholds based on annual gross sales. But as the FDA’s own cost calculations demonstrate, these thresholds still seriously stack the deck against the very types of farms that are the bedrock of farming here. Grossing $500,000 a year might be a lot of money if your business required nothing more than a few laptops, an Internet connection and a few employees. But $500,000 in the farming world is peanuts: By the time you pay for your tractors, your greenhouses, your property taxes, and all the employees required to plant, weed and harvest vegetables on any scale, you’ll be lucky if your net income from a $500,000 gross is even at the poverty line for a family of four.

The most maddening part of the proposed law is that it doesn’t address the root cause of food-related illness in America: Significant portions of our water sources have been polluted by industrial agriculture. Many of the E. coli outbreaks have been traced to irrigation water fouled by nearby feedlots that concentrate too many animals into too small a space, effectively turning manure, which used to be considered a fertilizer, into a pollutant. Rather than requiring that these large farms pay for the damage they’re causing, the FDA is effectively proposing that small farms pick up the tab.

What can be done? The rule is open for public comment, so there’s still time to make improvements. If you want to delve into the arcana of the law itself, go to http://www.fda.gov/Food/GuidanceRegulation/FSMA/default.htm, where you can read up on the details and submit your comments before the Nov. 15 deadline. If you don’t have time for that, contact your representatives and ask them to level the playing field by changing the thresholds so that small farms don’t have to pay more than large farms to implement the law. (The FDA is writing the rule; Congress set the thresholds in the enabling legislation.)

And if you really want to have some fun, suggest that the law should apply only to those farmers who are unwilling to put their money where their mouths are and actually eat the stuff that they grow. Every day.

Chuck Wooster is a farmer and writer who lives in White River Junction.