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Organic Consumers Association

Food Safety Bill Would be Bad for Local and Organic Farms

Anational egg recall, local Umpqua milk contamination: When will it end? Isn't it about time the Senate followed the House and passed The Food Modernization and Safety Act (S 510)?

When Congress reconvenes in September, the push will intensify to get this done. But Houston, we have a problem.

This bill treats small farmers the same as large industrial operations, requiring mountains of paperwork and outright meddling with farming practices. Think of raw milk producer Mookie Moss, recently featured on Page 1B of this paper. Fed up with interference by the Oregon Department of Agriculture, he renounced his state dairy license, limiting his market rather than fight red tape. S 510 would bring the power of the federal government down on Mookie, damaging and potentially destroying his business altogether.

If you like buying locally produced food, if you think that diversified local agriculture is a good thing, if you are a small farmer, then you should be very concerned about this legislation.

Even though all the major food-borne illness outbreaks and recalls have occurred within the large, industrial food system, under S 510 the Food and Drug Administration would regulate everyone from Community Supported Agriculture to the farmers and food processors who sell at the local farmers market. Increased regulations, interference with farm practices, burdensome record-keeping requirements, penalties and fees could drive already struggling small farmers out of the business altogether.

Take HACCP, for example. Under this legislation, all food producers of any size would be required to implement a Hazard Analysis and Critical Control Points plan for each food product they sell. The operator must have in writing:

 * A hazard analysis.  * Preventive controls to address those hazards identified, including those hazards identified by the Health and Human Services Secretary through regulation or guidance.  * A description of the procedures for monitoring preventive controls.  * A description of procedures for taking corrective actions.  * A description of verification activities for preventive controls including: (a) validation that the system of controls will prevent, eliminate or reduce to an acceptable level the identified hazards; (b) review of monitoring and corrective action records; and (c) procedures for determining whether the system of controls as implemented will effectively prevent, eliminate or reduce to an acceptable level the occurrence of identified hazards.  * A description of the facility's procedures for record-keeping.  * A description of the facility's procedures for the recall of articles of food.  * A description of the facility's procedures for tracing the distribution history of articles of food.  * A description of the facility's procedures to ensure a safe and secure supply chain for the ingredients or components used in making a food manufactured, processed, packed, transported or held by such facility.  * A description of the facility's procedures to implement science-based performance standards issued by HHS.


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