There's been a lot of buzz on the web about the new Food Safety Enhancement Act of 2009 (HR 2749). Many of our supporters have called or emailed us to find our stance on the issue.

Although the Organic Consumers Association is fairly satisfied that the bill is intended to protect organic farmers from being negatively impacted by new food safety regulations (Sec. 419A directs the USDA to "take into consideration, consistent with ensuring enforceable public health protection, the impact on small-scale and diversified farms, and on wildlife habitat, conservation practices, watershed-protection efforts, and organic production methods"), unfortunately the bill does not address the underlying causes of America's persistent and evermore serious food safety crisis: factory farms and chemical-intensive agriculture. When addressing the concerns of E.coli or salmonella, the bill focuses on fresh vegetables and fruits rather than CAFOs or intensive confinement factory farms, in effect treating the symptom and not the disease.

A close look at the nation's food poisoning epidemics over the past decade reveal that the overwhelming majority of fruit and vegetable contamination incidents are a direct result of water and soil pollution from large factory farms. The OCA believes that HR 2749 should be amended to address factory farming:

1. Animals should never be fed blood, manure or slaughterhouse waste.

2. Cows need to eat grass.

3. Animals need to be spread out on enough land to absorb their waste.

4. CAFOs (Confined Animal Feeding Operations) pose unacceptable risks to human health, such as antibiotic resistance, incubate dangerous viruses and pathogens, such as the Swine Flu and Bird Flu, contaminate the environment, institutionalize animal cruelty, and need to be phased out and shut down.

In addition, we share the concerns of the Farm-to-Consumer Legal Defense Fund and support the amendments suggested by the Maine Organic Farmers And Gardeners Association. We also agree with the Wild Farm Alliance, especially their position paper, Food Safety Requires a Healthy Environment: Policy Recommendations for E. coli O157.

The dangers to food safety of factory farms, also known as Confined Animal Feeding Operations, are well documented by the Pew Commission on Industrial Farm Animal Production, the Union of Concerned Scientists, the National Resources Defense Council and Food & Water Watch.

In addition to factory farm runoff, vegetables can also become contaminated is through the use of untreated animal manure or biosolids (the fertilizer industry's name for sewage sludge/human waste). Organic regulations ban sewage sludge and have rules for the use of manure that prevent contamination.

Certified organic farmers must maintain a farm plan detailing the methods used to build soil fertility, including the application of manure. Organic rules require raw animal manure to be composted if it is to be applied to land used for a crop intended for human consumption. Well-composted manure reduces the incidence of E. coli. Manure must be applied to the land at least 120 days prior to harvest if the edible part crops come in contact with soil, and at least 90 days prior to harvest of edible parts that do not come into contact with soil. Longer periods can be required by certifiers if soil or other conditions warrant. No other agricultural regulation in the United States imposes such strict control on the use of manure.