Farm Heresies
When is a farm not a farm?
This is the last delivery of the year and hopefully everyone is enjoying a bit of holiday cheer. On the farm, seasonal exuberance is measured by simple tasks like finally cleaning out the top of the barn, rediscovering an 11/32 wrench that went missing sometime in March, and watching my dog stare out into the Pennsylvania wilderness while wondering when this stupid farmer is going to come in out of the cold. But the holidays would not be complete without a new tradition that has taken hold on the farm the last few years – commenting on the proposed FDA regulations that will soon determine how farmers will farm, and more importantly whether we will be able to farm at all based on rather vague theoretical concepts of how farms actually function. The Food Safety Management Act (FSMA or as we affectionately call it the F****d-up System for Mismanaging Agriculture), has been in the works for over a decade with the passage of the Bioterrorism Act of 2002. It is also a response to high profile food contamination incidents that are largely the result of corporate farming practices. Unfortunately, those of us who have been in the forefront of food safety for nearly 40 years by rejecting the corporate model, as well as conventional farming methods for more sustainable practices to assure safe food, have been swept up in the regulatory fervor of an agency that is devoid of any experience or knowledge of agriculture.
To be fair, FDA did respond positively to tens of thousands of comments last year, and adjusted some of the most egregious parts of the proposed rules. Unfortunately, they ignored other significant aspects of the rules that will have serious repercussions for small farms like ours. Most notably, FDA continues to cling to an ambiguous distinction between farms and facilities. To the uninitiated this may seem trivial, but it is at the heart of who will be subject to some of the most onerous parts of the rule and whether small farms like our will be able to afford the expenses associated with compliance. According to FDA, a farm is defined as existing in one general location and under single ownership. This rather sentimental view of farms contradicts how farms have worked for centuries. The details of the definition would redefine farms as facilities by default if a farmer rented land, owned a farm with a family member, bought and redistributed agricultural products from other farms and generally participated in the local agricultural economy. The result of applying this rule would have a resoundingly negative impact on the continued growth of local food hubs and the profitability of small farms that thrive on the relationship between local farms and the consumer. Of course, the most ironic part of this rule is that it contradicts the efforts of other well meaning bureaucrats at USDA who have programs that actively promote the current trend in local food hubs. The right hand definitely doesn’t know what the left is doing in this instance, and if they did they wouldn’t care anyway.
So with that holiday rant I’ll leave you with a link to learn more about this rule and how you can comment. Even if you don’t comment, you should understand the import of this regulation because it will eventually effect how we all conduct our business. http://writetofarm.com/2014/12/08/let-a-farm-be-a-farm. The local food movement is successful precisely because there is broad based support for it from small farmers, local governments, and most importantly consumers. That’s why I’m generally optimistic about the future of small farms – there are just too many of us who want local farmers to thrive and expand.
