Page 82 - Fall2010

In the end, a sickening image of hundreds of thousands of know and trust.
the bill does chickens kept under the most unsanitary condi- The fight to include the Tester-Hagan
tions imaginable. Among other things, the report amendments is not over, and even if the bill
nothing to noted that “Uncaged birds (chickens having passes, we will continue to have opportunities
address escaped). . . were using the manure, which was to fight for our local food producers during the
Big Ag’s approximately eight feet high, to access the egg rule-making process. For the latest information,
laying area.” In other words, hens were climbing go to www.FarmAndRanchFreedom.org.
control over on top of the piles of manure in order to reach

FDA, so the the feed within the cages. “Chicken manure NAIS UPDATE
agency will located in the manure pits below the egg laying As discussed in previous issues of Wise
operations was observed to be approximately 4 Traditions, in February 2010, Secretary Vilsack
almost feet high to 8 feet high” in multiple locations, announced that the USDA would drop its plans
certainly built up to the extent that the manure forced for the National Animal Identification System

continue to doors outward and allowed rodents access to (NAIS) and re-focus its efforts on a “new frame-
the indoors. Yet neither S.510 nor any other pro-
work” for animal traceability. The Secretary
target small posal in front of Congress or FDA even tries to stated the new framework would apply only to
producers reduce the growth of intensive confined feeding animals that cross state lines and would encour-
rather than operations, which create the perfect conditions age the use of low-tech methods of identification.
for bacterial contamination.

The USDA’s announcement sparked widely
the real In the end, the bill does nothing to address divergent reactions. Groups representing inde-
culprits in the Big Ag’s control over FDA, so the agency will pendent farmers and local consumers applauded
food safety almost certainly continue to target small produc- the USDA’s decision. But the proponents of
ers rather than the real culprits in the food safety NAIS, namely the Big Ag and Big Tech groups,
system. system. And as small farmers and local food expressed disappointment and issued statements

producers are driven out of business, consumers about the horrible things that could supposedly
will be deprived of their choices to obtain safe happen without a centralized ID system. These
and healthy local foods from producers they pro-NAIS entities quickly regrouped and an-

SOME TALKING POINTS ON S. 510 FOOD SAFETy LEGISLATION

• Proponents of S.510 claim that the bill allows an exemption for “farms” from the requirements for facilities, but the
language of the exemption is extremely narrow. A “farm” is not a “facility” only if the farm does not sell any processed
goods. The definition of processing is extremely broad and covers almost everything other than fresh-cut produce. So a
farmer who makes sun-dried tomatoes, jams from their own fruits, fermented vegetables, or other value-added products
would not be a “farm” under this definition and would be subject to the bill’s HACCP-type requirements for “facilities.”
• Moreover, there are no exemptions in the bill from the FDA’s “produce safety standards,” which will govern how farmers
can grow and harvest their crops. The only caveat is that the new standards cannot conflict with the organic standards,
but this only applies to certified organic operations. Many small sustainable farmers are not certified by USDA because
of the expense and paperwork burdens. Moreover, while not conflicting with certified organic standards, the FDA can
still add additional, burdensome and unnecessary requirements even for certified organic producers.
• We cannot effectively address microbiological contamination of produce without addressing CAFOs. There’s excellent
science showing that e. coli O157:H7 is rarely found in wildlife or grass-fed cattle, but is much more common in concen-
trated, grain-fed cattle. The continued avoidance of this issue creates a huge loophole in the legislation.
• Substituting paperwork inspections for actual inspections does little to improve food safety, while providing political cover
for large companies. Congress needs to focus resources on actual inspections, not HACCP.
• The GAO and others have identified that one of the core problems with food safety is the consolidation of our food
supply, which allows contamination at one farm or in one plant to sicken thousands of people across the country. yet the
advocates of S.510 simply ignore the threat of increasing consolidation. Any food safety bill should include an analysis of
how its requirements would affect small, local producers, and encourage decentralization. This is not just about fairness
for the producers themselves, it’s a necessary piece of addressing food safety.
• The bill does not respect small, local and organic farms, as claimed. On the contrary, it appears to be based on the myth
that all food should be subject to FDA regulation in order to be safe, and it leaves FDA with extensive discretion over
even the smallest of farms and food producers.
82 Wise Traditions FALL 2010