How can we protect both the U.S. food supply and small producers, who can't afford a full-time clerical staff to chart regulatory compliance?
Just south of my little bit of Heaven here at Langdon, the earliest known case of food borne illness may have occurred several thousand years ago in Jackson County, Missouri. (According to Joseph Smith, founder of the Latter Day Saint movement, that’s the location of the Garden of Eden.)
The victim was known simply as Adam.
The alleged incident occurred through direct contact with an unapproved reptilian species, aided by a female co-worker who failed to follow instructions from a higher authority. Like they say, rules were made to be broken, and we’ve been paying for it ever since.
Yes, food safety is costly, especially when people don’t follow the rules. But as food production has taken place on a grander scale, our sins have multiplied to the point that the government thinks we need a whole new standard of HACCP, that’s short for Hazard Analysis and Critical Control Point Principles.
Principles didn’t save Adam. HACCP probably wouldn’t have either, but one thing is sure: Eve could have covered her backside with all the paperwork.
These days the Food and Drug Administration and U.S. Department of Agriculture share responsibility for overseeing the nation’s food, though USDA alone has responsibility for meat and poultry through the Food Safety and Inspection Service. USDA can be difficult for small processors to deal with, because its rules typically are written to manage and oversee larger corporations.
In low population areas like Langdon, small meat processors are booked up months in advance. It seems strange with so much demand for locally produced food that more local butcher shops aren’t thriving. According to a recent article in the Atlantic by Joe Cloud, owner of an abattoir, the biggest hindrance to local meat processing is USDA’s byzantine rule-making. Joe blames HACCP administered by the Food Safety and Inspection Service (FSIS) for running 20% of small processing plants out business. He says revisions to HACCP will eliminate even more small processors, due to competition from industrial meat production and rules USDA has adopted to protect consumers.
On the surface HACCP sounds like a great idea — everyone wants safe food — but it assumes that food suppliers are all large corporations involved in producing, processing, and merchandising. The requirements of HACCP generate mountains of paper, the kind of detailed reporting that only resource-rich big business can handle.
Small farms work a little differently than big corporations do. Farmers do bookwork on rainy days, weekends, or evenings after supper. Hiring a fulltime bookkeeper is something few can afford. Those who work a job in town and farm on the fringe of each and every day have even less time to jump through bureaucratic hoops. Despite the Obama Administration’s position on locally produced food, HACCP threatens to derail local food production by forcing small farmers to adhere to the same complex set of standards designed for big multinational corporations.
HACCP fails to recognize that a lot of food ills are cured simply by doing it right, locally, in the first place. What the Obama Administration calls “Know Your Farmer” makes full reporting seem like overkill, because getting acquainted with where our food comes from and who raises it means we can have confidence in its safety. Knowing your trustworthy farmer is the ultimate food safety guideline.
Meantime, a lot of what big business tells us about food needs to be taken with a grain of salt. For instance, Cargill wants to add more salt to food even though FDA says they use too much. Cargill says the alternative to salt in processed foods is added sugar. That kind of sweet talk sounds more like blackmail. A better alternative to flavor additives is fresh, flavorful, high quality food.
For some of us it’s all about gathering cheap ingredients from all over the world and making a lot of money. FDA barely scratches the surface in its inspection of food imports; about 99% of food imports — worth $75 BILLION — are not inspected, and exporting countries aren’t required to have the same high standards we have here. Even when inspectors do find a contaminated needle in the haystack, many times the food recall is issued after the tainted food has been consumed. But the paperwork all looks great.
FDA has recently opened an office in Beijing to keep an eye on rising U.S. food imports from China. With nearly 1.4 billion people, about 20 percent of China’s population are farmers. That’s 300 million people, equal to the entire population of the United States of America. It’s doubtful that all of them will file HACCP paperwork on time.
Food is not inherently dangerous any more than air or water is dangerous. They’re only dangerous when man or nature has polluted them. The way to stop pollution may not be to put more laws on the books but to enforce the laws we have. Unfortunately, neither FDA nor USDA has a strong track record for ensuring safe food. In spite of all our rules and oversight, 25% of Americans contract a food borne illness every year. That compares to only 1 or 2% of Europeans with their access to smaller scale local food systems. Without adequate enforcement, retirement accounts can be pilfered, oceans polluted…. and consumers poisoned.But what are the odds that the existing laws will be better enforced?
Real farms are a paradise of real food. With real food handled sensibly there is no adulteration, no melamine, no MSA, no gunk, no junk, just pure nourishment — the kind Adam once had in his garden.
GAP (Good Agricultural Practices) fills the regulation gap, letting farmers write their own inexpensive seven-page rulebook to show regulators that they know how to do their job. USDA administered GAP is better for farms because, generally speaking USDA, knows farms in a way that FDA does not. That’s why a lot of farmers favor the GAP food protocol. Farms aren’t like big pharmaceutical firms or other corporations with lawyers and lobbyists on staff working constantly to make restrictive rules meaningless and negotiate penalties after rules are broken. Most of us are just trying to get the job done right.
Delegates to this year’s National Farmers Union policy session heard one farmer tell about FDA inspectors who visited a small vegetable farm. One inspector happened to look up at the sky, and was filled with alarm: “Oh, my God,” he said to the farmer, “You have birds!”
Alfred Hitchcock saw this coming nearly 40 years ago, when he portrayed gulls and crows as cold blooded killers. That’s the way FDA sees it, too. Anyone who’s ever washed a windshield knows what birds can do. That’s one reason why big business has a hard time slicing, dicing and mixing ingredients without blending in contaminants.
Big farms and food companies say food rules are too costly now without piling on new standards. After joining a cooperative along with other growers, one large scale farmer estimated his annual cost of compliance on about 8000 acres at nearly $250,000. That’s about $30 per acre, a relatively small expense for crops worth millions. (A single acre of fresh cauliflower can be worth $6000.) But for small scale producers with fewer resources, time is money that needs to be spent on actual production from 5 or 10 acres.
Small producers’ costs could easily be hundreds of dollars on every acre through added expense and lost time in the field. That’s why National Farmers Union delegates placed language favoring GAP into the NFU 2010 policy statement.
Here in Missouri, Lincoln University is trying to help small food producers by offering a workshop where aquaculture farmers can learn how to become HACCP certified and how a planned mobile processing unit will operate. Nancy Smith with Farm to Family Naturally and Missouri Organic Association president Sue Baird are working to train growers for GAP compliance in an effort to counteract regulations that seem to favor large farms.
HACCP assumes food producers and processors need strict rules to follow, but GAP relies on basics combined with ethical standards of food production by caring local providers. Oversight isn’t removed, but it’s carried out in a better, less costly context for more effective outcomes.
Ethical standards combined with knowledgeable, responsible local food production seems like an effective way to get the quality food people want to eat. Honest farmers standing face to face with consumers should make all the difference in a world of food where not everything is good.
Rules aside, without trust, just one wicked snake spoils the garden for everyone.