The Gary Null Blog

Cornucopia Institute, June 29th, 2011

http://www.cornucopia.org/2011/06/action-alert-big-agusda-could-run-organic-leafy-green-growers-out-of-business/

National Leafy Greens Marketing Agreement Comments: Due July 28

Action Alert

Corporate agribusiness wants to tell the rest of us how to farm, and shut anyone out of the market who does not follow their one-size-fits-all “food safety” standards for leafy green vegetables. The USDA is supporting their plan, which, if accepted, will allow a committee of industry representatives, lobbyists and other officials to write a set of so-called food safety standards for the entire leafy green farming community—this could competitively injure smaller, local and organic producers.

If passed, leafy green handlers/marketers who sign on to this agreement will require every grower they buy from to follow a uniform set of standards, which will be written with large-scale, monoculture, chemical-intensive farming methods in mind. Farmers do not sign on to the agreement – their buyers (brokers, distributors and supermarket chains) do. Sustainable organic and local growers who take different approaches to food safety will likely be shut out of the market when buyers refuse their buy their crops.

With the recent passage of the Food Safety Modernization Act, this proposal by industrial-scale, monoculture interests for industry self-regulation is simply unnecessary and counterproductive.

The USDA needs to hear the widespread opposition from the organic/local community, farmers and consumers together, before the July 28th commenting deadline.

This ill-conceived plan is proposed in the name of food safety, but fails to tackle the root of our nation’s food safety woes: the unnatural rearing and feeding practices of conventional beef and dairy cows, hogs and chickens on industrial-scale “factory” farms. There is nothing inherently dangerous about leafy greens—the problem lies in contamination of surface and groundwater, and even the air in farm country, from our nation’s filthy feedlots and animal factories!

Tell the USDA, which does not have the legal authority to supervise vegetable safety (Congress has exclusively charged the FDA with that responsibility) to withdraw the National Leafy Greens Marketing Agreement proposal immediately.

Talking Points

Please submit your comments today, expressing your strong opposition to the proposed Leafy Greens Marketing Agreement, for the following reasons:

Industry self-regulation is the wrong approach to food safety: The Leafy Greens Marketing Agreement will give industry representatives authority to self-regulate for food safety, doing a disservice to our citizenry’s need for safer food.

The USDA Agricultural Marketing Service has no food safety experience or expertise: With the recent passage of the Food Safety Modernization Act, which gives greater authority to the Food and Drug Administration to regulate for food safety, there is no need for the USDA’s Agricultural Marketing Service to get involved in food safety through industry self-regulation.

Wildlife and biodiversity: Experiences in California have shown that industry-driven food safety measures ignore important environmental, wildlife, and biodiversity concerns. The California LGMA has resulted in the wholesale loss of wildlife habitat and destruction of natural vegetation, even though it has not been proven that these are material factors in food contamination.

The NLGMA will be a setback for the organic movement: With the current proposal to reserve only one slot on the 26-member committee for an organic producer, the food safety benefits of organic and sustainable farming practices will likely not be factored in to the LGMA’s standards. Organic and sustainable farmers who choose not to follow the LGMA’s standards will likely to be shut out of the market, doing irreparable harm to the growth of the organic and sustainable farming movement—and the availability of organics for consumers.

Failure to address the root of the problem: The LGMA metrics will do nothing to tackle the root of the problem, which is, in most cases, bacterially tainted manure from confined animal feeding operations (CAFOs) that contaminate nearby fields and waterways

One-size-fits-all standards hurt family farmers: It is unclear how a set of national rules can accommodate both large-scale, monoculture growers in one part of the country and small-scale, diversified farms in other regions in the US. Rules that may be appropriate for one type of farm may put unnecessary burdens on other producers—and with large-scale growers setting the standards, chances are that the smaller-scale and diversified farms’ needs and concerns will be the first to go.Smaller, owner-operated, local and organic are likely producing the safest and most nutritious food in this country. If any problems occur, these events are isolated given smaller geographical marketing footprints. It would be a blow to produce safety if this growing trend towards diffuse, regional production is competitively injured.

Sample Letter

We encourage you to write your own comment using the talking points above, but you may also cut and paste the following sample letter:

Dear Ms. Schmaedick,

I am strongly opposed to the proposed National Leafy Greens Marketing Agreement. Allowing an industry to regulate itself is simply the wrong approach to food safety. With the recent passage of the Food Safety Modernization Act, this proposal is simply unnecessary.

I am most concerned with the way in which this proposed agreement would impact organic, small-scale and sustainable farmers. With only one slot on the 26-member committee reserved for an organic producer, it is unlikely that the food safety benefits of organic and sustainable farming practices will be factored in to the Agreement’s standards. Organic and sustainable farmers should not have to choose between following metrics that were written by and for large-scale, monoculture farming operations, and finding a market for their vegetables.

The proposal is merely a band-aid solution to food safety concerns, doing little to address the root of the problem (such as bacterially tainted manure from confined animal feeding operations (CAFOs) that contaminate nearby fields and waterways) while shutting smaller-scale, owner-operated, local and organic farms out of the market.

Please withdraw the proposed National Leafy Greens Marketing Agreement.

Take Action

1. Submit your comment before the July 28 deadline.

To submit your comment electronically, follow the link: http://www.regulations.gov/#!submitComment;D=AMS-FV-09-0029-0150

We strongly encourage to also email the USDA’s Melissa Schmaedick, author of the proposal, directly with your comment: Melissa.Schmaedick@ams.usda.gov, with “AMS-FV-09-0029” in the subject line.

To submit your comment via mail:

Address your comment to:

Hearing Clerk, United States Department of Agriculture
1400 Independence Ave., SW., Room 1031-S
Washington, DC 20250-9200

Please make sure to place the following docket number on your letter: AMS-FV-09-0029 and state clearly that you are opposed to the National Leafy Greens Marketing Agreement

2. Please e-mail/Facebook your family and friends and encourage them to submit their comments as well!

* Please take the time to submit your comment by clicking on the link to http://www.regulations.gov/#!submitComment;D=AMS-FV-09-0029-0150. This is the official government website for comments.