This issue focuses on the proposed regulations that the U. S. Food and Drug Administration (FDA) released in January for public comment. The regs are designed to enforce the Food Safety Modernization Act (FSMA) passed by Congress and signed into law in January, 2011. Originally the comment period for these regs was to end on May 16, but widespread concerns, including that such a date caught farmers in the midst of the busy planting season, has persuaded the FDA to extend the comment period until September 16.
We hope that the information presented here helps you understand the concerns that the FDA has with the problem of microbial contamination of food in this country. According to the FDA itself, despite the US claiming to have the safest food supply in the world, about 48 million people (1 in 6 Americans) get sick, 128,000 are hospitalized, and 3,000 die each year from foodborne diseases (Center for Disease Control estimatesas of Feb. 6, 2013). So it is not as safe as it might be!
Many changes will be required of farmers in the months and years to come because of these regulations, so it is important that you understand them. But it is also important at this time that you not only understand them, but make the effort to contact the FDA with your comments this summer, before they become final.
When the USDA regulations governing the National Organic Program were first presented to the public in the winter of 1997-98, opposition to them was so widespread (they allowed Irradiation, GMOs and sewage sludge in organic, among other things) that the USDA revoked them and issued entirely new ones after four more years of study. So it is possible to affect this process if public concerns are widespread and presented to the FDA. How to do this is well documented in this issue.
But many observers wonder whether the concern of our government for food safety is not myopic. We are witnessing a gargantuan effort to keep pathogens out of our food. Yet when it comes to other — far more sinister — problems with food safety the FDA has been almost criminally negligent.
The agency has, for example, for almost 20 years allowed the widespread adulteration of food with new and untested proteins stemming from transgenic crops. This was done to increase the competitive advantages of American business, despite numerous warnings about the untested products being unsafe for the food supply.
When first presented with GMOs, FDA’s scientists howled and fired off memo after memo declaring that transgenics presented serious potential human health risks. But they were ignored. The result, two decades later, may well be a national epidemic of inflammatory and auto-immune diseases.
I say “may well” because the FDA has required no testing of these foods, and they go unlabeled in the food supply, so no one can know for sure how much of them we are eating or what damage they are doing.
Another example of FDA’s myopia is the specific allowance in these FSMA regulations of the use of sewage sludge as fertilizer. Study after study has shown that many heavy metals, industrial chemicals, solvents, pesticides and carcinogens are unaffected by the processes used at US municipal treatment plants. They are still present and active in the sludge as it is shipped off to American farmers to spread on crop land.
That the regs virtually prohibit the use of manure — while specifically allowing the use of sludge — is more a testament to the political power of US cities faced with a difficult disposal problem than an indication of the reliance of the FDA on sound science.
Read this issue carefully and see how your operation may have to change because of this focus on microbial contamination. Is it possible for you to comply? Will you have to give up fields, water sources, crops, or procedures? How much will it cost you?
But don’t forget that food safety is more than a fight against pathogens. For us to be truly healthy we must eat food which is grown without toxic chemicals, from pure seed, and in biologically active soil. That is what we as farmers, and our customers as consumers, really want from agriculture.