The Food Safety Modernization Act – Part 3

You’ll recall from my last post that the FDA estimates the annual cost of compliance with the FSMA to domestic farms to be roughly $460 million.  However, anyone reading past the press briefings by the agency has the opportunity to learn that the FDA further specifies the division of this cost.  According to the agency’s analysis the cost of compliance with FSMA every year, will be nearly $4700 for ‘very small farms’, nearly $13,000 for ‘small farms’ and $30,566 for ‘large farms’.  If this still doesn’t mean very much to you then you may want to jump over to another important policy document produced by the United States Department of Agriculture (USDA).

Small farms and huge corporate farms operate very differently

Small farms and huge corporate farms operate very differently

According to the 2007 Ag Census, 60% of all farms in the country report sales of less than $10,000 annually.  These farms are what the USDA classifies as ‘very small farms’. The FDA is expecting ‘very small farms’ to  suddenly add expenses equal to nearly half of their annual revenue.  I’ll save you the research and subsequent algebra and let you know that this means over 1.315.470 farms will potentially be driven out of business.  And that’s just the ‘very small farms’.  The Ag Census does not provide specific enough data regarding where on the spectrum from $10,001 to $250,000 the remaining 31% of U.S. ‘small farms’ fall.  But to be sure many of them are just too large to be counted as a ‘very small farm’.  This means that a certain percentage of farms are expected to pay out thousands of dollars more than they make each year.  The implications for this are devastating for a vast majority of the nations farms and farmers.

But what are the implications for you, your family and your dinner plates.  Many officials at the national and state levels all across the nation have recently ratcheted up the rhetorical campaign about this issue by suddenly claiming that small-scale farms are just as likely to cause outbreaks as large farms.  This is to combat two arguments that most of us small-scale, and yes, ‘very small’ scale farmers are making.  First, the illnesses and outbreaks caused by food are traced back to huge corporate farms, huge packing facilities and national or regional grocery chains.  And second, the regulations being crafted to combat the problems do not take into account the difference in scale and the beneficial effects that small-scale have on food safety.  So who is right, the government officials or the farmers and food sovereignty activists?

Anytime you hear an official claim (anything really) that small farms are just as likely as large to cause outbreaks of illness you should remember a quote by the most widely read political thinker and dissident in the world (excluding the U.S.) Noam Chomsky.

“It’s always a good idea to start by asking about the facts. Whenever you hear something said very confidently the first thing that should come to mind is, Wait a minute, is that true?”
In this case the facts stand in marked contrast to the statements being made.  And once again, anyone can learn this for themselves.  The hope of these agencies and officials is that you don’t.  However, you can view the Food Outbreak Online Database (FOOD), and similar sites by the FDA and USDA.  You can also search the internet for news stories related to outbreaks of food caused illnesses.  What you will find is that outbreaks come from the biggest corporate players.  This is even more noteworthy because of the fact that 91% of the nation’s farms are considered ‘small’.  Statistically speaking the statements by these officials are wrong.  Scientifically speaking, they are false.  
E-coli 0157:H7 cannot exist in the cows pictured here.

E-coli 0157:H7 cannot exist in the cows pictured here.

Consider for example the case of E-coli.  You may not know this but every human has e-coli in the gut.  In fact it is very prevalent in all mammals (as far as we know) and many other animals.  However, when you hear E-coli and panic, that’s because you’re associating the name with a very specific type, namely E-coli 0157:H7.  In the case of this pathogen it can only exist in a certain environment and in fact was created by the mistreatment of cattle.  This particular strain of the bacteria did not exist until corporate Confined Animal Feeding Operations (CAFO’s) began keeping millions of cows penned in pits of their own manure eating nothing but grain (all with the blessing and ‘science’ of the FDA and USDA).  Cows did not evolve to eat grain, stand still nor stand in their own manure.  They evolved to eat grass, roam grasslands and move to new ground frequently.  When the industry changed this they had to change a lot of other things too because the cows get sick.  One result of all of these changes is that the ph in the cow’s rumen has changed and allowed for a mutation or adaptation of e-coli that survives in the human gut, which is too acidic for most other e-coli that is introduced through food.  E-coli 0157:H7 does not exist in a cow that has lived its life out on open pasture eating grass and forage because the cow’s series of stomachs are in balance.  The same is true for all livestock animals.  If an animal is allowed to live as it evolved to live, the bacteria make-up and load will be very different relative to the same animal that is not.
Eggs from hens that range, hunt, scratch and breath fresh air do not pose the same risks as factory raised eggs.

Eggs from hens that range, hunt, scratch and breathe fresh air do not pose the same risks as factory raised eggs.

This is one of the most obvious reasons I say that the Food Safety Modernization Act will result in a food system that is less safe than the current 1 in 6 of us gets sick system.  The result of this law and the resulting regulations being written by the FDA will lead to the loss of the farms that actually produce safe food.  This will have lasting effects beyond this generation.  Once this fact is finally recognized by the mainstream we may find that much of the knowledge of how to produce food safely has been lost.  This is already happening due to the industrialization of the farm.  That knowledge has always been passed from one generation to the next on the farm.  What happens when those farms disappear?

In my next post I’ll get into the “science” behind the FDA’s proposed rules.  That science also leads to a system that is no safer than the one we have now.  And the FDA can prove it.  Local food.  Eat well – be well.


Ryan Parker

About Ryan Parker

Ryan Parker is a farmer, writer, artist and musician. He currently lives in Central Maine with his wife, two children, a golden retriever, some pigs and chickens. He raises pastured and forested animals and grows a diverse range of vegetables without synthetic chemicals, pesticides, herbicides or taxpayer subsidies.