Changing seasons & the Food Safety Modernization Act

This is the last week of our summer CSA season, but we are not done for the year. We are again offering a winter season CSA (here’s the sign-up form: 2013wintercsasignup), which this year is running through December. The early part of the season this year was a bit rough, and resulted in a poor harvest of several full season crops, including some of our major staples, like Potatoes and Winter Squash. A lot of our fall storage crops are looking great though, so which we are not offering a long haul option, we’ll have lots of vegetables through December.

Our Northampton Farmer’s Markets extend right through the winter – Tuesday Market is running through November 12th, and the Northampton Winter Market is starting up on the 16th, and will happen every Saturday through April. As some may have seen in the Hampshire Gazette, it looks like the Winter Market is going to lose the space in Thornes that we have been using. It’s still unclear how that is going to play out and where we will be, but we are expecting that the market is going to happen and we’re planning to be there.

Depending on how the winter market goes and how our hoophouses are producing, we’ll be assessing our vegetable supply in March and deciding on whether or not to offer a spring CSA season before our regular summer season starts. All we know right now is that we need a little bit of a break in January and February.

In other news, we want to encourage all of you to comment on the Food Safety Modernization Act. If you haven’t heard about it, this is a new piece of legislation that gives the FDA broad new powers to control the food supply from the farm through processing. It was enacted in response to the many disease outbreaks in recent years linked to fresh produce. Fresh produce has been almost entirely unregulated up until now. Since much of the produce industry really is industrial in scale, some level of regulation seems appropriate. In just the past week there was another recall of salad greens from a processor in Boston, of 300,000 pounds of salad. It’s a mind boggling amount of salad. But the proposed federal standards were mainly written based on the recommendations of the industrial processors, and are going to hurt small and mid sized farmers and processors much more than the big ones.

CISA has put together a lot of great information about the issues on their website: (including a petition to sign and sample comment letters to send)

Crabapple Farm fits into the Small Farm Exemption, which means that we are (maybe) exempt from the new standards and so won’t be harmed by them. But here’s the catch – there are some folks arguing to get rid of the exemption (which would be terrible for small scale local production and would likely put us and most farms like us out of business), and the exemption as proposed leaves a lot of unanswered questions. My understanding of the proposed exemption is that a small farm is exempt from inspection, and so can ignore the rules, but if the FDA feels like inspecting you, they can, and if they want to, they can remove your exemption entirely, and then you must comply with the full requirements of the law, with no mechanism for getting back into the exempt category.

The exemption was written into the law due to an understanding that the costs of complying with the new rules would be prohibitive for small farms. There is a significant recordkeeping component to the rules, with many estimates determining that most farms would need to hire a full time employee just to handle the paperwork involved.

While not prohibiting it, the standards place so many restrictions on livestock and manure that integrated diversified production like we do will be very difficult. Basically, the FDA doesn’t want a farm to raise both vegetables and livestock. They also want farmers to keep wildlife away from fields used for vegetable production. While I don’t particularly like it when deer nibble our seedlings, we consider birds and other wildlife in our fields to be a sign of ecosystem health and something to encourage. The proposed rules could lead to the destruction of riparian areas near farm fields, which happened in California when the first produce rules were created by the processing industry there.

Meat and Dairy are both subject to federal regulation, and have been for decades. The effect of those regulations was serious consolidation in the processing industries, and most small farmers going out of business. It is only in the past decade or so that some small farmers like us are finding our way around the regulations and beginning to produce those products for a local market again. We produce a lot of different kinds of food. Two that we don’t do, you may have noticed, are dairy and poultry. Why? Because of the regulations. It would cost us too much money to build facilities that would be approved by the inspectors for either product to be profitable on our scale. There are a small handful of folks in the area who have waded through the bureaucracy in order to provide folks with these products, but the reason there are so few is not that there isn’t demand, and it isn’t that milking cows or raising chickens is so much harder than raising vegetables. But selling milk or poultry legally is way, way harder and more expensive than selling vegetables.

The only way we can do meat is to truck our animals to a USDA inspected slaughterhouse an hour and a half away. If you’ve ever heard of the idea of the hundred mile diet, well, you can’t do that around here. Our meat has over a hundred miles on it just to get from our fields to our freezers. There is no other option, if we want to sell our meat legally.

There are a lot of young farmers like us these days, and while some of us are raising meat or milk, most of us are vegetable farmers. Because that is the only sort of farming that you can do without investing a ton of money in infrastructure. If the small farm exemption isn’t made solid, then that may stop being true in the near future.

The comment period on the proposed rules is until November 15th.

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