Friday, September 4, 2009

Proposed Federal Rules Could Competitively Injure Small, Local and Organic Fresh Market Produce Growers

Action Alert
September 3, 2009

Proposed Federal Rules Could Competitively Injure Small, Local
and Organic Fresh Market Produce Growers

USDA Schedules Public Hearings to Obtain Citizens' Concerns and Suggestions

The “Leafy Green Marketing Agreement,” which requires producers to follow a set of rules (metrics) in the name of food safety, has already shown to be injurious for the environment, biodiversity, and organic growers in California. The USDA is now considering a similar “Leafy Green Marketing Agreement” that would extend beyond California and Arizona to cover the entire United States—let's help make this rule work for growers of all sizes!

The USDA has scheduled a series of hearing sessions, around the country, inviting you to this perfect opportunity to share your concerns and suggestions.

Make your voice heard!—if you are able to attend, we urge you to speak on behalf of the organic and family-scale farming community. (See below for locations and dates.)

High Quality and Organic Growers Competitively Disadvantaged

Producers’ experiences in California, where these metrics have been in place for several years, reveal what is at stake. While food safety is a legitimate national concern, organic and small-scale farmers bear a disproportionate economic burden of these metrics. Consider this:

  • An estimate from leafy green growers in California indicates an average expenditure of $18,000/ year per farm for food safety efforts.
  • Metrics require the expense of regular laboratory testing of irrigation water, soil amendments, fertilizers and sometimes seeds and transplants.
  • Growers must have someone regularly monitor fields for wildlife and domestic animal incursions and documentation of all their efforts and testing is required.
  • Farms with more acreage generally spend more to comply with the metrics but can experience some economies of scale due to larger field sizes and existing staff—these burdens could force the safest farms out of business.
  • Smaller farms often have smaller field sizes, grow more diverse crops and raise livestock as well. These farms don't usually have staff available to help them comply with complicated record-keeping requirements nor can they afford to hire extra help. They incur higher expenses per acre due to their smaller field sizes and greater complexity and disproportionately high testing/inspection costs.
  • The requirement to have traceability of the produce grown also poses significant financial and record keeping challenges for many growers—organic farmers are already required to do much of this—it is redundant for organic growers—and local direct marketers have a special relationship with customers facilitating trace back.

Biodiversity Threatened

The environmental impacts of the Leafy Green metrics have also been alarming. Since wildlife, non-crop vegetation (wild habitat), and water bodies could be viewed as food safety risks, many environmentally positive, conservation and habitat-oriented practices that growers have implemented in California have been forced to be destroyed or abandoned by growers threatened with the rejection of their crops.

If these metrics are adopted nationally, organic farmers across the nation could face difficulties balancing organic requirements, to promote biodiversity, with metrics seeking elimination of wildlife and non-crop vegetation.

Voluntary Regulations?

Although the USDA has defined this regulation as “voluntary,” it is important to realize that in California, this has not been the case. Large grocery chains and distributors have refused to purchase produce from growers unless they are a signatory to the “leafy greens” program, making this a defacto rule. Don’t let the voluntary nature of this program dissuade you from recognizing the impact this proposal could have on small, local and organic growers.

Make Your Voice Heard!

The USDA organized public hearings to glean citizens’ concerns and suggestions. The USDA invites you to present evidence at the hearing on the possible economic impacts of the proposal on small businesses.

When and Where?

Monterey, California September 22-24

Jacksonville, Florida September 30-October 1

Columbus, Ohio October 6

Denver, Colorado October 8

Yuma, Arizona October 14-15

Syracuse, New York October 20

Charlotte, North Carolina October 22

All hearing sessions are scheduled for 8:30 a.m. – 5 p.m.

Stay tuned! The Cornucopia Institute, in partnership with other public interest groups, will shortly issue a more comprehensive action alert including talking points, information to submit written comments, sample letters and detailed instructions and help regarding appearing at the public hearings (including the precise location of each hearing).

We encourage other NGOs that would like to collaborate on this project to contact us. A number of other groups have also invested in developing an excellent knowledgebase and networking together will leverage our work on behalf of family farmers and consumers.

A copy of the USDA's Federal Register notice announcing the public hearings can be viewed on this action alert at The Cornucopia Institute website:

The Cornucopia Institute, a Wisconsin-based nonprofit farm policy research group, is dedicated to the fight for economic justice for the family-scale farming community. Their Organic Integrity Project acts as a corporate and governmental watchdog assuring that no compromises to the credibility of organic farming methods and the food it produces are made in the pursuit of profit. Cornucopia’s web page can be viewed

Mark A. Kastel
The Cornucopia Institute
608-625-2042 Voice
866-861-2214 Fax

P.O. Box 126
Cornucopia, Wisconsin 54827

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