UPDATE: FOOD SAFETY BILL FIGHT CONTINUES
Last week, the Senate passed S510, the Food Safety Modernization Act, with the Tester-Hagan amendment. Almost immediately, members of the House of Representatives raised objections that S510 includes provisions for user fees, which they argued were revenue raising provisions that violated the Constitutional requirement that all tax provisions originate in the House.
No one in the Senate apparently noticed this problem, yet unnamed House members supposedly spotted it within hours. Other bills that have originated in the Senate have included user fees and passed without objection. There may be Constitutional problems with the provisions, but it also may be a maneuver to stall the bill in order to make changes.
With the clock ticking on the lame duck session, the procedural objections might finally kill this bill. But don't count on it! The SAME day that the procedural objections were announced, Agribusiness lobby groups sent letters urging House members to conference S510 with HR 2749 (the House version), for the single specific purpose of stripping out the Tester-Hagan amendment. Until the procedural objections were raised, the House leadership had pledged to bring S510 to a vote without conferencing the bills. It's suspicious that the Agribusiness groups were prepared to immediately take advantage of the delay to try to remove the protections of the Tester-Hagan amendment.
To quote from Agribusiness: one letter was signed by produce industry groups, which represent the majority of fresh fruits and vegetables sold in the United States, while the second letter was sent by organizations that represent the vast majority of growers, producers, shippers, distributors, processors, packers, and wholesalers. In other words, these lobby groups represent the industrial food system that has been the source of the problems. Yet they are working to convince House members to impose the same regulations on local farmers market producers as on their huge corporate operations.
To be clear, we dont think S.510 is a good bill even with the Tester-Hagan amendment. It increases FDA's power, which will undoubtedly lead to even more battles between FDA and local food producers and consumers. FDA has abused the powers it already has, and that will almost certainly continue, with or without this bill. But as bad as the bill is now, it would be even worse without the amendment.
Agribusiness's real concern about the Tester-Hagan amendment isn't food safety, but the precedent set by having Congress recognize that small, direct-marketing producers are different, and should be regulated differently, from the large Agribusinesses.
TAKE ACTION
Please CALL or EMAIL your Congressman! You can call the Capitol Switchboard at (202) 224-3121 or go to http://www.house.gov/htbin/zipfind to find their website (if the phone lines are busy, the best way to reach them is through the Contact page on their website)
Message: My name is ____, and I am a constituent who is concerned that FDA will abuse its new authority under the food safety bill to hurt small farmers and local food producers. IF the food safety bill passes, it's critical that it at least include the Tester-Hagan amendment to protect small-scale producers from the regulations for hazard analysis plans and growing and harvesting standards. And whether this bill passes or not, I want my Congressman to take steps to rein in the FDA's abuses, through limiting appropriations and overseeing the agency's rulemaking. I would like to talk with you more about this, please call me back at ________.
MORE INFORMATION
The structure and language of the Tester-Hagan amendment is complex because every piece of this amendment was fiercely fought by the opponents. To be understood, the amendment needs to be read in the context of S510 and the existing background law, including the 2002 Bioterrorism Act.
Here are some of the key provisions of the amendment:
* For farmers selling fresh fruits and vegetables: if the producer grosses under half a million dollars, adjusted for inflation, and sells at least half of their produce directly to qualified end users (see below), then the farmer is exempt from the produce safety standards (i.e. regulations in which FDA would tell farmers how to grow and harvest their crops). See pages 16-19 of the amendment. Note that the FDA has already started working on these growing and harvesting standards, and claims that the existing law -- without S510 or Tester-Hagan -- gives it authority to impose the standards on ALL farmers.
* For farmers and producers who sell processed or value-added foods: if they sell more than half of their products directly to individual consumers, they do not have to register with the FDA nor develop a hazard analysis plan. This is due to the provision entitled clarification of intent that directs FDA how to define retail food establishments, see pages 1-2 of the amendment.
* For farmers and producers who sell processed or value-added foods, but do not sell more than half of their products directly to individual consumers: they are ALREADY under a legal requirement to register with the FDA due to the 2002 Bioterrorism Act. The Tester-Hagan amendment provides that these producers can avoid having to comply with S510s extensive requirements for hazard analysis plans by:
1) Submitting documentation that they gross under half a million dollars, adjusted for inflation, and sell more than half their products directly to qualified end users (see below), and
2) EITHER providing documentation that they comply with state and local laws such as a copy of their commercial kitchen license OR preparing a simplified hazard plan. See pages 5-6 (the or is found on line 4 of page 6)
* Qualified end users are (a) individual consumers, WITHOUT any restriction on their location or proximity to the producer, and (b) restaurants and retail food establishments that are either in-state OR within 275 miles. The farmers and producers will NOT have to ask individual consumers where they come from. See pages 7-8 & 18.
* The $500,000 limit on the exemptions is adjusted for inflation. See page 5, lines 13-14, and page 16, line 12
* The amendment also directs FDA to conduct a study that would, for the first time, look at the issues of scale and type of processes in relation to foodborne illness. The directive to do a study is the first attempt to get data to show that smaller-scale producers who don't commingle their products and who do less processing and transportation produce safer food. The bill does NOT mandate that any individual person hand over the information to the government. The FDA is also directed to use the results of the study to define very small businesses that will also be exempt from the hazard analysis plan requirements.
You can read the Tester-Hagan amendment for yourself at http://tester.senate.gov/Legislation/upload/tester_amendment_agreement.pdf
Tuesday, December 7, 2010
Monday, November 22, 2010
Update on Food Safety Legislation
Agribusiness shows its true colors!
Last week, the Senate voted 74-25 to move to consideration of S.510, the Food Safety Modernization Act. After thirty hours of debate and behind-the-scenes negotiations, the Senators released a final Managers Amendment that includes a compromise version of the Tester-Hagan amendment. Thank you to all our members who have called and written over the last several months to help protect local foods!
But even though an agreement was reached on the Tester-Hagan amendment last week, the issue is still not over. The final vote on the bill has been delayed until Monday, November 29, due to disagreements over amendments relating to the health care bill and a ban on earmarks. And, in the meantime, Agribusiness has shown its true colors.
For over a year, the big Agribusiness trade organizations have supported passage of S.510. From Agribusinesss perspective, the bill was a win-win: they could absorb the costs of the regulations because of their size; they'd gain good PR for supposedly improving food safety practices; and the competition created by local food producers, which is rapidly growing, would be crushed by the regulatory burdens.
This was only speculation until now. But when the Senators agreed to include the Tester-Hagan amendment in the bill, to exempt small-scale direct-marketing producers from some of the most burdensome provisions, twenty Agribusiness trade organizations fired off a letter stating that they would now oppose the bill.
The letter from the Agribusiness groups states: [B]y incorporating the Tester amendment in the bill, consumers will be left vulnerable to the gaping holes and uneven application of the law created by these exemptions. In addition, it sets an unfortunate precedent for future action on food safety policy by Congress that science and risk-based standards can be ignored.
http://www.unitedfresh.org/assets/files/Letter%20on%20Passage%20of%20S%20%20510%20and%20Tester%20Amendment.pdf
What science and risk? No one has produced any data or evidence of any widespread problems caused by local producers and marketed directly to consumers. All of the major food-borne illness outbreaks have been caused by products that went through the long supply chains of Agribusiness.
Agribusinesss real concern about the Tester-Hagan amendment isn't food safety, but the precedent set by having Congress recognize that small, direct-marketing producers are different, and should be regulated differently than large Agribusinesses.
Agribusiness is trying to convince the Senators to pull the Tester-Hagan amendment back out. While the amendment is currently part of the Managers Package the amended version of the bill agreed to by six bipartisan sponsors nothing is certain until the actual vote.
ACTION TO TAKE
This Thanksgiving week, please take a moment to call or email your Senators to tell them to hold firm on KEEPING the Tester-Hagan amendment part of the bill.
You can call the Capitol Switchboard at 202-224-3121 or go to www.senate.gov to find their website (if the phone lines are busy, the best way to reach them is through the Contact Page on their website)
Last week, the Senate voted 74-25 to move to consideration of S.510, the Food Safety Modernization Act. After thirty hours of debate and behind-the-scenes negotiations, the Senators released a final Managers Amendment that includes a compromise version of the Tester-Hagan amendment. Thank you to all our members who have called and written over the last several months to help protect local foods!
But even though an agreement was reached on the Tester-Hagan amendment last week, the issue is still not over. The final vote on the bill has been delayed until Monday, November 29, due to disagreements over amendments relating to the health care bill and a ban on earmarks. And, in the meantime, Agribusiness has shown its true colors.
For over a year, the big Agribusiness trade organizations have supported passage of S.510. From Agribusinesss perspective, the bill was a win-win: they could absorb the costs of the regulations because of their size; they'd gain good PR for supposedly improving food safety practices; and the competition created by local food producers, which is rapidly growing, would be crushed by the regulatory burdens.
This was only speculation until now. But when the Senators agreed to include the Tester-Hagan amendment in the bill, to exempt small-scale direct-marketing producers from some of the most burdensome provisions, twenty Agribusiness trade organizations fired off a letter stating that they would now oppose the bill.
The letter from the Agribusiness groups states: [B]y incorporating the Tester amendment in the bill, consumers will be left vulnerable to the gaping holes and uneven application of the law created by these exemptions. In addition, it sets an unfortunate precedent for future action on food safety policy by Congress that science and risk-based standards can be ignored.
http://www.unitedfresh.org/assets/files/Letter%20on%20Passage%20of%20S%20%20510%20and%20Tester%20Amendment.pdf
What science and risk? No one has produced any data or evidence of any widespread problems caused by local producers and marketed directly to consumers. All of the major food-borne illness outbreaks have been caused by products that went through the long supply chains of Agribusiness.
Agribusinesss real concern about the Tester-Hagan amendment isn't food safety, but the precedent set by having Congress recognize that small, direct-marketing producers are different, and should be regulated differently than large Agribusinesses.
Agribusiness is trying to convince the Senators to pull the Tester-Hagan amendment back out. While the amendment is currently part of the Managers Package the amended version of the bill agreed to by six bipartisan sponsors nothing is certain until the actual vote.
ACTION TO TAKE
This Thanksgiving week, please take a moment to call or email your Senators to tell them to hold firm on KEEPING the Tester-Hagan amendment part of the bill.
You can call the Capitol Switchboard at 202-224-3121 or go to www.senate.gov to find their website (if the phone lines are busy, the best way to reach them is through the Contact Page on their website)
Saturday, October 2, 2010
Action Alert Regarding Food Safety Legislation
URGENT ACTION ALERT
FOOD SAFETY LEGISLATION MOVING TOWARDS SENATE VOTE
The Senate has returned home without voting on S.510, the Food Safety Modernization Act, but unfortunately the bill is still alive. Before returning home, the Senate started the process to bring S.510 to the floor for a vote, and it is likely that they will finally vote on it shortly after they re-convene on November 15.
This bill greatly expands FDAs authority over both processed foods and fresh fruits and vegetables, and would give FDA authority to impose extensive, burdensome requirements on even the smallest processing facilities and farms who sell to local consumers.
We need the Tester-Hagan amendment to protect our vulnerable local businesses!
The Senators are back in their home States for the election season. This is an important time to publicize this issue and get their commitment to support the Tester-Hagan amendment!
ACTION TO TAKE
1) Contact your Senators local office. You can find your Senators contact information at www.Senate.gov . Call and ask them if the Senator will be attending any events near you, so that you can meet with them.
Urge your Senators to:
a)Support the Tester-Hagan amendment to exempt small-scale, local producers, AND
b)Oppose the addition of criminal penalties unless there is actual harm to human health
2)Educate your community by writing a letter to the editor. See the sample below
SAMPLE LETTER TO THE EDITOR
NOTE: It is VERY important to write your own, personal letter to the editor. Newspapers will NOT print form letters! The letter below is simply to provide you with some ideas. Remember to keep your letter short (100-150 words) and try to connect it with you, your family, and/or your community.
Dear Editor:
The U.S. Senate is likely to vote on a Food Safety bill (S. 510) when it reconvenes after the election. Unfortunately, as the bill is currently written, small local farms and processing facilities will come under a sweeping new industrial regulatory standard that threatens to put many of them out of the food business. These small producers provide food for our local community through CSAs, farmers markets, and local co-ops.
Sen. Jon Tester (MT), with Sen. Kay Hagan (NC), has an amendment to exempt small, direct-marketing farms and facilities. This amendment is critical to protecting local food systems and giving consumers a choice to buy fresh local products. It would be counter-productive and deeply disturbing if a bill designed to curb the abuses of Big Agribusiness snuffs out local food businesses as an "unintended consequence." Please call your Senators to urge them to vote for the Tester-Hagan amendment.
Signed,
Name
City, State
MORE INFORMATION
All of the well-publicized incidents of contamination in recent years including the recent egg recall occurred in industrialized food supply chains that span national and even international boundaries. The food safety problems in this system can and should be addressed without harming the local food systems that provide an alternative for consumers.
The growing trend toward healthy, fresh, locally sourced vegetables, fruit, dairy, and value-added products improves food safety by providing the opportunity for consumers to know their farmers and processors, to choose products on the basis of that relationship, and to readily trace any problems should they occur.
Farmers and processors who sell directly to consumers and end users have a direct relationship with their customers that ensures quality, safety, transparency and accountability. In addition, small-scale food producers are already regulated by local and state authorities, and the potential risk their products pose is inherently limited by their size. For these farmers and processors, new federal requirements are unnecessary and would simply harm both the food producers and their consumers.
Although S. 510 includes some provisions for flexibility for small and diversified producers and processors, the bills new hazard analysis and risk-based preventive controls would affect these facilities and authorize FDA to dictate growing and harvesting practices for produce. These requirements will impose significant expenses and burdens on individuals and small businesses.
Below are answers to some of the frequently asked questions.
QUESTION: What would S.510 do to farmers?
S.510 authorizes FDA to issue standards for production and harvesting of fruits and vegetables. Given the agencys track record, it is likely that the regulations will discriminate against small, organic, and diversified farms. While the bill directs FDA to consider the impact of its rulemaking on small-scale and diversified farms, there are few enforceable limits to protect small, sustainable farms from inappropriate and burdensome federal rules.
The only enforceable limit is that FDA's new regulations cannot contradict the regulations for certified organic producers. But many local food producers are not certified organic. And even certified organic can still be subject to additional regulations by FDA imposing impractical or unfair burdens, so long as the regulations dont directly contradict the organic regulations.
The Tester-Hagan amendment would exempt farms that have gross sales under $500,000 and that sell more than half of their produce directly to consumers and other qualified end users such as local restaurants and local stores.
QUESTION: Are direct marketing farms exempt from the bill?
No, direct-marketing farmers are not exempt from the produce safety standards. Under the bill as currently written, all farmers raising produce are subject to the produce safety standards (section 105 of the bill), regardless of how they market their fruits and vegetables.
The Tester-Hagan amendment is needed to protect direct marketing produce farmers from being told how to grow and harvest their crops by FDA bureaucrats.
QUESTION: What does S.510 require of people who process food?
Under S.510, anyone who processes food for sale would have to comply with extensive new regulations over every step of its process. This includes people who make such things as jam, bread, and cheese for local markets. S. 510 would require that all facilities would have to comply with a Hazard Analysis and Risk-Based Preventative Controls, which would require:
--Hazard analysis: Identify and evaluate known or reasonable hazards and develop written analysis of the hazards.
--Preventive Controls: Identify and implement preventive controls, to provide assurances that hazards indentified will be significantly minimized and prevented.
--Monitor effectiveness of the preventive controls.
--Establish procedures that a facility would implement if the preventive controls are found to be ineffective through monitoring.
--Verify that the preventive controls are adequate; that monitoring is in accordance with 103(d); that the owner is making appropriate decisions about corrective actions under 103(e); that the preventive controls are effectively and significantly minimizing or preventing the occurrence of identified hazards, including the use of environmental and product testing programs; that there is documented, periodic reanalysis of the plan to ensure that it is still relevant.
--Recordkeeping: Maintain, for not less than two years, records documenting the monitoring of the preventive controls implemented, instances of nonconformance, the results of testing, instances of corrective actions, and the efficacy of preventive controls.
--Written plan and documentation: Prepare a written plan that documents and describes the procedures used by the facility to comply with the requirements of this section, including analyzing the hazards under subsection 103(b) and identifying the preventive controls adopted under subsection 103(c) to address those hazards.
All of this would be subject to FDA approval, inspections, and fees for re-inspection. The paperwork burdens would drive many small-scale processors out of business.
The Tester-Hagan amendment would exempt processors that have gross sales under $500,000 and that sell more than half of their products directly to consumers and other qualified end users such as local restaurants and local stores. The amendment also exempts very small businesses, to be defined by FDA.
QUESTION: I heard that S.510 doesnt require anyone to register who isnt already required to do so. Is that true?
Technically, S.510 does not change the law on registration. But, in practical terms, there are thousands of small-scale processors who are not even aware that they have to register who will now be subject to extensive new requirements.
In 2002, Congress required all food facilities to register with the FDA under the Public Health Security and Bioterrrorism Preparedness and Bioterrorism Response Act of 2002. The rationale for such a sweeping federal reach into the smallest of food facilities was national security and bioterrorism.
While S.510 does not add new registration requirements, the reality is that there are many small-scale facilities that have not registered and are probably unaware that they are required to do so. FDA estimates that there are 37,000 facilities that have not yet registered.
In addition, S. 510 superimposes a significant regulatory burden on all of those facilities, regardless of the need from a food safety perspective. It is one thing to require a small-scale processor to register with the FDA; it is entirely different to require that small-scale processor to comply with extensive regulations on every step of its business. Small-scale producer and facilities that sell direct to consumers are inherently transparent and accountable and do not require federal oversight. Such facilities are already sufficiently regulated by state and local authorities.
QUESTION: Are direct marketing food processors exempt from the bill?
It depends. Based on FDAs guidance documents, food processors who market directly to individual consumers might be exempt from the requirements for HACCP-type programs. But the language is far from clear.
The bills provisions for facilities are dependent on the definition of facility under the 2002 Bioterrorism Act, which exempted retail food establishments from being categorized as facilities, but did not define the term. FDAs definition of the term does not address the majority of our local food producers. The specific examples of retail food establishments are establishments such as grocery stores, convenience stores, and vending machine locations. Not only are farmers markets, farm stands, and CSAs not listed, but they may not qualify because they typically sell food at a different physical location than where the food is held, packed, or processed. Consider the typical example of a small-scale processor who buys local ingredients and makes jams, breads, cheeses, etc. to sell at the farmers market. It may be that the farmers market itself qualifies as a "retail food establishment" -- but the commercial kitchen where the goods were prepared would not qualify, because the main purpose of that location is to process food, not sell to consumers. Different physical locations may mean different requirements under the FDAs definitions.
In addition, the current definitions specifically limit the exemption to producers who sell directly to individual consumers. It excludes producers who sell directly to end users such as restaurants, local grocers, and schools. So many food producers who provide healthy, safe foods to these institutions would be subject to the extensive new regulations under S.510.
The Tester Hagan amendment would do two things: (1) it would clarify that people selling directly to individual consumers are exempt, even if the physical location of the sale is different from the physical location of the processing; and (2) it would add a new exemption for processors who gross less than $500,000 and who sell directly to both individual consumers and other end-users such as local restaurants and local stores.
QUESTION: Does S. 510 help small farmers and local food producers?
No. The bill does include provisions to try to reduce the burdens that will be imposed on small producers, such as providing for longer deadlines for compliance and directing FDA to consider various issues facing organic farms and small businesses. But none of these actually prevent FDA from imposing new, burdensome requirements. The provisions essentially tell FDA to be nice to local food producers, but do not create enforceable limits on the agency's power.
IN SUMMARY: The Tester-Hagan amendment is a reasonable way to protect small-scale businesses from overly burdensome and unnecessary regulations, and thus also protect consumers options to buy from local producers whom they trust.
FOOD SAFETY LEGISLATION MOVING TOWARDS SENATE VOTE
The Senate has returned home without voting on S.510, the Food Safety Modernization Act, but unfortunately the bill is still alive. Before returning home, the Senate started the process to bring S.510 to the floor for a vote, and it is likely that they will finally vote on it shortly after they re-convene on November 15.
This bill greatly expands FDAs authority over both processed foods and fresh fruits and vegetables, and would give FDA authority to impose extensive, burdensome requirements on even the smallest processing facilities and farms who sell to local consumers.
We need the Tester-Hagan amendment to protect our vulnerable local businesses!
The Senators are back in their home States for the election season. This is an important time to publicize this issue and get their commitment to support the Tester-Hagan amendment!
ACTION TO TAKE
1) Contact your Senators local office. You can find your Senators contact information at www.Senate.gov . Call and ask them if the Senator will be attending any events near you, so that you can meet with them.
Urge your Senators to:
a)Support the Tester-Hagan amendment to exempt small-scale, local producers, AND
b)Oppose the addition of criminal penalties unless there is actual harm to human health
2)Educate your community by writing a letter to the editor. See the sample below
SAMPLE LETTER TO THE EDITOR
NOTE: It is VERY important to write your own, personal letter to the editor. Newspapers will NOT print form letters! The letter below is simply to provide you with some ideas. Remember to keep your letter short (100-150 words) and try to connect it with you, your family, and/or your community.
Dear Editor:
The U.S. Senate is likely to vote on a Food Safety bill (S. 510) when it reconvenes after the election. Unfortunately, as the bill is currently written, small local farms and processing facilities will come under a sweeping new industrial regulatory standard that threatens to put many of them out of the food business. These small producers provide food for our local community through CSAs, farmers markets, and local co-ops.
Sen. Jon Tester (MT), with Sen. Kay Hagan (NC), has an amendment to exempt small, direct-marketing farms and facilities. This amendment is critical to protecting local food systems and giving consumers a choice to buy fresh local products. It would be counter-productive and deeply disturbing if a bill designed to curb the abuses of Big Agribusiness snuffs out local food businesses as an "unintended consequence." Please call your Senators to urge them to vote for the Tester-Hagan amendment.
Signed,
Name
City, State
MORE INFORMATION
All of the well-publicized incidents of contamination in recent years including the recent egg recall occurred in industrialized food supply chains that span national and even international boundaries. The food safety problems in this system can and should be addressed without harming the local food systems that provide an alternative for consumers.
The growing trend toward healthy, fresh, locally sourced vegetables, fruit, dairy, and value-added products improves food safety by providing the opportunity for consumers to know their farmers and processors, to choose products on the basis of that relationship, and to readily trace any problems should they occur.
Farmers and processors who sell directly to consumers and end users have a direct relationship with their customers that ensures quality, safety, transparency and accountability. In addition, small-scale food producers are already regulated by local and state authorities, and the potential risk their products pose is inherently limited by their size. For these farmers and processors, new federal requirements are unnecessary and would simply harm both the food producers and their consumers.
Although S. 510 includes some provisions for flexibility for small and diversified producers and processors, the bills new hazard analysis and risk-based preventive controls would affect these facilities and authorize FDA to dictate growing and harvesting practices for produce. These requirements will impose significant expenses and burdens on individuals and small businesses.
Below are answers to some of the frequently asked questions.
QUESTION: What would S.510 do to farmers?
S.510 authorizes FDA to issue standards for production and harvesting of fruits and vegetables. Given the agencys track record, it is likely that the regulations will discriminate against small, organic, and diversified farms. While the bill directs FDA to consider the impact of its rulemaking on small-scale and diversified farms, there are few enforceable limits to protect small, sustainable farms from inappropriate and burdensome federal rules.
The only enforceable limit is that FDA's new regulations cannot contradict the regulations for certified organic producers. But many local food producers are not certified organic. And even certified organic can still be subject to additional regulations by FDA imposing impractical or unfair burdens, so long as the regulations dont directly contradict the organic regulations.
The Tester-Hagan amendment would exempt farms that have gross sales under $500,000 and that sell more than half of their produce directly to consumers and other qualified end users such as local restaurants and local stores.
QUESTION: Are direct marketing farms exempt from the bill?
No, direct-marketing farmers are not exempt from the produce safety standards. Under the bill as currently written, all farmers raising produce are subject to the produce safety standards (section 105 of the bill), regardless of how they market their fruits and vegetables.
The Tester-Hagan amendment is needed to protect direct marketing produce farmers from being told how to grow and harvest their crops by FDA bureaucrats.
QUESTION: What does S.510 require of people who process food?
Under S.510, anyone who processes food for sale would have to comply with extensive new regulations over every step of its process. This includes people who make such things as jam, bread, and cheese for local markets. S. 510 would require that all facilities would have to comply with a Hazard Analysis and Risk-Based Preventative Controls, which would require:
--Hazard analysis: Identify and evaluate known or reasonable hazards and develop written analysis of the hazards.
--Preventive Controls: Identify and implement preventive controls, to provide assurances that hazards indentified will be significantly minimized and prevented.
--Monitor effectiveness of the preventive controls.
--Establish procedures that a facility would implement if the preventive controls are found to be ineffective through monitoring.
--Verify that the preventive controls are adequate; that monitoring is in accordance with 103(d); that the owner is making appropriate decisions about corrective actions under 103(e); that the preventive controls are effectively and significantly minimizing or preventing the occurrence of identified hazards, including the use of environmental and product testing programs; that there is documented, periodic reanalysis of the plan to ensure that it is still relevant.
--Recordkeeping: Maintain, for not less than two years, records documenting the monitoring of the preventive controls implemented, instances of nonconformance, the results of testing, instances of corrective actions, and the efficacy of preventive controls.
--Written plan and documentation: Prepare a written plan that documents and describes the procedures used by the facility to comply with the requirements of this section, including analyzing the hazards under subsection 103(b) and identifying the preventive controls adopted under subsection 103(c) to address those hazards.
All of this would be subject to FDA approval, inspections, and fees for re-inspection. The paperwork burdens would drive many small-scale processors out of business.
The Tester-Hagan amendment would exempt processors that have gross sales under $500,000 and that sell more than half of their products directly to consumers and other qualified end users such as local restaurants and local stores. The amendment also exempts very small businesses, to be defined by FDA.
QUESTION: I heard that S.510 doesnt require anyone to register who isnt already required to do so. Is that true?
Technically, S.510 does not change the law on registration. But, in practical terms, there are thousands of small-scale processors who are not even aware that they have to register who will now be subject to extensive new requirements.
In 2002, Congress required all food facilities to register with the FDA under the Public Health Security and Bioterrrorism Preparedness and Bioterrorism Response Act of 2002. The rationale for such a sweeping federal reach into the smallest of food facilities was national security and bioterrorism.
While S.510 does not add new registration requirements, the reality is that there are many small-scale facilities that have not registered and are probably unaware that they are required to do so. FDA estimates that there are 37,000 facilities that have not yet registered.
In addition, S. 510 superimposes a significant regulatory burden on all of those facilities, regardless of the need from a food safety perspective. It is one thing to require a small-scale processor to register with the FDA; it is entirely different to require that small-scale processor to comply with extensive regulations on every step of its business. Small-scale producer and facilities that sell direct to consumers are inherently transparent and accountable and do not require federal oversight. Such facilities are already sufficiently regulated by state and local authorities.
QUESTION: Are direct marketing food processors exempt from the bill?
It depends. Based on FDAs guidance documents, food processors who market directly to individual consumers might be exempt from the requirements for HACCP-type programs. But the language is far from clear.
The bills provisions for facilities are dependent on the definition of facility under the 2002 Bioterrorism Act, which exempted retail food establishments from being categorized as facilities, but did not define the term. FDAs definition of the term does not address the majority of our local food producers. The specific examples of retail food establishments are establishments such as grocery stores, convenience stores, and vending machine locations. Not only are farmers markets, farm stands, and CSAs not listed, but they may not qualify because they typically sell food at a different physical location than where the food is held, packed, or processed. Consider the typical example of a small-scale processor who buys local ingredients and makes jams, breads, cheeses, etc. to sell at the farmers market. It may be that the farmers market itself qualifies as a "retail food establishment" -- but the commercial kitchen where the goods were prepared would not qualify, because the main purpose of that location is to process food, not sell to consumers. Different physical locations may mean different requirements under the FDAs definitions.
In addition, the current definitions specifically limit the exemption to producers who sell directly to individual consumers. It excludes producers who sell directly to end users such as restaurants, local grocers, and schools. So many food producers who provide healthy, safe foods to these institutions would be subject to the extensive new regulations under S.510.
The Tester Hagan amendment would do two things: (1) it would clarify that people selling directly to individual consumers are exempt, even if the physical location of the sale is different from the physical location of the processing; and (2) it would add a new exemption for processors who gross less than $500,000 and who sell directly to both individual consumers and other end-users such as local restaurants and local stores.
QUESTION: Does S. 510 help small farmers and local food producers?
No. The bill does include provisions to try to reduce the burdens that will be imposed on small producers, such as providing for longer deadlines for compliance and directing FDA to consider various issues facing organic farms and small businesses. But none of these actually prevent FDA from imposing new, burdensome requirements. The provisions essentially tell FDA to be nice to local food producers, but do not create enforceable limits on the agency's power.
IN SUMMARY: The Tester-Hagan amendment is a reasonable way to protect small-scale businesses from overly burdensome and unnecessary regulations, and thus also protect consumers options to buy from local producers whom they trust.
Monday, September 27, 2010
Organic Valley's Anti-Raw Milk Policy
This just in from the Weston A. Price society:
INFORMATION UPDATE
ORGANIC VALLEYS ANTI-RAW MILK POLICY
Dear Members,
As many of you may have already heard, the CROPP cooperative, producer of dairy products and other foodstuffs under the Organic Valley (OV) and Organic Prairie labels, voted at their May 13 board meeting to prohibit any of the CROPP farmer members from selling raw milk as a side business. The vote was a close onefour in favor, three againstreflecting the division of opinion among the CROPP board members themselves. After the Board vote, the cooperative took the decision to their Dairy Executive Committee (DEC) for further discussion and another vote. The result was a split, 20 votes in favor and 20 against. This policy is to take effect January 1, 2011.
We at WAPF did not immediately publicize this new policy, instead writing privately to CROPP CEO George Siemon and the members of the board, urging them to reconsider and take the issue back to the board for further discussion and another vote. In our letter, we addressed some of what we felt were misguided issues that led to the cooperatives anti-raw milk stance, such as potential liability to CROPP and marketplace competition, pointing out that these were grossly inflated and not legitimate concerns; we noted the potential downside to CROPPs reputation as a supporter of family farms; and, most importantly, we pointed out that the new policy would impose severe economic hardship on many farmers, farmers the co-op was founded to protect. (For a discussion and rebuttal of CROPPs concerns about raw milk, see below.)
Many of CROPPs farmers have high levels of debt, and they have, over the past few years, faced new financial burdens with lower pay prices and quotas that CROPP had in place for the past yearin some cases amounting to a 30 percent reduction in income. Their financial situation is recovering somewhat now, but many are challenged to make up for past losses.
Many of their farmers had active raw milk businesses established before they even joined the cooperative, many operating in states where the enterprise is unquestionably legal. Others developed raw milk customers after their incomes droppedallowing these farms to remain solvent. The new policy will force these farmers to choose between remaining a CROPP member or selling raw milk exclusively, either of which will likely lead to severe financial stress or even bankruptcy and possible loss of the family farm.
Despite our grave concerns, I received a response from George Siemon dated June 21, 2010, stating that the anti-raw milk policy would remain in effect. In the letter, Siemon insisted that CROPP is not against raw milk, and that we are standing on the same side of the river in supporting organic and local food, agricultural reform and corporate reform.
Is that true? CROPP did indeed start small, as a local cooperative of just a few dozen vegetable farmers, the Coulee Region Organic Produce Pool. The co-ops seven dairy producers soon branched out from produce to include cheese and eventually other dairy products. Unfortunately, in so doing, they opted for the industrial model. Instead of producing what consumers were asking fordairy products as natural as possible, such as low-temperature, non-homogenized milkCROPP chose to market ultra-high temperature (UHT), homogenized industrial-style milk and cream. (UHT processing takes milk to 230 degrees F, way above the boiling point, thereby killing every enzyme and immune-supporting factor in the milk.) When they branched out into eggs, they chose the industrial organic confinement model, instead of pastured poultry, something their grass-based farmers were perfectly positioned to do. Their raw cheese is actually heated to above 150 degrees. They also sell an Organic Valley brand of soy milk.
We then further delayed making any announcement about the OV decision because we were working behind the scenes with representatives of the co-op, and hoping that OV would reconsider. However, at their most recent board meeting, the board voted 7-0 that raw milk sales by their producers must not exceed 1 percent of their volume, and must be limited to family, friends and neighbors. While some board members have insisted that this anti-raw milk policy will not be enforced, we hear from others in the organization that OV is planning to strenuously enforce the policy.
In any event, for the average OV farmer, 1 percent is probably about three to six gallons per day, so the updated policy merely puts a gloss on the original anti-raw milk stance. The new policy will mean that thousands of consumers who need raw milk for their own and their childrens health will no longer be able to obtain it.
Ironically, the $12 billion dairy industry giant, Dean Foods, which owns the Horizon Organic label, the largest conventional and organic dairy producer in the United States, has specifically stated that its farmers are free to sell or provide raw milk on the side. Dean Foods/Horizon the good guys and Organic Valley hurting family farmersthis picture seems upside down.
This isn't the first time CROPP seems to have lost its bearings. A couple of years ago, the management opted to buy some of their milk from a 7200-cow industrial dairy located in an arid part of Texas, until some of their farmer-members found out and put an end to the lunacyboth their farmers and consumers saw the move as a violation of trust. Organic Valley has always represented itself as being pro-family farmertheir management shouldn't need to be reminded that a 7200-cow dairy is not a family farm!
Just as in the case of buying from factory farms, we hope CROPP farmer leadership will come to their senses and rescind their destructive anti-raw milk policy.
The unfortunate decision by the CROPP board should galvanize all of us to renew our efforts to purchase as much of our food as possible directly from local farmers; if your only choice for dairy foods and eggs is the local health food store or cooperative, make a point of purchasing from the local dairy producers listed in our Shopping Guide. Farmer-friendly brands such as Natural by Nature and farmstead dairy producers such as Traders Point Creamery, among many others, are highly rated in The Cornucopia Institute's organic dairy scorecard (ratings of all 120 organic brands www.cornucopia.org) and deserve our food dollars. Another good choice is to purchase raw grass-fed butter from one of our many advertisers in Wise Traditions and have it shipped to you.
If the farm family you get your raw milk from faces the dilemma of choosing between CROPP and direct raw milk sales, please express your support for them and do everything you can to help them choose the latter. You can help them build their customer base, reduce their expenses by offering help on the farm, and even provide the funding and financial advice they may desperately need to make the transition. The Farm-to-Consumer Legal Defense Fund can help assist with advice and model cow-share and herd-share agreements.
If you feel betrayed by a cooperative that you had always considered to be an ally, you can also visit their website, www.organicvalley.coop, and let them know how you feel. Maybe if they hear from enough of us, they will realize the damage they are doing to their brands reputation. Please consider forwarding this message to your friends and family members who might also want to convey their feelings to Organic Valley management.
Above all, lets all make the pledge to vote with our pocketbooks in support of small farmers and artisan producers instead of large commercial dairy interests that put their profits before the interests of the hard-working farmers who produce their milk and other commodities.
Sincerely yours,
Sally Fallon Morell, President
The Weston A. Price Foundation
ORGANIC VALLEYS ANTI-RAW MILK POLICY
Dear Members,
As many of you may have already heard, the CROPP cooperative, producer of dairy products and other foodstuffs under the Organic Valley (OV) and Organic Prairie labels, voted at their May 13 board meeting to prohibit any of the CROPP farmer members from selling raw milk as a side business. The vote was a close onefour in favor, three againstreflecting the division of opinion among the CROPP board members themselves. After the Board vote, the cooperative took the decision to their Dairy Executive Committee (DEC) for further discussion and another vote. The result was a split, 20 votes in favor and 20 against. This policy is to take effect January 1, 2011.
We at WAPF did not immediately publicize this new policy, instead writing privately to CROPP CEO George Siemon and the members of the board, urging them to reconsider and take the issue back to the board for further discussion and another vote. In our letter, we addressed some of what we felt were misguided issues that led to the cooperatives anti-raw milk stance, such as potential liability to CROPP and marketplace competition, pointing out that these were grossly inflated and not legitimate concerns; we noted the potential downside to CROPPs reputation as a supporter of family farms; and, most importantly, we pointed out that the new policy would impose severe economic hardship on many farmers, farmers the co-op was founded to protect. (For a discussion and rebuttal of CROPPs concerns about raw milk, see below.)
Many of CROPPs farmers have high levels of debt, and they have, over the past few years, faced new financial burdens with lower pay prices and quotas that CROPP had in place for the past yearin some cases amounting to a 30 percent reduction in income. Their financial situation is recovering somewhat now, but many are challenged to make up for past losses.
Many of their farmers had active raw milk businesses established before they even joined the cooperative, many operating in states where the enterprise is unquestionably legal. Others developed raw milk customers after their incomes droppedallowing these farms to remain solvent. The new policy will force these farmers to choose between remaining a CROPP member or selling raw milk exclusively, either of which will likely lead to severe financial stress or even bankruptcy and possible loss of the family farm.
Despite our grave concerns, I received a response from George Siemon dated June 21, 2010, stating that the anti-raw milk policy would remain in effect. In the letter, Siemon insisted that CROPP is not against raw milk, and that we are standing on the same side of the river in supporting organic and local food, agricultural reform and corporate reform.
Is that true? CROPP did indeed start small, as a local cooperative of just a few dozen vegetable farmers, the Coulee Region Organic Produce Pool. The co-ops seven dairy producers soon branched out from produce to include cheese and eventually other dairy products. Unfortunately, in so doing, they opted for the industrial model. Instead of producing what consumers were asking fordairy products as natural as possible, such as low-temperature, non-homogenized milkCROPP chose to market ultra-high temperature (UHT), homogenized industrial-style milk and cream. (UHT processing takes milk to 230 degrees F, way above the boiling point, thereby killing every enzyme and immune-supporting factor in the milk.) When they branched out into eggs, they chose the industrial organic confinement model, instead of pastured poultry, something their grass-based farmers were perfectly positioned to do. Their raw cheese is actually heated to above 150 degrees. They also sell an Organic Valley brand of soy milk.
We then further delayed making any announcement about the OV decision because we were working behind the scenes with representatives of the co-op, and hoping that OV would reconsider. However, at their most recent board meeting, the board voted 7-0 that raw milk sales by their producers must not exceed 1 percent of their volume, and must be limited to family, friends and neighbors. While some board members have insisted that this anti-raw milk policy will not be enforced, we hear from others in the organization that OV is planning to strenuously enforce the policy.
In any event, for the average OV farmer, 1 percent is probably about three to six gallons per day, so the updated policy merely puts a gloss on the original anti-raw milk stance. The new policy will mean that thousands of consumers who need raw milk for their own and their childrens health will no longer be able to obtain it.
Ironically, the $12 billion dairy industry giant, Dean Foods, which owns the Horizon Organic label, the largest conventional and organic dairy producer in the United States, has specifically stated that its farmers are free to sell or provide raw milk on the side. Dean Foods/Horizon the good guys and Organic Valley hurting family farmersthis picture seems upside down.
This isn't the first time CROPP seems to have lost its bearings. A couple of years ago, the management opted to buy some of their milk from a 7200-cow industrial dairy located in an arid part of Texas, until some of their farmer-members found out and put an end to the lunacyboth their farmers and consumers saw the move as a violation of trust. Organic Valley has always represented itself as being pro-family farmertheir management shouldn't need to be reminded that a 7200-cow dairy is not a family farm!
Just as in the case of buying from factory farms, we hope CROPP farmer leadership will come to their senses and rescind their destructive anti-raw milk policy.
The unfortunate decision by the CROPP board should galvanize all of us to renew our efforts to purchase as much of our food as possible directly from local farmers; if your only choice for dairy foods and eggs is the local health food store or cooperative, make a point of purchasing from the local dairy producers listed in our Shopping Guide. Farmer-friendly brands such as Natural by Nature and farmstead dairy producers such as Traders Point Creamery, among many others, are highly rated in The Cornucopia Institute's organic dairy scorecard (ratings of all 120 organic brands www.cornucopia.org) and deserve our food dollars. Another good choice is to purchase raw grass-fed butter from one of our many advertisers in Wise Traditions and have it shipped to you.
If the farm family you get your raw milk from faces the dilemma of choosing between CROPP and direct raw milk sales, please express your support for them and do everything you can to help them choose the latter. You can help them build their customer base, reduce their expenses by offering help on the farm, and even provide the funding and financial advice they may desperately need to make the transition. The Farm-to-Consumer Legal Defense Fund can help assist with advice and model cow-share and herd-share agreements.
If you feel betrayed by a cooperative that you had always considered to be an ally, you can also visit their website, www.organicvalley.coop, and let them know how you feel. Maybe if they hear from enough of us, they will realize the damage they are doing to their brands reputation. Please consider forwarding this message to your friends and family members who might also want to convey their feelings to Organic Valley management.
Above all, lets all make the pledge to vote with our pocketbooks in support of small farmers and artisan producers instead of large commercial dairy interests that put their profits before the interests of the hard-working farmers who produce their milk and other commodities.
Sincerely yours,
Sally Fallon Morell, President
The Weston A. Price Foundation
Friday, September 17, 2010
Urgent Action Alert on S510 Food Safety Legislation
Although it has been delayed many times, the Food Safety Modernization Act (S.510) continues to be a threat. This bill greatly expands FDAs authority over both processed foods and fresh fruits and vegetables, and would give FDA authority to impose extensive, burdensome requirements on even the smallest processing facilities and farms who sell to local consumers.
While the latest version of the bill included some provisions for flexibility and scale-sensitivity, the provisions do not go far enough to protect the small-scale local food businesses that could be destroyed by the new federal regulations.
Take Action:
S.510 could be voted on in the next couple of weeks without much notice. So the time to call your Senators is NOW!
You can find your Senators contact information at www.Senate.gov or by calling the Capitol Switchboard at 202-224-3121 or toll-free at 877-210-5351. When you call your Senators offices, ask to speak to the staffer who handles food safety issues, and tell them these two things:
1) Support the Tester-Hagan amendment to exempt small-scale, direct marketing farms and facilities from some of the most burdensome portions of the bill. This common-sense amendment is critical to protecting local food sources.
2) Oppose criminal penalties for violations that do not endanger human health or safety: Although it is unclear, there may also be an amendment introduced to combine S.3767 (introduced by Senator Leahy) with S.510, which would create criminal penalties for knowingly introducing adulterated or misbranded food into interstate commerce. Adulterated or misbranded food could mean simply that the farmer or producer did not have all his paperwork in order or made a technical violation of some kind that does not endanger human health or safety.
Special Action for OKLAHOMA residents
Senator Coburn is blocking the passage of S.510 by unanimous consent, and has raised a lot of very good objections to the bill. Please call and THANK HIM for taking this stand. Call his DC office at 202-224-5754. You can read Senator Coburns statement at:
http://coburn.senate.gov/public/index.cfm/rightnow?ContentRecord_id=8df5cb89-91a2-4ae3-b846-7487db0bd4f0
SAMPLE EMAIL
Dear Senator ________:
As you consider sweeping new federal food safety legislation (S. 510, the Food Safety Modernization Act), please vote in support of common sense amendments offered by Senators Tester and Hagan to exempt small-scale direct marketing processing facilities from federal hazard analysis and control regulations and to exempt small-scale direct marketing farms from the produce safety standards. Local and state health and sanitation laws are enough for producers selling into local markets. These small-scale producers do not need and many may not survive new federal regulations.
In August, half a billion eggs were recalled to try to prevent the spread of salmonella that had originated on two related farms in Iowa. Those two farms had sold eggs under at least 25 different labels in 12 different states! The recall is symptomatic of the industrialized food system characterized by mega-farms and long, complex supply chains and distribution systems. This food system needs reform.
But without Senators Tester's and Hagans common sense amendment to S. 510, the bill actually hurts food safety by imposing FDA regulation on the local food businesses who provide consumers with an alternative to the industrialized food system. More and more people are seeking out local producers to buy fresh, wholesome foods from people they trust, and they dont need or want FDA to interfere.
I urge you to vote FOR the Tester-Hagan Amendment to S. 510!
I also urge you to vote against any attempt to create criminal penalties for adulterated or misbranded food. These terms as defined in S.510 could include minor technical violations that harm no one. Criminal violations should be limited to those who knowingly cause serious harm to human health or safety.
Signed,
Your name and state
***
While the latest version of the bill included some provisions for flexibility and scale-sensitivity, the provisions do not go far enough to protect the small-scale local food businesses that could be destroyed by the new federal regulations.
Take Action:
S.510 could be voted on in the next couple of weeks without much notice. So the time to call your Senators is NOW!
You can find your Senators contact information at www.Senate.gov or by calling the Capitol Switchboard at 202-224-3121 or toll-free at 877-210-5351. When you call your Senators offices, ask to speak to the staffer who handles food safety issues, and tell them these two things:
1) Support the Tester-Hagan amendment to exempt small-scale, direct marketing farms and facilities from some of the most burdensome portions of the bill. This common-sense amendment is critical to protecting local food sources.
2) Oppose criminal penalties for violations that do not endanger human health or safety: Although it is unclear, there may also be an amendment introduced to combine S.3767 (introduced by Senator Leahy) with S.510, which would create criminal penalties for knowingly introducing adulterated or misbranded food into interstate commerce. Adulterated or misbranded food could mean simply that the farmer or producer did not have all his paperwork in order or made a technical violation of some kind that does not endanger human health or safety.
Special Action for OKLAHOMA residents
Senator Coburn is blocking the passage of S.510 by unanimous consent, and has raised a lot of very good objections to the bill. Please call and THANK HIM for taking this stand. Call his DC office at 202-224-5754. You can read Senator Coburns statement at:
http://coburn.senate.gov/public/index.cfm/rightnow?ContentRecord_id=8df5cb89-91a2-4ae3-b846-7487db0bd4f0
SAMPLE EMAIL
Dear Senator ________:
As you consider sweeping new federal food safety legislation (S. 510, the Food Safety Modernization Act), please vote in support of common sense amendments offered by Senators Tester and Hagan to exempt small-scale direct marketing processing facilities from federal hazard analysis and control regulations and to exempt small-scale direct marketing farms from the produce safety standards. Local and state health and sanitation laws are enough for producers selling into local markets. These small-scale producers do not need and many may not survive new federal regulations.
In August, half a billion eggs were recalled to try to prevent the spread of salmonella that had originated on two related farms in Iowa. Those two farms had sold eggs under at least 25 different labels in 12 different states! The recall is symptomatic of the industrialized food system characterized by mega-farms and long, complex supply chains and distribution systems. This food system needs reform.
But without Senators Tester's and Hagans common sense amendment to S. 510, the bill actually hurts food safety by imposing FDA regulation on the local food businesses who provide consumers with an alternative to the industrialized food system. More and more people are seeking out local producers to buy fresh, wholesome foods from people they trust, and they dont need or want FDA to interfere.
I urge you to vote FOR the Tester-Hagan Amendment to S. 510!
I also urge you to vote against any attempt to create criminal penalties for adulterated or misbranded food. These terms as defined in S.510 could include minor technical violations that harm no one. Criminal violations should be limited to those who knowingly cause serious harm to human health or safety.
Signed,
Your name and state
***
Sunday, August 29, 2010
FTCLDF Labor Day Close-Out Sale!
This just in...the FTCLDF is clearing out some of their old t-shirts in their shop. Check it out:
We're making way for new merchandise! These limited production designs are all on closeout sale. Once inventory is sold, these designs will no longer be available. All proceeds support the Fund.
Regular cotton tees - $10
Organic cotton tees - $15
Shipping free for $75 or more
Adult (including some XXL), ladies fitted, youth, toddler and infant sizes are still available. Start shopping here or call 703-208-3276 10 am - 6 pm EDT to place your order over the phone.
This is your opportunity to scoop up favorites like Raw Milk Nation in metro blue or Raw Milk Nation - Fitted Ladies in navy or The Only Genuine Milk is Raw Milk in lavender.
Like slogans with an edge? These black and white Pasteurize the FDA Instead, The Revolution Will Not Be Pasteurized or Keep the Government Off Our Farms in sand might be for you!
You'll love the feel of these organic tees - try the Raw Milk - Nature's Perfect Food in mulberry, The Only Genuine Milk Is Raw Milk in navy Grass-fed Nation - Ladies or Grass-fed Nation - Mensin natural. They all look great with jeans.
Got love handles? Here's some styles in 2XL - Raw Milk Nation - Adult or Raw Milk Nation - Ladies Fit or Pasteurize the FDA or the original version of The Revolution Will Not Be Pasteurized
Here's a couple in long sleeve the classic I Love Raw Milk -Youth Long Sleeve.
Mothers and daughters like the Express Yourself - Drink Raw Milk - Girls or Mom's version Express Yourself - Drink Raw Milk - Ladies.
These I Love Raw Milk infant rompers are adorable and come in two colors - white/navy and turqouise/white. I Love Raw Milk Long Sleeve is great for toddlers.
We'd love if someone would buy these Got Asthma? Drink Raw Milk tees (super clearance priced at $8) and wear it at an American Lung Association event or walkathon. Any takers?
These designs will be lost forever, unless they are in your closet!
Thursday, August 12, 2010
Talk With Your Senators and Congressman
Talk With Your Senators and Congressman in Person!
- Tell your Senators to Amend or Oppose S. 510, the Food Safety Modernization Act
- and Tell Your Senators and Congressman to Support USDAs Proposed Rules for Fair Play in Livestock and Poultry Markets
An in-person meeting with your legislators is one of the best ways to make an impact on them. And you dont have to go to DC to do it! Congress is in recess from August 9th through September 10th, which means that the legislators are heading back to their home states and districts to meet with constituents and attend public events. Town hall meetings and other public events are great opportunities to ask questions and to inform policy makers and their staff of your concerns.
Find your legislators' public meetings schedules by calling their district office. Go to www.Congress.org and type in your zip code. In the column for President & Congress, click on the legislator's name, and then on the contact tab for the phone number for the district office. Call and request a meeting to talk about food safety and fairness for farmers. If the Senators and/or Congressman do not have time available for an individual meeting, ask their offices for a schedule of any town hall meetings and public events. Let them know you would like a moment to speak to your legislator about food safety and fairness for farmers at one of the events.
FOOD SAFETY BILL
S.510, the Food Safety Modernization Act, continues to be delayed. But pressure from consumer groups also continues to mount, and there will be yet another push to bring the bill to a vote when the Senate reconvenes in September. Even if you have already called and written about this bill, talking with your Senators during the August recess can make a difference!
S. 510 poses a very serious threat to the local, nutrient-dense food movement. Farmers would be subject to FDA regulation of how they grow and raise their crops, while processed food producers (including people making products such as cheese and kombucha) would be buried in the red tape of HACCP plans. The bill does not outlaw backyard gardens or organic methods, but the long-term effect will be to drive local food sources out of business through unnecessary burdensome regulations and deprive consumers of their options to buy healthy foods from producers they know and trust.
Tell your Senators that you want them to amend or oppose S. 510. Senator Tester (D-MT) continues to work on amendments to exempt local and small-scale producers from some of the worst provisions of the bill, and we need your Senators to support this effort!
Over 150 organizations have signed a letter of support for the Tester-Hagan amendments to exempt small-scale and local producers from the more burdensome provisions of the bill. You can borrow some talking points from the letter (posted at http://farmandranchfreedom.org/sff/Amend-S510-June-7 ) or use the ones below:
1. The major foodborne illness outbreaks and recalls have all been caused by the large, industrial food system. Small, local food producers have not contributed to the highly publicized outbreaks. Yet S. 510 subjects the small, local food system to the same, broad federal regulatory oversight that would apply to the industrial food system.
2. Increased regulations and record-keeping obligations could destroy small businesses that bring food to local communities. In particular, the reliance on hazard analysis and risk-based preventative controls, a concept similar to HACCP, will harm small food producers. HACCP has already proven to be an overwhelming burden for a significant number of small, regional meat processors across the country. Applying a HACCP-type system to small, local foods processors could drive them out of business, reducing consumers options to buy fresh, local foods.
3. FDA does not belong on the farm. S. 510 calls for FDA regulation of how farms grow and harvest produce. Given the agencys track record, it is likely that the regulations will discriminate against small, organic, and diversified farms. Although language calling for flexibility may be included, but there are no enforceable limits or protections for small diversified and organic farms from inappropriate and burdensome federal rules.
4. Food safety and security both come from a diversified, vibrant local food system. Local foods give consumers the choice to buy from producers they know, creating a transparent, accountable food system without federal government oversight. State and local laws, which are often size-specific rather than one-size-fits-all, are more appropriate for local food producers.
You can also get more information about the bill in our earlier action alerts, posted at http://realmilk.comwww.westonaprice.org/action-alerts/2010-alerts.html
SUPPORT FAIR PLAY FOR LIVESTOCK FARMERS
While youre talking with your Senators or at a meeting with your Congressman, ask them to stand with family farmers on fair competition and fair contracts.
Today, a tiny handful of meatpackers and poultry processors dominate the livestock industry, making it hard for an individual farmer or rancher to get a fair deal or equitable price for cattle, hogs, or chickens. Packers are able to use their monopoly-like power to manipulate prices paid to livestock producers. The U.S. Department of Agriculture is finally taking action, proposing rules to identify practices that are illegal under the Packers & Stockyards Act. These rules:
- Prohibit packers from selling livestock to each other
- Make it easier for ranchers to sue companies accused of using deceptive trade practices or offering unfairly low prices
- End discrimination against producers based upon size alone
- Restrict livestock buyers from buying for more than one packer
In addition, the rules contain improvements for contract pork and poultry growers.
The consolidation of the livestock markets in the hands of a few large corporations hurts everyone. Together with bad regulations, consolidation is one of the main reasons it is so hard for small farmers to find local slaughterhouses to process their animals independently. Consolidation also makes it harder to buy and sell animals at fair prices even if the farmer is raising meat for direct sales. Ultimately, all farmers and all consumers are impacted by the control the meat packers exert. So its important that we stand together and support fair markets for family farmers.
Urge your legislators to support the USDA proposed rules that restore competition and contract fairness to livestock and poultry markets. Tell them we need a level playing field for family farmers and ranchers. Ask them to contact USDA Secretary Tom Vilsack and let him know they support the proposed rule.
More information:
The Packers and Stockyards Act of 1921 makes it unlawful for meat packers and companies that contract with farmers to raise hogs and poultry from engaging in any "unfair, unjustly discriminatory, or deceptive practice or device," or to "make or give any undue or unreasonable preference or advantage." But, until now, USDA has never issued the regulations necessary to properly enforce the protections for livestock and poultry farmers. In the 2008 Farm Bill, a majority of the full Congress voted to direct USDA to define these prohibitions and to clarify how the Act should be applied to give individual farmers and ranchers a fair chance when dealing with the large corporate entities that control our nation's meat and poultry processing.
For more information on how the USDA rules help livestock producers, go to the Western Organization of Resource Councils (WORC) website: http://www.worc.org/Unduepref
For more information on how the USDA rules help poultry producers, go to the Rural Advancement Foundation International USA (RAFI) website: http://www.rafiusa.org/programs/contractag/gipsa2101rules.html
COLORADO MEETING ON CONSOLIDATION OF BEEF INDUSTRY
The USDA and the U.S. Department of Justice (DOJ) are holding hearings around the country on the issue of the lack of competition in livestock and poultry markets and potential anti-trust violations. The hearing on the beef cattle industry will take place in Colorado on Friday, Aug. 27, 2010. The official purpose of this meeting is to provide the DOJ and USDA with information on the state of the cattle industry. Unofficially, the meeting will show the agencies whether cattle producers and consumers demand that the government take immediate, aggressive action to restore competition to the U.S. cattle industry.
If you are within traveling distance, please come! Even if you don't speak, your attendance at this historic event will help send a powerful message to Washington, D.C.
WHEN: Friday, August 27, 2010, beginning at 8 am MDT
WHERE: Lory Student Center, 1101 Centre Avenue Mall, Fort Collins, Colorado, 80523
MORE INFORMATION: The Department of Justice has a page dedicated to the hearings at http://www.justice.gov/atr/public/workshops/ag2010/index.htm
TRAVEL: Several organizations are coordinating buses to the event and special room rates at a nearby hotel. For more information, please contact jerilynn@worc.org or sam@fwwatch.org
- Tell your Senators to Amend or Oppose S. 510, the Food Safety Modernization Act
- and Tell Your Senators and Congressman to Support USDAs Proposed Rules for Fair Play in Livestock and Poultry Markets
An in-person meeting with your legislators is one of the best ways to make an impact on them. And you dont have to go to DC to do it! Congress is in recess from August 9th through September 10th, which means that the legislators are heading back to their home states and districts to meet with constituents and attend public events. Town hall meetings and other public events are great opportunities to ask questions and to inform policy makers and their staff of your concerns.
Find your legislators' public meetings schedules by calling their district office. Go to www.Congress.org and type in your zip code. In the column for President & Congress, click on the legislator's name, and then on the contact tab for the phone number for the district office. Call and request a meeting to talk about food safety and fairness for farmers. If the Senators and/or Congressman do not have time available for an individual meeting, ask their offices for a schedule of any town hall meetings and public events. Let them know you would like a moment to speak to your legislator about food safety and fairness for farmers at one of the events.
FOOD SAFETY BILL
S.510, the Food Safety Modernization Act, continues to be delayed. But pressure from consumer groups also continues to mount, and there will be yet another push to bring the bill to a vote when the Senate reconvenes in September. Even if you have already called and written about this bill, talking with your Senators during the August recess can make a difference!
S. 510 poses a very serious threat to the local, nutrient-dense food movement. Farmers would be subject to FDA regulation of how they grow and raise their crops, while processed food producers (including people making products such as cheese and kombucha) would be buried in the red tape of HACCP plans. The bill does not outlaw backyard gardens or organic methods, but the long-term effect will be to drive local food sources out of business through unnecessary burdensome regulations and deprive consumers of their options to buy healthy foods from producers they know and trust.
Tell your Senators that you want them to amend or oppose S. 510. Senator Tester (D-MT) continues to work on amendments to exempt local and small-scale producers from some of the worst provisions of the bill, and we need your Senators to support this effort!
Over 150 organizations have signed a letter of support for the Tester-Hagan amendments to exempt small-scale and local producers from the more burdensome provisions of the bill. You can borrow some talking points from the letter (posted at http://farmandranchfreedom.org/sff/Amend-S510-June-7 ) or use the ones below:
1. The major foodborne illness outbreaks and recalls have all been caused by the large, industrial food system. Small, local food producers have not contributed to the highly publicized outbreaks. Yet S. 510 subjects the small, local food system to the same, broad federal regulatory oversight that would apply to the industrial food system.
2. Increased regulations and record-keeping obligations could destroy small businesses that bring food to local communities. In particular, the reliance on hazard analysis and risk-based preventative controls, a concept similar to HACCP, will harm small food producers. HACCP has already proven to be an overwhelming burden for a significant number of small, regional meat processors across the country. Applying a HACCP-type system to small, local foods processors could drive them out of business, reducing consumers options to buy fresh, local foods.
3. FDA does not belong on the farm. S. 510 calls for FDA regulation of how farms grow and harvest produce. Given the agencys track record, it is likely that the regulations will discriminate against small, organic, and diversified farms. Although language calling for flexibility may be included, but there are no enforceable limits or protections for small diversified and organic farms from inappropriate and burdensome federal rules.
4. Food safety and security both come from a diversified, vibrant local food system. Local foods give consumers the choice to buy from producers they know, creating a transparent, accountable food system without federal government oversight. State and local laws, which are often size-specific rather than one-size-fits-all, are more appropriate for local food producers.
You can also get more information about the bill in our earlier action alerts, posted at http://realmilk.comwww.westonaprice.org/action-alerts/2010-alerts.html
SUPPORT FAIR PLAY FOR LIVESTOCK FARMERS
While youre talking with your Senators or at a meeting with your Congressman, ask them to stand with family farmers on fair competition and fair contracts.
Today, a tiny handful of meatpackers and poultry processors dominate the livestock industry, making it hard for an individual farmer or rancher to get a fair deal or equitable price for cattle, hogs, or chickens. Packers are able to use their monopoly-like power to manipulate prices paid to livestock producers. The U.S. Department of Agriculture is finally taking action, proposing rules to identify practices that are illegal under the Packers & Stockyards Act. These rules:
- Prohibit packers from selling livestock to each other
- Make it easier for ranchers to sue companies accused of using deceptive trade practices or offering unfairly low prices
- End discrimination against producers based upon size alone
- Restrict livestock buyers from buying for more than one packer
In addition, the rules contain improvements for contract pork and poultry growers.
The consolidation of the livestock markets in the hands of a few large corporations hurts everyone. Together with bad regulations, consolidation is one of the main reasons it is so hard for small farmers to find local slaughterhouses to process their animals independently. Consolidation also makes it harder to buy and sell animals at fair prices even if the farmer is raising meat for direct sales. Ultimately, all farmers and all consumers are impacted by the control the meat packers exert. So its important that we stand together and support fair markets for family farmers.
Urge your legislators to support the USDA proposed rules that restore competition and contract fairness to livestock and poultry markets. Tell them we need a level playing field for family farmers and ranchers. Ask them to contact USDA Secretary Tom Vilsack and let him know they support the proposed rule.
More information:
The Packers and Stockyards Act of 1921 makes it unlawful for meat packers and companies that contract with farmers to raise hogs and poultry from engaging in any "unfair, unjustly discriminatory, or deceptive practice or device," or to "make or give any undue or unreasonable preference or advantage." But, until now, USDA has never issued the regulations necessary to properly enforce the protections for livestock and poultry farmers. In the 2008 Farm Bill, a majority of the full Congress voted to direct USDA to define these prohibitions and to clarify how the Act should be applied to give individual farmers and ranchers a fair chance when dealing with the large corporate entities that control our nation's meat and poultry processing.
For more information on how the USDA rules help livestock producers, go to the Western Organization of Resource Councils (WORC) website: http://www.worc.org/Unduepref
For more information on how the USDA rules help poultry producers, go to the Rural Advancement Foundation International USA (RAFI) website: http://www.rafiusa.org/programs/contractag/gipsa2101rules.html
COLORADO MEETING ON CONSOLIDATION OF BEEF INDUSTRY
The USDA and the U.S. Department of Justice (DOJ) are holding hearings around the country on the issue of the lack of competition in livestock and poultry markets and potential anti-trust violations. The hearing on the beef cattle industry will take place in Colorado on Friday, Aug. 27, 2010. The official purpose of this meeting is to provide the DOJ and USDA with information on the state of the cattle industry. Unofficially, the meeting will show the agencies whether cattle producers and consumers demand that the government take immediate, aggressive action to restore competition to the U.S. cattle industry.
If you are within traveling distance, please come! Even if you don't speak, your attendance at this historic event will help send a powerful message to Washington, D.C.
WHEN: Friday, August 27, 2010, beginning at 8 am MDT
WHERE: Lory Student Center, 1101 Centre Avenue Mall, Fort Collins, Colorado, 80523
MORE INFORMATION: The Department of Justice has a page dedicated to the hearings at http://www.justice.gov/atr/public/workshops/ag2010/index.htm
TRAVEL: Several organizations are coordinating buses to the event and special room rates at a nearby hotel. For more information, please contact jerilynn@worc.org or sam@fwwatch.org
Thursday, July 29, 2010
NOFA Mass Raw Milk Network Fundraiser
FUNDRAISER
To Benefit the NOFA/Massachusetts Raw Milk Network
Thursday, August 12, 6:30 P.M.
Cook Farm, 1 East Hadley Rd., Hadley, MA
$50 Donation
Join us at this raw milk dairy in Hadley for a gathering of local raw milk farmers, consumers and supporters. Enjoy a local cheese tasting, local foods and a cash ice cream bar. Support the NOFA/Massachusetts Raw Milk Network, and hear from our special guests about the raw milk movement's progress around the country.
Special Guests
- Sally Fallon Morell, President of The Weston A. Price Foundation and founder of A Campaign for Real Milk
- Pete Kennedy, President of the Farm to Consumer Legal Defense Fund
Contact Winton Pitcoff at winton@nofamass.org for more information, or register by sending a check to NOFA/Massachusetts Raw Milk Network, 27 South Union St., Plainfield, MA 01070.
To Benefit the NOFA/Massachusetts Raw Milk Network
Thursday, August 12, 6:30 P.M.
Cook Farm, 1 East Hadley Rd., Hadley, MA
$50 Donation
Join us at this raw milk dairy in Hadley for a gathering of local raw milk farmers, consumers and supporters. Enjoy a local cheese tasting, local foods and a cash ice cream bar. Support the NOFA/Massachusetts Raw Milk Network, and hear from our special guests about the raw milk movement's progress around the country.
Special Guests
- Sally Fallon Morell, President of The Weston A. Price Foundation and founder of A Campaign for Real Milk
- Pete Kennedy, President of the Farm to Consumer Legal Defense Fund
Contact Winton Pitcoff at winton@nofamass.org for more information, or register by sending a check to NOFA/Massachusetts Raw Milk Network, 27 South Union St., Plainfield, MA 01070.
Monday, July 19, 2010
What Are We Eating?
Here's a great image of what the average American consumes in a year. What surprises you the most? (click to enlarge)
Thursday, July 15, 2010
Seacoast WAPF Potluck
YOU’RE INVITED TO A WESTON A. PRICE POTLUCK DINNER
Little Brook Farm, a biological & pasture based diverse animal and vegetable farm, and the Seacoast Weston A. Price Foundation chapter are having a potluck dinner on Wednesday, July 21, from 6 pm to 8 pm. A guest speaker is also planned.
Not only will you be able to enjoy the bucolic surroundings of one of the last old-time, third generation local beef farms, but additionally you’ll get a taste of their pastured chickens and eggs, grass fed beef and sumptuous vegetables.
So come dine under the big tent at Little Brook Farm, 58 Oaklands Rd., in Exeter (turn down the driveway at the small wooden building by the edge of the road).
Please bring a WAPF style dish and interested friends. Hope to see you there!
Please RSVP to Kendall Montouri and also let us know if you have children coming.
Wednesday, July 14, 2010
Food Safety Legislation Update
Thank you to the many people who have called or emailed their Senators to urge them to amend or oppose S. 510, the Food Safety Modernization Act! The bill continues to be delayed and its future is unclear. But it still poses a threat to producers of local, nutrient-dense foods.
ACTION TO TAKE
If you have not yet called your Senators, please do so now! I cannot stress how important it is to make your voice heard on this issue. Urge them to support the Tester-Hagan amendments to exempt small-scale and direct marketing producers from the most burdensome provisions of the bill. Also encourage them to support the Senator Feinsteins proposal to ban Bisphenol A (BPA) from food containers because this endocrine-disrupting chemical has no place in our food.
You can find your Senators contact information at www.Senate.gov or by calling the Capitol Switchboard at 202-224-3121 or toll-free at 877-210-5351.
IMPORTANT TO NOTE
Several members have received responses from their Senators extolling provisions in the bill that allegedly help or exempt local food producers. Its very important that we continue to educate these Senators about the real impacts of the bill. Check out the questions and answers below for more information.
QUESTION: Does S. 510 help small farmers and local food producers?
NO! The bill does include provisions to try to reduce the burdens that will be imposed on small producers, such as providing for longer deadlines for compliance and directing FDA to consider various issues facing organic farms and small businesses. But none of these actually prevent FDA from imposing new, burdensome requirements. The provisions essentially tell FDA to be nice to local food producers, but do not create enforceable limits on the agency's power.
The only enforceable limit is that FDA's new regulations cannot contradict the regulations for certified organic producers. But many local food producers are not certified organic. And even certified organic can still be subject to additional regulations by FDA imposing impractical or unfair burdens, so long as the regulations dont directly contradict the organic regulations.
While the industrial food system is in need of reform, the well-publicized problems with food safety have not come from the sustainable, local food system. No one has demonstrated any need to have local producers regulated by FDA more than they already are! The Tester-Hagan amendments are a reasonable method for protecting local food producers from unnecessary and unfair regulations.
QUESTION: Are direct marketing farms exempt from the bill?
NO! Under the bill as written, all farmers raising produce are subject to the produce safety standards (section 105 of the bill) regardless of how they market their fruits and vegetables. The Tester-Hagan amendments are needed to protect direct marketing produce farmers from being told how to grow and harvest their crops by FDA bureaucrats.
QUESTION: Are direct marketing food processors exempt from the bill?
NOT CLEAR! Based on FDAs guidance documents, food processors who market directly to consumers might be exempt from the requirements for HACCP-type programs. But the language is far from clear, and subject to change any time FDA chooses.
The bills provisions for traceability and HACCP-type requirements are dependent on the definition of facility under the 2002 Bioterrorism Act. That Act exempted farms and retail food establishments from being categorized as facilities, but it did not define the terms. So the scope of these exemptions is defined by FDAs regulations and guidance documents, which can be changed by the agency without Congressional approval.
In addition, the current definitions do not appear to address the majority of our local food producers. Under FDA's guidance document, a "retail food establishment" is an establishment that sells food products directly to consumers as its primary function. However, the FDAs definition of consumer excludes end users such as restaurants, local grocers, and schools. So many food producers who provide healthy, safe foods to these institutions would be subject to HACCP-type regulations under the bill and current definitions.
Moreover, the specific examples of retail food establishments are establishments such as grocery stores, convenience stores, and vending machine locations. Not only are farmers markets, farm stands, and CSAs not listed, but they may not qualify because they typically sell food at a different physical location than where the food is held, packed, or processed. Consider the typical example of a small-scale processor who buys local ingredients and makes jams, breads, cheeses, etc. to sell at the farmers market. It may be that the farmers market itself qualifies as a "retail food establishment" -- but the commercial kitchen where the goods were prepared would not qualify, because the main purpose of that location is to process food, not sell to consumers. Different physical locations may mean different requirements under the FDAs definitions.
"Farms" are also exempt from registration requirements. But the definition of "farm" specifically excludes any place that manufactures or processes food, unless that food is consumed on location. Take a typical farm that processes some of its own fruit into jams. Farmer Joe argues that he is exempt from registration as a "farm." FDA points to the fact that, if he's selling any of that jam, he's a facility because of the limitation on the definition of farm. While Farmer Joe might fit under the literal terms of the "retail food establishment" definition, FDA has a very strong argument that Congress wouldn't have acquiesced in the narrow definition of farm if it intended these locations to be exempt.
The bottom line is that some direct marketing food processors would be exempt from the requirements as "retail food establishments," but the FDA's definitions do not appear to cover many of our local food producers, and FDA can change the definitions at any time. Local food processors are already regulated by the local and state authorities, and FDA regulation is not needed. The Tester-Hagan amendments are a reasonable way to protect small-scale businesses from overly burdensome and unnecessary regulations.
QUESTION: What is BPA?
Bisphenol A (BPA) is a chemical found in the linings of cans and in polycarbonate plastic, including some sports bottles, food-storage containers and baby bottles. It has potential links to a wide range of health effects, including an increased risk of diseases or disorders of the brain, reproductive and immune systems. A recent CDC study showed that more than 90 percent of Americans have BPA in their urine, suggesting that exposure to BPA is likely prevalent and ongoing. In January, the FDA changed its position on the safety of BPA, voicing some concern about its effects on children and infants, but stopped short of calling for a ban. Previously the agency had said trace amounts of the chemical that leach out of food containers are not dangerous, only later admitting that it relied on a small number of industry-sponsored studies
ACTION TO TAKE
If you have not yet called your Senators, please do so now! I cannot stress how important it is to make your voice heard on this issue. Urge them to support the Tester-Hagan amendments to exempt small-scale and direct marketing producers from the most burdensome provisions of the bill. Also encourage them to support the Senator Feinsteins proposal to ban Bisphenol A (BPA) from food containers because this endocrine-disrupting chemical has no place in our food.
You can find your Senators contact information at www.Senate.gov or by calling the Capitol Switchboard at 202-224-3121 or toll-free at 877-210-5351.
IMPORTANT TO NOTE
Several members have received responses from their Senators extolling provisions in the bill that allegedly help or exempt local food producers. Its very important that we continue to educate these Senators about the real impacts of the bill. Check out the questions and answers below for more information.
QUESTION: Does S. 510 help small farmers and local food producers?
NO! The bill does include provisions to try to reduce the burdens that will be imposed on small producers, such as providing for longer deadlines for compliance and directing FDA to consider various issues facing organic farms and small businesses. But none of these actually prevent FDA from imposing new, burdensome requirements. The provisions essentially tell FDA to be nice to local food producers, but do not create enforceable limits on the agency's power.
The only enforceable limit is that FDA's new regulations cannot contradict the regulations for certified organic producers. But many local food producers are not certified organic. And even certified organic can still be subject to additional regulations by FDA imposing impractical or unfair burdens, so long as the regulations dont directly contradict the organic regulations.
While the industrial food system is in need of reform, the well-publicized problems with food safety have not come from the sustainable, local food system. No one has demonstrated any need to have local producers regulated by FDA more than they already are! The Tester-Hagan amendments are a reasonable method for protecting local food producers from unnecessary and unfair regulations.
QUESTION: Are direct marketing farms exempt from the bill?
NO! Under the bill as written, all farmers raising produce are subject to the produce safety standards (section 105 of the bill) regardless of how they market their fruits and vegetables. The Tester-Hagan amendments are needed to protect direct marketing produce farmers from being told how to grow and harvest their crops by FDA bureaucrats.
QUESTION: Are direct marketing food processors exempt from the bill?
NOT CLEAR! Based on FDAs guidance documents, food processors who market directly to consumers might be exempt from the requirements for HACCP-type programs. But the language is far from clear, and subject to change any time FDA chooses.
The bills provisions for traceability and HACCP-type requirements are dependent on the definition of facility under the 2002 Bioterrorism Act. That Act exempted farms and retail food establishments from being categorized as facilities, but it did not define the terms. So the scope of these exemptions is defined by FDAs regulations and guidance documents, which can be changed by the agency without Congressional approval.
In addition, the current definitions do not appear to address the majority of our local food producers. Under FDA's guidance document, a "retail food establishment" is an establishment that sells food products directly to consumers as its primary function. However, the FDAs definition of consumer excludes end users such as restaurants, local grocers, and schools. So many food producers who provide healthy, safe foods to these institutions would be subject to HACCP-type regulations under the bill and current definitions.
Moreover, the specific examples of retail food establishments are establishments such as grocery stores, convenience stores, and vending machine locations. Not only are farmers markets, farm stands, and CSAs not listed, but they may not qualify because they typically sell food at a different physical location than where the food is held, packed, or processed. Consider the typical example of a small-scale processor who buys local ingredients and makes jams, breads, cheeses, etc. to sell at the farmers market. It may be that the farmers market itself qualifies as a "retail food establishment" -- but the commercial kitchen where the goods were prepared would not qualify, because the main purpose of that location is to process food, not sell to consumers. Different physical locations may mean different requirements under the FDAs definitions.
"Farms" are also exempt from registration requirements. But the definition of "farm" specifically excludes any place that manufactures or processes food, unless that food is consumed on location. Take a typical farm that processes some of its own fruit into jams. Farmer Joe argues that he is exempt from registration as a "farm." FDA points to the fact that, if he's selling any of that jam, he's a facility because of the limitation on the definition of farm. While Farmer Joe might fit under the literal terms of the "retail food establishment" definition, FDA has a very strong argument that Congress wouldn't have acquiesced in the narrow definition of farm if it intended these locations to be exempt.
The bottom line is that some direct marketing food processors would be exempt from the requirements as "retail food establishments," but the FDA's definitions do not appear to cover many of our local food producers, and FDA can change the definitions at any time. Local food processors are already regulated by the local and state authorities, and FDA regulation is not needed. The Tester-Hagan amendments are a reasonable way to protect small-scale businesses from overly burdensome and unnecessary regulations.
QUESTION: What is BPA?
Bisphenol A (BPA) is a chemical found in the linings of cans and in polycarbonate plastic, including some sports bottles, food-storage containers and baby bottles. It has potential links to a wide range of health effects, including an increased risk of diseases or disorders of the brain, reproductive and immune systems. A recent CDC study showed that more than 90 percent of Americans have BPA in their urine, suggesting that exposure to BPA is likely prevalent and ongoing. In January, the FDA changed its position on the safety of BPA, voicing some concern about its effects on children and infants, but stopped short of calling for a ban. Previously the agency had said trace amounts of the chemical that leach out of food containers are not dangerous, only later admitting that it relied on a small number of industry-sponsored studies
Monday, July 12, 2010
Wise Traditions 2010
(I am planning on attending this conference. Let me know if you want to carpool/room share.)
WISE TRADITIONS 2010
Eleventh International Conference of the Weston A. Price Foundation
THE POLITICS OF FOOD
Friday, November 12 - Saturday, November 13 - Sunday, November 14
Plus special activities Monday, November 15
Accessible Mid-Atlantic Region!
VALLEY FORGE CONVENTION CENTER
King of Prussia, Pennsylvania (near Philadelphia)
Cutting Edge Information on a Wide Range of Nutritional Topics.
A Showcase for Delicious Traditional Food.
A Unique Opportunity for Health Professionals and Laymen interested in Diet and Health.
WAPF Networking, Friendship and Fun.
SEMINARS AND SESSIONS ON
Gut and Psychology Syndrome
Traditional Diets
Gonzalez Cancer Protocol
The Politics of Food
Low-Carb Therapies
Pasture-Based Farming
Native Diets
Heart Disease
Hormonal Health
Holistic Dentistry
Traditional Food Preparation
Farm Tour
Homeopathy Workshop
Pig Butchering Workshop
Movement Therapy
FEATURED SPEAKERS
Janez Bogataj, PhD, author of The Food and Cooking of Slovenia
Kevin Brown, author of The Liberation Diet
Jerry Brunetti, soil and animal health specialist
Joette Calabrese, HMC,CCH, RSHom(NA), expert on homeopathy
Natasha Campbell-McBride MD, author of Gut and Psychology Syndrome
Kari Carlisle, LinkedIn.com expert
Monica Corrado, holistic nutrition and food educator
Thomas Cowan, MD, author of Fourfold Path to Healing
Andrew Cutler, PhD, PE, author of Amalgam Illness: Diagnosis and Treatment
Kaayla Daniel, PhD, author of The Whole Soy Story
Maureen Diaz, author of Traditional Food Preparation Techniques
Robert Disney, environmental scientist
Sally Fallon Morell, MA, author of Nourishing Traditions
Wayne Feister, DO, holistic practitioner
Anne Fischer Silva, CNT, LE, founder and owner of A New Leaf Nutrition
Cathy Garger, founding Charter member "Chesapeake Safe Energy Coalition"
Nora Gedgaudas, author of Primal Body-Primal Mind
Nicholas Gonzalez, MD, author of The Trophoblast and the Origins of Cancer
Stephan Guyenet, PhD, health blogger at wholehealthsource.blogspot.com
James Hague, soil and animal health specialist
Kimberly Hartke, WAPF publicist
Magda Havas, PhD, expert on biological effects of environmental contaminants
Shannon Hayes, author of Radical Homemakers
Dean Howell, ND, expert on neuro-cranial restructuring
Anore Jones, author of The Fish We Eat
Kelly the Kitchen Kop, real foods blogger
Janet Lang, DC, thyroid expert
Peter Langsjoen, MD, holistic cardiologist
Felix Liao, DDS, expert on root canal dangers
Chris Masterjohn, expert on fat-soluble vitamins
Mark McAfee, owner of Organic Pastures Dairy in California
Judith McGeary, Esq, farmer and founder Farm and Ranch Freedom Alliance
Jenny McGruther, Nourished Kitchen blogger
Ann Marie Michaels, Cheeseslave.com blogger
Ken Morehead, DOM, holistic practitioner
Rami Nagel, author of Cure Tooth Decay
Jill Nienhiser, WAPF webmaster
Bruce Rind, MD, holistic medical doctor and authority on endocrinology
Joel Salatin, farmer and author of Everything I Want to Do is Illegal
Stephanie Seneff, PhD, authority on the effects of drugs on human health
Jeffrey Smith, bestselling author of Seeds of Deception
Kim Thompson, movement educator
Tim Wightman, president of Farm-to-Consumer Foundation
Will Winter, DVM, expert on sustainable agriculture and pastured livestock
Gary Zimmer, soil specialist
LOCATION AND ACCOMMODATION
This year you have a choice of hotels The Valley Forge Convention Center is attached to the Radisson Hotel Valley Forge and the Scanticon Hotel and Conference Center, offering a total of 488 guestrooms. Both hotels have a special conference rate of $105.00 per night plus tax, single to quad occupancy with free parking.
RADISSON VALLEY FORGE has many room amenities:
Sleep number beds-(King and Double Beds available)
Modern comfortable dcor
High speed wireless internet access (complimentary)
Large work desk
Iron and iron board
In-room safe
Refrigerator (upon request)
If you are in need of two beds, please call the hotel to make reservations
To make reservations at the Radisson Hotel, please call (610) 337-2000 and use code, Weston Price Wise Traditions or register on-line using the following link www.radissonvalleyforge.com
SCANTICON HOTEL has many room amenities:
All rooms are suites (King and Double Beds available)
High speed wireless internet access (complimentary)
Refrigerator
Iron and iron board
Whirlpool
In-room safe
To make reservations at the Scanticon Hotel please, call (610) 265-1500 and use code, Weston Price Wise Traditions or register on-line using the following link https://reservations.ihotelier.com/crs/g_reservation.cfm?groupID=388328&hotelID=11984
TROPIANO AIRPORT SHUTTLE SERVICE
The shuttle departs from the Airport Ground Transportation Center every 30 minutes from 6 am-midnight. Reservations can be made by calling Tropiano at (215) 616-5370.
One Way: $29 Round Trip: $53.00
Should you have any difficulty making your hotel reservations, please contact the meeting registrar at (304) 724-3006.
MONDAY ACTIVITIES
Chapter leaders meeting with Sally Fallon Morell
Farm Tour with Kathy Kramer*
Porkshop with Brooks Miller*
Movement Workshop with Kim Thompson*
Cooking with Monica Corrado*
Homeopathy Seminar with Joette Calabrese, HMC, CCH, RSHom(NA)*
*Additional fees apply. Space is extremely limited so be sure to secure your space today. Lunch provided with all Monday activities.
SPECIAL PRE-CONFERENCE ACTIVITY
THURSDAY GMO TRAINING SEMINAR WITH JEFFREY SMITH
Take a full day workshop BEFORE the Weston A. Price conference, on Thursday, November 11, 2010, at the same location with international bestselling author and filmmaker Jeffrey M. Smith. Learn how to speak about genetically modified organisms (GMOs) and to organize effective activism on the issue. Help achieve the tipping point of consumer rejection to force GMOs out of our food supply. Whether you want to give complete presentations or simply add a GMO section to your current lecture, whether youre planning to discuss GMOs in a professional setting with clients or just with friends in a casual way, or whether you want to be a leading anti-GMO campaigner or simply want to help out where you can, dont miss this unique opportunity to learn from the leading spokesperson on GMO health dangers. For further information, visit http://www.responsibletechnology.org/GMFree/TakeAction/Workshop/index.cfm?ndrx=99
CHILDCARE
The Wise Traditions Conference is pleased to provide a children's program for this year's meeting. $100 per child, includes lunch. Children 3 - 12 who are potty trained are welcome to Wise Traditions 2010 as long as they are enrolled in our children's program. For the sake of other conference attendees, we ask that parents refrain from bringing children to the conference sessions.
Please note: We will serve nourishing traditional food (including fruit and natural sweeteners) but we cannot cater to special diets in the children's program. There may be casein and gluten in the children's lunches and snacks. Parents will need to supply their own food if their children are on special diets.
Also note: A special room has been set aside for mothers of infants who want to attend the conference. There will be a live audio feed from one of the sessions to that room throughout the day's events. There will be no child care provided for infants and children under age 3.
CONFERENCE FOOD
As always, the conference will feature delicious traditional foods. To view the menus, visit http://westonaprice.org/conferences/132-2010-conference/1977-2010-conference-menus.html (Menus are subject to change without notice.)
As we did last year, we will also provide gluten-free, casein-free alternative meals. Participants requiring gluten-free or casein-free meals will be served in a separate buffet with the exception of the Saturday banquet which is GF/CF with items containing gluten and/or casein served on the side. If you wish to have this option, please select the GF/CF option on your registration form.
EARLY BIRD SPECIAL
Save $50 if you register by September 1.
SCHOLARSHIPS
Thanks to a generous grant, we will be offering 50 conference scholarships this year. To apply, go to https://www.ptfassociates.com/secure/wisetraditions/financial_aid_application_2010.pdf or call (304) 724-3006.
TO REGISTER, http://www.westonaprice.org/conferences/132/1948-2010-conference-registration.html or call (304) 724-3006.
ROOM SHARES AND RIDE SHARES
Connect with other conference attendees using the Room Share/Ride Share Forum: https://www.ptfassociates.com/secure/wisetraditions/forum/default.asp.
EXHIBITING AND SPONSOR INFORMATION
For information about becoming a sponsor or exhibiting at the conference please visit https://www.ptfassociates.com/secure/wisetraditions/sponsor_exhibitor_2010.pdf or, contact Paul Frank at PTF Associates at (304) 724-3006 or via email to pfrank@ptfassociates.com. Space for sponsor and exhibiting is very limited; early registration is encouraged!
CONTINUING EDUCATION UNITS for many health professionals attending the full conference. For further information http://www.westonaprice.org/conferences/132/1947-2010-conference-ceus.html.
POSTER PRESENTATION: Submissions of abstracts for poster presentations from health professionals on a broad range of topics relating food and nutrition to health are welcome. Contact info@westonaprice.org for further information.
FOR FURTHER INFORMATION, http://www.westonaprice.org/conferences/2010-conference.html or call (304) 724-3006.
WISE TRADITIONS 2010
Eleventh International Conference of the Weston A. Price Foundation
THE POLITICS OF FOOD
Friday, November 12 - Saturday, November 13 - Sunday, November 14
Plus special activities Monday, November 15
Accessible Mid-Atlantic Region!
VALLEY FORGE CONVENTION CENTER
King of Prussia, Pennsylvania (near Philadelphia)
Cutting Edge Information on a Wide Range of Nutritional Topics.
A Showcase for Delicious Traditional Food.
A Unique Opportunity for Health Professionals and Laymen interested in Diet and Health.
WAPF Networking, Friendship and Fun.
SEMINARS AND SESSIONS ON
Gut and Psychology Syndrome
Traditional Diets
Gonzalez Cancer Protocol
The Politics of Food
Low-Carb Therapies
Pasture-Based Farming
Native Diets
Heart Disease
Hormonal Health
Holistic Dentistry
Traditional Food Preparation
Farm Tour
Homeopathy Workshop
Pig Butchering Workshop
Movement Therapy
FEATURED SPEAKERS
Janez Bogataj, PhD, author of The Food and Cooking of Slovenia
Kevin Brown, author of The Liberation Diet
Jerry Brunetti, soil and animal health specialist
Joette Calabrese, HMC,CCH, RSHom(NA), expert on homeopathy
Natasha Campbell-McBride MD, author of Gut and Psychology Syndrome
Kari Carlisle, LinkedIn.com expert
Monica Corrado, holistic nutrition and food educator
Thomas Cowan, MD, author of Fourfold Path to Healing
Andrew Cutler, PhD, PE, author of Amalgam Illness: Diagnosis and Treatment
Kaayla Daniel, PhD, author of The Whole Soy Story
Maureen Diaz, author of Traditional Food Preparation Techniques
Robert Disney, environmental scientist
Sally Fallon Morell, MA, author of Nourishing Traditions
Wayne Feister, DO, holistic practitioner
Anne Fischer Silva, CNT, LE, founder and owner of A New Leaf Nutrition
Cathy Garger, founding Charter member "Chesapeake Safe Energy Coalition"
Nora Gedgaudas, author of Primal Body-Primal Mind
Nicholas Gonzalez, MD, author of The Trophoblast and the Origins of Cancer
Stephan Guyenet, PhD, health blogger at wholehealthsource.blogspot.com
James Hague, soil and animal health specialist
Kimberly Hartke, WAPF publicist
Magda Havas, PhD, expert on biological effects of environmental contaminants
Shannon Hayes, author of Radical Homemakers
Dean Howell, ND, expert on neuro-cranial restructuring
Anore Jones, author of The Fish We Eat
Kelly the Kitchen Kop, real foods blogger
Janet Lang, DC, thyroid expert
Peter Langsjoen, MD, holistic cardiologist
Felix Liao, DDS, expert on root canal dangers
Chris Masterjohn, expert on fat-soluble vitamins
Mark McAfee, owner of Organic Pastures Dairy in California
Judith McGeary, Esq, farmer and founder Farm and Ranch Freedom Alliance
Jenny McGruther, Nourished Kitchen blogger
Ann Marie Michaels, Cheeseslave.com blogger
Ken Morehead, DOM, holistic practitioner
Rami Nagel, author of Cure Tooth Decay
Jill Nienhiser, WAPF webmaster
Bruce Rind, MD, holistic medical doctor and authority on endocrinology
Joel Salatin, farmer and author of Everything I Want to Do is Illegal
Stephanie Seneff, PhD, authority on the effects of drugs on human health
Jeffrey Smith, bestselling author of Seeds of Deception
Kim Thompson, movement educator
Tim Wightman, president of Farm-to-Consumer Foundation
Will Winter, DVM, expert on sustainable agriculture and pastured livestock
Gary Zimmer, soil specialist
LOCATION AND ACCOMMODATION
This year you have a choice of hotels The Valley Forge Convention Center is attached to the Radisson Hotel Valley Forge and the Scanticon Hotel and Conference Center, offering a total of 488 guestrooms. Both hotels have a special conference rate of $105.00 per night plus tax, single to quad occupancy with free parking.
RADISSON VALLEY FORGE has many room amenities:
Sleep number beds-(King and Double Beds available)
Modern comfortable dcor
High speed wireless internet access (complimentary)
Large work desk
Iron and iron board
In-room safe
Refrigerator (upon request)
If you are in need of two beds, please call the hotel to make reservations
To make reservations at the Radisson Hotel, please call (610) 337-2000 and use code, Weston Price Wise Traditions or register on-line using the following link www.radissonvalleyforge.com
SCANTICON HOTEL has many room amenities:
All rooms are suites (King and Double Beds available)
High speed wireless internet access (complimentary)
Refrigerator
Iron and iron board
Whirlpool
In-room safe
To make reservations at the Scanticon Hotel please, call (610) 265-1500 and use code, Weston Price Wise Traditions or register on-line using the following link https://reservations.ihotelier.com/crs/g_reservation.cfm?groupID=388328&hotelID=11984
TROPIANO AIRPORT SHUTTLE SERVICE
The shuttle departs from the Airport Ground Transportation Center every 30 minutes from 6 am-midnight. Reservations can be made by calling Tropiano at (215) 616-5370.
One Way: $29 Round Trip: $53.00
Should you have any difficulty making your hotel reservations, please contact the meeting registrar at (304) 724-3006.
MONDAY ACTIVITIES
Chapter leaders meeting with Sally Fallon Morell
Farm Tour with Kathy Kramer*
Porkshop with Brooks Miller*
Movement Workshop with Kim Thompson*
Cooking with Monica Corrado*
Homeopathy Seminar with Joette Calabrese, HMC, CCH, RSHom(NA)*
*Additional fees apply. Space is extremely limited so be sure to secure your space today. Lunch provided with all Monday activities.
SPECIAL PRE-CONFERENCE ACTIVITY
THURSDAY GMO TRAINING SEMINAR WITH JEFFREY SMITH
Take a full day workshop BEFORE the Weston A. Price conference, on Thursday, November 11, 2010, at the same location with international bestselling author and filmmaker Jeffrey M. Smith. Learn how to speak about genetically modified organisms (GMOs) and to organize effective activism on the issue. Help achieve the tipping point of consumer rejection to force GMOs out of our food supply. Whether you want to give complete presentations or simply add a GMO section to your current lecture, whether youre planning to discuss GMOs in a professional setting with clients or just with friends in a casual way, or whether you want to be a leading anti-GMO campaigner or simply want to help out where you can, dont miss this unique opportunity to learn from the leading spokesperson on GMO health dangers. For further information, visit http://www.responsibletechnology.org/GMFree/TakeAction/Workshop/index.cfm?ndrx=99
CHILDCARE
The Wise Traditions Conference is pleased to provide a children's program for this year's meeting. $100 per child, includes lunch. Children 3 - 12 who are potty trained are welcome to Wise Traditions 2010 as long as they are enrolled in our children's program. For the sake of other conference attendees, we ask that parents refrain from bringing children to the conference sessions.
Please note: We will serve nourishing traditional food (including fruit and natural sweeteners) but we cannot cater to special diets in the children's program. There may be casein and gluten in the children's lunches and snacks. Parents will need to supply their own food if their children are on special diets.
Also note: A special room has been set aside for mothers of infants who want to attend the conference. There will be a live audio feed from one of the sessions to that room throughout the day's events. There will be no child care provided for infants and children under age 3.
CONFERENCE FOOD
As always, the conference will feature delicious traditional foods. To view the menus, visit http://westonaprice.org/conferences/132-2010-conference/1977-2010-conference-menus.html (Menus are subject to change without notice.)
As we did last year, we will also provide gluten-free, casein-free alternative meals. Participants requiring gluten-free or casein-free meals will be served in a separate buffet with the exception of the Saturday banquet which is GF/CF with items containing gluten and/or casein served on the side. If you wish to have this option, please select the GF/CF option on your registration form.
EARLY BIRD SPECIAL
Save $50 if you register by September 1.
SCHOLARSHIPS
Thanks to a generous grant, we will be offering 50 conference scholarships this year. To apply, go to https://www.ptfassociates.com/secure/wisetraditions/financial_aid_application_2010.pdf or call (304) 724-3006.
TO REGISTER, http://www.westonaprice.org/conferences/132/1948-2010-conference-registration.html or call (304) 724-3006.
ROOM SHARES AND RIDE SHARES
Connect with other conference attendees using the Room Share/Ride Share Forum: https://www.ptfassociates.com/secure/wisetraditions/forum/default.asp.
EXHIBITING AND SPONSOR INFORMATION
For information about becoming a sponsor or exhibiting at the conference please visit https://www.ptfassociates.com/secure/wisetraditions/sponsor_exhibitor_2010.pdf or, contact Paul Frank at PTF Associates at (304) 724-3006 or via email to pfrank@ptfassociates.com. Space for sponsor and exhibiting is very limited; early registration is encouraged!
CONTINUING EDUCATION UNITS for many health professionals attending the full conference. For further information http://www.westonaprice.org/conferences/132/1947-2010-conference-ceus.html.
POSTER PRESENTATION: Submissions of abstracts for poster presentations from health professionals on a broad range of topics relating food and nutrition to health are welcome. Contact info@westonaprice.org for further information.
FOR FURTHER INFORMATION, http://www.westonaprice.org/conferences/2010-conference.html or call (304) 724-3006.
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