This just in from the Weston A. Price Foundation:
STOP THE CORPORATE TAKEOVER OF ORGANICS
Send Your Comments to the National Organic Standards Board
COMMENTS DUE APRIL 10TH
Dear Members,
The following urgent action alert comes via the Cornucopia Institute. It is a long and detailed message but one that is very important. Please read carefully and take action.
Sincerely,
Sally Fallon Morell,
President
The National Organic Standards Board (NOSB), which advises the Secretary of Agriculture on organic policy and rulemaking, is considering several changes to the USDAs organic standards that would water down organics, catering to corporate interests.
We cannot allow corporate-backed members of the NOSB to chip away at the integrity of the label. The following proposals are highly objectionable. Please comment on them through www.regulations.gov ( http://e2ma.net/go/7024527539/208523220/221483910/1407690/goto:http://www.regulations.gov ) (complete instructions below).
SYNTHETIC ADDITIVES
The proposal would allow any synthetic additive that qualifies as a nutrient to be added freely to organics, even those that have never been tested for safety by the FDA. Currently, organic law requires all synthetic additives, including nutrients, to be individually petitioned, carefully reviewed and approved by the USDA before they can be added to organics.
MESSAGE to the NOSB: Reject the Handling Committees proposal regarding nutrient additives. Nutrient additives must be individually petitioned, reviewed and approved as safe and appropriate for organics before they can be used, as the law currently requires.
Already, some companies are illegally adding a synthetic form of DHA omega-3 (from algae) and ARA omega-6 (from soil fungus) oils to organic food, including organic infant formula. These additives have been linked to serious gastrointestinal reactions in some babies and toddlers.
More information: An action alert ( http://e2ma.net/go/7024527539/208523220/221483911/1407690/goto:http://www.cornucopia.org/2011/03/keep-questionable-synthetic-additives-out-of-organics/ ) on this topic was sent out in late March. If you already sent in your commentsThank You! If you havent already commented, please do so today.
SPACE FOR CHICKENS
Factory farms, with as many as 100,000 birds in a building, that do not have legally mandated access to the outdoors, would be shut down if new strict rules are put into place.
The good news is that the NOSB Livestock Committee proposal would outlaw the tiny enclosed porches that industrial-scale producers had been illegally calling "the outdoors."
But our struggle for meaningful animal welfare standards is not over! The committee caved once again to industry pressureproposing outdoor space requiring just two square feet per layer and one square foot per broiler! In the European Union, organic standards require at least 43 square feet per bird outdoors and the US leading organic brand, Organic Valley, affords their birds 5 square feet outdoors.
Two square feet and one square foot are simply not enough for birds to have meaningful outdoor space where they can exhibit their natural behaviors (like running around and "foraging").
Furthermore, the proposal would grant 1.2 square feet indoors for laying hens and one square foot for meat birds, which is no better than the current industry standard for factory farms, and certainly inadequate for organics. Many legitimate organic farmers currently provide 1.5 square feet of indoor space for their laying hens.
MESSAGE to the NOSB: Please resist pressure by the industrial-scale producers to reduce the outdoor space requirements for chickens any further. When I buy organic eggs and chicken, I expect that the birds were raised with ample access to real outdoor runs5 square feet should be the bare minimum!
More information: Watch the video ( http://e2ma.net/go/7024527539/208523220/221483912/1407690/goto:http://www.cornucopia.org/2010/10/video-scrambled-eggs/ ) and read Cornucopias report, Scrambled Eggs (http://e2ma.net/go/7024527539/208523220/221483913/1407690/goto:http://www.cornucopia.org/2010/09/organic-egg-report-and-scorecard/ ). A complete action alert on the NOSBs proposal for organic poultry is also available.
INDOOR AND OUTDOOR SPACE FOR GROWING PIGS
The Livestock Committees proposed space requirements for growing pigs are so small, even standards set by the National Pork Boardwhich is controlled by industrial hog producersare more generous! The proposed space requirements would make it impossible for growing pigs to turn around in their bedded indoor space, with even less space outdoors.
MESSAGE to NOSB: The proposed space requirements for growing pigs are woefully inadequate. If organic standards are going to be the gold standard in terms of animal welfare, growing pigs should be granted more space than what is currently proposed.
More information: A complete action alert (http://e2ma.net/go/7024527539/208523220/221483914/1407690/goto:http://www.cornucopia.org/actionalerts/HogsActionAlert.pdf ) for organic hogs is available.
INDOOR SPACE FOR DAIRY COWS
The opposite is true for dairy cows. The latest proposal for indoor space requirements is so overly generous that it could essentially put thousands of family-scale dairy producers out of the organic business.
Many small-scale organic dairy farmers use stalls in their barns to position the cows and direct their manure away from their bedding. The proposed space requirements would have cows lying in their own excrement. Most family farm producers would have to build new barns to meet these space requirementsa capital investment that many could not afford, forcing them out of the organic business.
MESSAGE to NOSB: A previous recommendation, which had been accepted by the full NOSB, already requires stall barns to provide one full, traditional stall per animal. Therefore, indoor space requirements for dairy producers with stall barns are unnecessary.
More information: A complete action alert (http://e2ma.net/go/7024527539/208523220/221483915/1407690/goto:http://www.cornucopia.org/actionalerts/NOSB_DairyActionAlertApril2011.pdf ) fororganic dairy cows is available.
TAKE ACTION
Please submit your comment electronically before the April 10 deadline.
http://www.regulations.gov/#!submitComment;D=AMS-NOP-11-0014-0001
We strongly recommend submitting two separate commentsone for nutrient additives and one for animal welfare. Also remember that a message in your own words carries more weight than cutting and pasting the sample letter, so please personalize your message, at least at the beginning and end if possible!
And your message doesn't need to be long to be effective.
Tell your family and friends to submit their comments as well!
To speak in person at the NOSB meeting (important if you can make it):
In addition to sending their written comments, organic farmers and consumers living in the Seattle area, or willing to travel, are encouraged to also sign up for a five-minute speaking slot at the meeting at the end of April. Individuals can find more information about the meeting, and can pre-register for a slot byApril 10, 2011, by visiting http://www.ams.usda.gov/nosbseattleslots or by calling (202) 720-3252.
Please email cultivate@cornucopia.org or call 715-514-2627 if you are planning on attending the Seattle meeting.
SAMPLE LETTER FOR CONSUMERS
Unregulated Synthetics/Animal Welfare
Dear Members of the National Organic Standards Board,
Thank you for your efforts in setting animal welfare standards for organically raised farm animals. I appreciate the clarification that organic laying hens and meat birds be required to have outdoor access beyond a tiny, lifeless enclosed porch.
However, I have some concerns about the proposed stocking rate chart.
For chickens, the current proposal does not grant enough space. Please require more outdoor space for chickens, since birds cannot run around freely in outdoor runs if they only have one or two square feet. Many producers already grant much more outdoor space, and 5 square feet should be the bare minimum in the organic standards.
Please resist pressure by the industrial-scale producers to reduce the outdoor space requirements for chickens any further. When I buy organic eggs and chicken, I expect that the birds were raised with ample access to real outdoor runs. And indoors, birds should have at least 1.5 square feet of space (1.2 square feet, the agribusiness standard for uncaged birds, is inadequate).
For growing pigs, the proposed stocking rate would not allow pigs to even turn around inside, and they would not all fit in their outdoor space. The space requirements for growing pigs must be increased.
For dairy cows, the proposed indoor space requirements would make it impossible for thousands of family-scale organic dairy producers to comply. Since a previous recommendation already requires one traditional stall per animal, indoor space requirements for dairy producers with stall barns are unnecessary.
Furthermore, I strongly object to the inclusion of any synthetic nutrient ingredient in organic food without the careful review by the NOSB, which is legally mandated.
Please do not water down the working definition of organic agriculture and food production!
Sincerely yours,
Your name
Friday, April 8, 2011
Thursday, February 3, 2011
Help Preserve the Right to Raise Free Range Poultry
Help Preserve the Right to Raise Free Range Poultry
After initially outlawing raising domestic Muscovy ducks, the Fish and Wildlife Service (FWS) still wants to regulate those that raise domestic Muscovy ducks as livestock, and to ban outright keeping domestic Muscovy ducks as pets.
Muscovy ducks have a long history of domestication dating back to the 1500s. This history of domestication is very similar to that of the turkey. Domestic Muscovy ducks are livestock and have been raised as livestock around the world for hundreds of years.
The public comment period for the most recently revised proposed regulations ended Dec. 31, 2010. The FWS has received numerous public comments insisting that domestic Muscovy ducks are livestock, and therefore not subject to regulation by the FWS. We have been informed that the FWS is considering revising the proposed rule again, but this time exempting domestic Muscovy ducks from any regulation.
ACTION TO TAKE
Letters and e-mails to both Dr Allen at the FWS, and to your elected representatives will help assure that the FWS does exempt domestic Muscovy ducks.
CONTACT INFO
Dr. George Allen at the Fish & Wildlife Service: George_T_Allen@fws.gov
Your congressperson: https://writerep.house.gov/writerep/welcome.shtml
Your senator: http://www.senate.gov/general/contact_information/senators_cfm.cfm
SAMPLE LETTER
I am contacting you in regard to the proposed regulations by the Fish and Wildlife Service regarding Muscovy ducks (Docket No. FWS-R9-MB-2010-0037), urging you not to propose any additional restrictions on raising Muscovy ducks.
The Fish and Wildlife Service (FWS) has failed to recognize the long history of the domestic Muscovy as livestock. Domestic Muscovy ducks have been raised as livestock since the 1500s. As livestock they should not be subject to U S Fish and Wildlife regulations.
The U S Fish and Wildlife Service should recognize a distinction between wild Muscovy ducks and the domestic Muscovy ducks that have been raised as livestock all across the world for hundreds of years.
It is my understanding that the problems with feral Muscovy ducks that prompted these regulations are, for the most part, limited to Florida and possibly Chicago. Considering our country's current budget deficits, why would the FWS propose new regulations that have to be implemented and enforced all across the United States?
I see no problem with the portion of the rules (21.54 Control order for muscovy ducks in the United States) that allows localities to control feral populations of Muscovies that have become a problem. There does not appear to be any conflict between this control order and recognizing domestic Muscovies as livestock and exempting them from this regulation.
I strongly urge the FWS to limit their revision of 21.14 (Permit exceptions for captive-bred migratory waterfowl other than mallard ducks) to include only following:
1) Domestic Muscovy ducks have a long history of domestication and have long been raised as livestock both in the United States and around the world. Muscovy ducks that are owned as livestock (for the production of meat, eggs, or breeding stock), pets, or for exhibition shall be considered domestic Muscovy ducks.
2) No migratory bird permit(s) shall be required to possess, propagate, or sell (as live birds, meat, or eggs) domestic Muscovy ducks.
3) The intentional release of domestic Muscovy ducks to the wild shall be prohibited.
4) You may not take Muscovy ducks or their eggs from the wild , unless such taking is provided for elsewhere in this subchapter.
5) 21.54 Control order for muscovy ducks in the United States shall remain in effect without revision.
Do not place any additional restrictions on domestic Muscovy ducks!
Sincerely,
****
Tuesday, December 7, 2010
Food Safety Bill Fight Continues
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
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
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
***
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