The extended deadline is now THIS FRIDAY, November 22nd. Here's the NSAC Action Page again for more details on how to submit your comment.
Thanks again to Emily! Here's her comment:
Re: Preventive Controls Rule: FDA-2011-N-0920, Produce Standards Rule: FDA-2011-N-0921
Food safety is a major concern that all consumers share. However, as a consumer, I am shocked and dismayed to learn about these proposed rules and the impact they could have on small farms—particularly those that use organic, sustainable farming methods. In recent years, along with millions of other Americans, I have become aware of the enormous threat to our health, environment, and future agricultural potential posed by large-scale industrial farming operations. Not only are toxic pesticides and fertilizers (and the processed food that our industrial system produces) threatening our short-term health, but massive soil degradation and erosion caused by industrial methods is stripping our beautiful and fertile land of its long-term ability to support a healthy population.
It is incredible to see the growing popularity of farmers’ markets—as a city-dweller, I am extremely lucky to live a few blocks from a wonderful weekly market that sells local, organic produce and some processed items such as jam and baked goods. The amount of organic produce now available even in mainstream grocery stores is amazing and a testament to the fact that many of us are voting with our wallets. Consumers want organic food; they want local options; they want diversity; they want the beauty and productivity of the countryside to be protected; and they want farming to remain a viable career choice for families who have farmed for generations, as well as for the growing number of young people who are passionate about improving our food supply by farming themselves.
More broadly, as an American citizen, I feel disenfranchised. I feel that the voices involved in drafting rules such as these must be the voices of corporate lobbyists. I can only assume that this is the case because I don’t think that the rules reflect what average citizens and consumers would choose if they were aware of what is at stake (mainstream media coverage of these detailed regulations has been minimal, unsurprisingly). As a parent, I cannot overstate my concern about what processed, shelf-stable food based on government-subsidized corn and soy inputs, and the associated environmental degradation, is doing to our children’s health. I question where we are headed as a society when we have already lain waste to our fields, rivers, and bays, and yet we make regulations that enable and encourage more of the same rather than attempting to mend our ways.
There is a massive awakening underway about the linkages between our health, our food, and the future of our country. More and more people are concerned about these issues. My fear is that these rules could drive the last nail in the coffin of local, sustainable food economies—just when people are realizing what has been lost over the last few decades and deciding that they want to recover it. I believe it is not an overstatement to say that this would be a tragedy of epic proportions. We cannot allow this to happen and I expect our government to work for, not against, the interests of consumers like me. An entirely large-scale, industrialized farming sector is simply not sustainable. We cannot indefinitely increase chemical inputs to increase yields. We cannot indefinitely increase the use of fossil fuels to transport inputs and products. We cannot expect our air to be clean, our food to be safe, and our water to be potable if we continue down the current path.
In short, we need an overhaul of policies and regulations related to food production and distribution. In the last couple of decades, billions of dollars have been spent and pages of regulations have been written to subsidize and support precisely the wrong kinds of practices. Time is running out to undo the damage that has been done. We need a framework that creates incentives for—rather than incapacitates—small-scale, sustainable, organic farming and local food economies. As far as the proposed rules referenced here, at a minimum, I submit that they should be revised substantially (as proposed by the National Sustainable Agriculture Coalition) in order to:
- Allow farmers to use sustainable farming practices, including those already allowed and encouraged by existing federal organic standards and conservation programs.
- Ensure that diversified and innovative farms, particularly those pioneering models for increased access to healthy, local foods, continue to grow and thrive without being stifled.
- Provide options that treat family farms fairly, with due process and without excessive costs.