TODAY IS THE LAST CHANCE TO SUBMIT YOUR COMMENT TO THE FDA! ACT NOW! DON'T WAIT!
Here's the NSAC Action Page, where you find all you need to know.
If you are still unsure what to say, you can read over the past few blog posts and follow the links. Or you can read what Jim submitted. Please do not copy and paste his comments, but feel free to use his ideas as a basis for your own. And thank you for taking the time out of your busy day to stand up for us and farms like ours!
Jim's Comment
To the US Food and Drug Administration:
I would like to submit a comment on the “Produce Rule” FDA-2011-N-0921.
I have made my living and supported my family as a vegetable farmer for forty-one years, since 1972. I grow about sixty different crops on about thirty acres in Pennsylvania, and market my produce directly to consumers at farmers markets in Washington, DC. My farm is certified-organic by USDA and has been certified since 1987 by various agencies before USDA certification existed. I was motivated to become an organic farmer by concerns about food safety and the environment. In my forty-one years of farming--using methods that the proposed rules would prohibit--and having sold probably millions of pounds of food to at least many thousands of consumers in Washington, DC, no one has ever, to my knowledge, been sickened by eating food grown by me, or for that matter, grown by any others of the hundreds of family farmers in my acquaintance around the country.
Having studied the proposed rules, I believe that these rules are unnecessary, overly burdensome, will have a negative impact on both food safety and the environment, and will make it difficult for me to continue to operate my farm business, which my customers value highly, since it supplies them with safe, nutritious, high-quality, fresh food. Following are a few of the many objections I have to the proposed rules:
1. Raw animal manure is at the heart of my fertility program for my farm. It is economical, very effective, totally harmless, and has been used liberally by farmers for thousands of years. In today’s agriculture, animals are usually highly concentrated, creating sources of manure far too concentrated to be used for fertility by farms near the sources. Therefore disposal of manure has become a major environmental problem. Farmers such as myself, who do use this excellent resource, are disposing of it safely and usefully, preventing it from being land-filled (and thus wasted) or spread so intensively near the sources, that the result is pollution of the nearby environment. With regard to the alleged harmfulness of manure, any farmer who cares for animals, including myself with my three-hundred laying hens, can testify to the harmlessness of manure. Farmers live with raw manure every day of their lives, and I have never heard of any farmer or farm family who has been sickened by exposure to manure. The new rules would prohibit the use of raw manure, except under conditions that make that use unfeasible. The alternative suggested, compost (very strictly defined), is far more expensive (and energy-intensive) than manure because of the high cost of processing, and is, in any case, unavailable to most farmers. Without using manure I would be unable to affordably maintain fertility for my crops, resulting in loss of yield and degradation of quality.
2. Use of water from our nearby creek is what keeps my crops growing, and I have been using this water on my crops with no bad effects for forty-one years. In my climate, and considering the high value of what I grow, I could not operate at all without the constant use of irrigation. The water in our creek is relatively clean, but it is surface water, subject to constant “pollution” by the waste of the wildlife around it. The proposed rules would not only force me to conduct expensive, frequent testing of this water, but would prohibit my use of it when it failed to pass some arbitrary standards of purity.
3. Average annual sales of produce from my farm are considerably above $500,000, causing me to be considered a “large” operation, which can presumably afford the high additional costs of complying with the proposed rules. And yet my net income is normally less than ten percent of sales, which means that I cannot maintain adequate profitability if tens of thousands of dollars of new costs are added by compliance with the new rules.
4. The proposed rules are so burdensome (and without compensating benefits to anyone), that younger people considering entering the farming business would be strongly discouraged. My personal experience proves that it is already very challenging to make a living at farming in this country, which is the reason that the average age of farmers has been increasing over recent decades. Thus we need to encourage, not discourage, young people to become farmers. I fear that without a new generation of farmers I will be unable to retire and sell my farm, and the country will have to drastically increase importation of food from other countries, which do not have the burdens of “safe food” regulations such as we would have.
These are a few of the many reasons I respectfully suggest that the proposed produce rules affecting farmers should be drastically reexamined and reconsidered. Thank you for your consideration.
Need more inspiration? The PA Farmer's Union submitted this comment. And check out these resources from The Cornucopia Institute: their White Paper has great in-depth info, and, if you are unsure what to say but know you want to say something, use their Proxy Letter to print and mail back. Use this page to find all the Food Safety info, including instructions for the proxy letter.
Here's the NSAC Action Page, where you find all you need to know.
If you are still unsure what to say, you can read over the past few blog posts and follow the links. Or you can read what Jim submitted. Please do not copy and paste his comments, but feel free to use his ideas as a basis for your own. And thank you for taking the time out of your busy day to stand up for us and farms like ours!
Jim's Comment
To the US Food and Drug Administration:
I would like to submit a comment on the “Produce Rule” FDA-2011-N-0921.
I have made my living and supported my family as a vegetable farmer for forty-one years, since 1972. I grow about sixty different crops on about thirty acres in Pennsylvania, and market my produce directly to consumers at farmers markets in Washington, DC. My farm is certified-organic by USDA and has been certified since 1987 by various agencies before USDA certification existed. I was motivated to become an organic farmer by concerns about food safety and the environment. In my forty-one years of farming--using methods that the proposed rules would prohibit--and having sold probably millions of pounds of food to at least many thousands of consumers in Washington, DC, no one has ever, to my knowledge, been sickened by eating food grown by me, or for that matter, grown by any others of the hundreds of family farmers in my acquaintance around the country.
Having studied the proposed rules, I believe that these rules are unnecessary, overly burdensome, will have a negative impact on both food safety and the environment, and will make it difficult for me to continue to operate my farm business, which my customers value highly, since it supplies them with safe, nutritious, high-quality, fresh food. Following are a few of the many objections I have to the proposed rules:
1. Raw animal manure is at the heart of my fertility program for my farm. It is economical, very effective, totally harmless, and has been used liberally by farmers for thousands of years. In today’s agriculture, animals are usually highly concentrated, creating sources of manure far too concentrated to be used for fertility by farms near the sources. Therefore disposal of manure has become a major environmental problem. Farmers such as myself, who do use this excellent resource, are disposing of it safely and usefully, preventing it from being land-filled (and thus wasted) or spread so intensively near the sources, that the result is pollution of the nearby environment. With regard to the alleged harmfulness of manure, any farmer who cares for animals, including myself with my three-hundred laying hens, can testify to the harmlessness of manure. Farmers live with raw manure every day of their lives, and I have never heard of any farmer or farm family who has been sickened by exposure to manure. The new rules would prohibit the use of raw manure, except under conditions that make that use unfeasible. The alternative suggested, compost (very strictly defined), is far more expensive (and energy-intensive) than manure because of the high cost of processing, and is, in any case, unavailable to most farmers. Without using manure I would be unable to affordably maintain fertility for my crops, resulting in loss of yield and degradation of quality.
2. Use of water from our nearby creek is what keeps my crops growing, and I have been using this water on my crops with no bad effects for forty-one years. In my climate, and considering the high value of what I grow, I could not operate at all without the constant use of irrigation. The water in our creek is relatively clean, but it is surface water, subject to constant “pollution” by the waste of the wildlife around it. The proposed rules would not only force me to conduct expensive, frequent testing of this water, but would prohibit my use of it when it failed to pass some arbitrary standards of purity.
3. Average annual sales of produce from my farm are considerably above $500,000, causing me to be considered a “large” operation, which can presumably afford the high additional costs of complying with the proposed rules. And yet my net income is normally less than ten percent of sales, which means that I cannot maintain adequate profitability if tens of thousands of dollars of new costs are added by compliance with the new rules.
4. The proposed rules are so burdensome (and without compensating benefits to anyone), that younger people considering entering the farming business would be strongly discouraged. My personal experience proves that it is already very challenging to make a living at farming in this country, which is the reason that the average age of farmers has been increasing over recent decades. Thus we need to encourage, not discourage, young people to become farmers. I fear that without a new generation of farmers I will be unable to retire and sell my farm, and the country will have to drastically increase importation of food from other countries, which do not have the burdens of “safe food” regulations such as we would have.
These are a few of the many reasons I respectfully suggest that the proposed produce rules affecting farmers should be drastically reexamined and reconsidered. Thank you for your consideration.
Need more inspiration? The PA Farmer's Union submitted this comment. And check out these resources from The Cornucopia Institute: their White Paper has great in-depth info, and, if you are unsure what to say but know you want to say something, use their Proxy Letter to print and mail back. Use this page to find all the Food Safety info, including instructions for the proxy letter.
Markets
Our markets are still going strong this fall! We have amazing winter greens, sweet potatoes, leeks, potatoes, and great root veggies. This is our last week for broccoli and for our romanesco cauliflower. It's that time of year, unfortunately! But we still have so much good stuff! Like our Brussels Sprouts! We will have stalks of brussels at both markets this week. Brussels are so delicious, so just forget their bad childhood associations! These cruciferous veggies are super healthy too, so give them another try! One of the easiest and tastiest ways to prepare them are roasting them: just pop them off the stalk, remove a layer of outer leaves (if they are too ugly), cut in half, toss with olive oil and salt, and roast until browned at 400 degrees. Delicious!
But if you want a bit more complexity to your brussels dish, check out these links that Heather found for us!
Real Simple's Baked Potatoes with Brussels Sprouts
Roasted Brussels Sprouts with Maple Balsamic Drizzle
But if you want a bit more complexity to your brussels dish, check out these links that Heather found for us!
Real Simple's Baked Potatoes with Brussels Sprouts
Roasted Brussels Sprouts with Maple Balsamic Drizzle
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